Estate Of Michael Cohen

CourtCourt of Appeals of Washington
DecidedMay 9, 2023
Docket56662-1
StatusUnpublished

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Bluebook
Estate Of Michael Cohen, (Wash. Ct. App. 2023).

Opinion

Filed Washington State Court of Appeals Division Two

May 9, 2023

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II In the Matter of the Estate of: No. 56662-1-II (Consol. with MICHAEL COHEN, No. 56759-8-II)

Deceased. UNPUBLISHED OPINION

LEE, J. — Loren Cohen appeals the superior court’s orders removing Cohen as the personal

representative of his father’s (Michael Cohen’s) estate and appointing a third-party neutral as

successor personal representative to his father’s estate. Cohen argues that the superior court erred

by removing him as personal representative and appointing a third-party neutral instead of Cohen’s

brother, Lee Cohen,1 as successor personal representative.

We hold that the superior court did not err by removing Cohen as personal representative

due to a conflict of interest or by appointing a third-party neutral instead of Lee, who also had a

conflict of interest, as successor personal representative. Therefore, we affirm the superior court’s

orders.

FACTS

Michael Cohen died in December 2020. The decedent’s will, executed in October 2020,

states that all of the decedent’s business assets were “transferred and sold to my eldest son Loren

McBride Cohen prior to my death and I do not own any business assets at the time of my death.”

1 Michael Cohen and his sons Loren Cohen and Lee Cohen all share the same last name. To avoid confusion, this opinion refers to Michael Cohen as “the decedent,” to Loren Cohen as “Cohen,” and to Lee Cohen as “Lee.” No disrespect is intended. No. 56662-1-II/No. 56759-8-II

Clerk’s Papers (CP) at 56. The decedent’s will nominated as personal representative of the estate

the decedent’s sons Cohen or Lee, in order of preference and succession. The decedent’s will

authorized the personal representative to have nonintervention powers.

Cohen presented the decedent’s will and moved for the superior court to appoint him as

personal representative of the decedent’s estate. Despite the will allowing for nonintervention

powers, Cohen expressly stated that he was not making a request for nonintervention powers “and

expect[ed] he [would] serve with full intervention until further order of this Court.”2 CP at 66.

The superior court admitted the will to probate and appointed Cohen to serve as personal

representative of the estate. The superior court did not grant nonintervention powers to Cohen.

William Newcomer filed a creditor’s claim with the estate. Newcomer’s creditor’s claim

alleged that the decedent owed Newcomer money on an unpaid promissory note. Newcomer had

initiated a lawsuit against the decedent on the promissory note claim in 2016, but the case had not

yet been fully litigated at the time Newcomer made his creditor’s claim against the estate.

In the probate proceeding, Newcomer requested a copy of the estate inventory from Cohen

pursuant to RCW 11.44.015(2).3 Cohen did not provide Newcomer with the requested estate

inventory, requiring Newcomer to file a motion to compel production of the estate inventory.

Subsequently, Cohen produced a preliminary inventory and appraisement. The preliminary estate

2 The record does not show Cohen requesting nonintervention powers at any point. 3 RCW 11.44.015(2) provides in relevant part that

upon receipt of a written request for a copy of the inventory and appraisement from any . . . unpaid creditor who has filed a claim, . . . the personal representative shall furnish to the person, within ten days of receipt of a request, a true and correct copy of the inventory and appraisement.

2 No. 56662-1-II/No. 56759-8-II

inventory and appraisement contained some unknown sums, but the sums provided showed the

estate’s liabilities outvaluing its assets.

After receiving the preliminary estate inventory and appraisement, Newcomer sent a letter

to Cohen regarding the personal representative’s statutory duty under RCW 11.48.1404 to recover

fraudulent conveyances. Newcomer’s letter stated that the decedent had previously attested under

penalty of perjury that the decedent owned more than $20,000,000.00 in business assets, and these

business assets were not included on the estate inventory. Because the will expressly states that

the decedent transferred all his business assets to Cohen prior to the decedent’s death, Newcomer

alleged that these business assets had been fraudulently transferred to Cohen. Newcomer also

stated that Cohen had a conflict of interest as the recipient of the transfers and told Cohen to either

transfer all business assets back to the estate or resign as personal representative.

Newcomer then filed a joint motion with another creditor of the estate5 to remove Cohen

as personal representative and appoint a third-party neutral. Newcomer’s motion alleged that the

4 RCW 11.48.140 provides that

[w]hen there shall be a deficiency of assets in the hands of a personal representative, and when the deceased shall in his or her lifetime have conveyed any real estate, or any rights, or interest therein, with intent to defraud his or her creditors or to avoid any right, duty, or debt of any person, or shall have so conveyed such estate, which deeds or conveyances by law are void as against creditors, the personal representative may, and it shall be his or her duty to, commence and prosecute to final judgment any proper action for the recovery of the same, and may recover for the benefit of the creditors all such real estate so fraudulently conveyed, and may also, for the benefit of the creditors, sue and recover all goods, chattels, rights, and credits which may have been so fraudulently conveyed by the deceased in his or her lifetime, whatever may have been the manner of such fraudulent conveyance. 5 The other creditor was Peoples Bank, which is not a party to this appeal.

3 No. 56662-1-II/No. 56759-8-II

decedent, shortly before his death, fraudulently transferred tens of millions of dollars in assets to

Cohen for the purpose of avoiding creditors. Newcomer’s motion relied on a statement the

decedent made under oath in 2018 that the decedent owned more than $20,000,000.00 in business

assets, the fact that these assets did not appear on the estate inventory, and the fact that the

decedent’s will stated that the decedent’s business assets were transferred to Cohen prior to death.

Newcomer argued that Cohen was conflicted out of serving as personal representative

because Cohen could not fulfill the statutory duty for personal representatives to investigate and

pursue recovery of fraudulent transfers. Newcomer cited RCW 11.68.0706 as the procedure for

removing a personal representative and appointing a successor.

Cohen opposed the motion, arguing, in relevant part, that Newcomer lacked standing to

bring the motion and did not follow the procedures outlined in RCW 11.68.070, which Cohen

contended required initiation of a Trust and Estate Dispute Resolution Act (TEDRA) action under

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