In the Matter of the Estate of Paul Nigito

CourtNew Jersey Superior Court Appellate Division
DecidedDecember 27, 2024
DocketA-2013-22
StatusUnpublished

This text of In the Matter of the Estate of Paul Nigito (In the Matter of the Estate of Paul Nigito) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Matter of the Estate of Paul Nigito, (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-2013-22

IN THE MATTER OF THE ESTATE OF PAUL NIGITO, deceased.

Submitted October 17, 2024 – Decided December 27, 2024

Before Judges Currier, Marczyk, and Torregrossa- O'Connor.

On appeal from the Superior Court of New Jersey, Chancery Division, Bergen County, Docket No. P- 000218-21.

Giordano, Halleran & Ciesla, PC, attorneys for appellant/cross-respondent Ann Mae Nigito (Michael J. Canning, of counsel and on the briefs).

Albert Buzzetti & Associates, LLC, attorneys for respondents Paul Nigito, Anthony Nigito, TNO2, LLC, and 400 Main Street, LLC, and respondent/cross- appellant Estate of Antoinette Nigito (Steven M. Davis, of counsel and on the briefs).

Sherman Atlas Sylvester and Stamelman LLP, attorneys for respondent Frank Brunetti (Anthony J. Sylvester and Anthony C. Valenziano, of counsel and on the brief). PER CURIAM

This matter arises from Ann Mae Nigito's (Nigito) challenge to the

funding of a generation skipping trust (GST) established by her father, decedent

Paul Nigito, under his will. Paul's1 will created a GST to benefit his wife,

Antoinette, during her lifetime; then his daughter, Nigito, during her lifetime;

and finally, Nigito's children. After Paul's death in 2001, Antoinette, as executor

and co-trustee, refused to fully fund the GST and defunded it entirely before she

died. After Nigito sought an accounting of the estate and other related relief

following Antoinette's death, the court awarded Nigito the sum that Antoinette

should have placed in the GST, plus interest.

Nigito appeals from the damages award, and the court's denial of her

request to add a punitive damages count against Antoinette. In a cross-appeal,

the Estate of Antoinette Nigito contends the court erred in awarding Nigito

counsel fees. After a careful review, we affirm the court's orders with the

exception of the denial of Nigito's request for additional attorney's fees in the

February 16, 2023 order. Because the court did not provide any reasons for the

1 Since several individuals share a surname, we refer to them by their first names. No disrespect is intended. A-2013-22 2 denial of the application, we remand on that narrow issue for the court to provide

its reasons under Rule 1:7-4(a).

I.

At the time of Paul's death, his estate held nearly $19,000,000 in assets,

which included real estate holdings, comprised of some income-producing real

properties held in various entities such as "TNO2, LLC" and "Ward Realty O2,

LLC."

Article Eighth of the will provided that some of the estate would pass to a

GST:

EIGHTH: This Article Eighth, otherwise referred to as Generation-Skipping Trust, shall be administered and managed by my Trustee, who shall invest and manage the property, and shall make distributions as follows:

A. My Trustees shall hold in trust, upon the following terms and conditions:

1. To invest and reinvest the same and, from the date of my death, to pay my spouse, the entire income, quarter- annually, including any accrued income at the time of the death of my said spouse. My Trustees, other than my spouse, shall also pay to my said spouse such part or all of the principal as my Trustees (other than my spouse), in their discretion, deem necessary or advisable for my said spouse. My wife shall not have the discretion to distribute principal. The judgment of my Trustees (other than my spouse), as to the amount of such payments or applications of principal and as to the necessity or advisability thereof, shall be final and

A-2013-22 3 conclusive upon all persons interested in the trust and upon making such payments or applications, my Trustees shall be fully released and discharged from all further liability or accountability therefor. In exercising the Trustee's discretion, the Trustee (other than my spouse) may, but shall not be required to take into consideration any other income or property owned by my spouse or that my spouse may (and shall not be required to legally or otherwise) transfer the property distributed to my spouse. Distribution of principal shall be charged to the elected qualified terminable interest trust.

2. My said spouse shall have the right to require that the assets of this trust be income-producing.

3. Notwithstanding the foregoing, if my said spouse (or her personal representative, guardian, agent acting under a power of attorney or the fiduciaries of her estate) shall disclaim my spouse's interest in any part of all of this Trust, then the part of all of this trust over which my spouse has disclaimed my spouse's interest shall pass to Paragraph B of this Article Eighth.

4. Upon the death of my said spouse, or upon my death if my said spouse shall predecease me, my Trustees shall distribute the then balance of this Trust to Paragraph B of Article EIGHTH herein.

The original trustees were Antoinette and Robert Pless.

Article Fourteenth "exculpated" Pless "from any and all liability as a

result" of conflicts of interest arising from the administration of the GST and

exonerated him "from any liability in connection with the administration of any

trust or my estate and if any suit or action is ever brought or initiated against"

A-2013-22 4 him. Article Tenth provided that any "successor trustee shall have the same

rights, titles, powers, duties, discretions and immunities and otherwise be in the

same position as if originally named trustee."

Article Eighth (B) created a "Sprinkle Trust" upon Antoinette's death.

That trust would distribute the GST's income and principal to Nigito, and upon

her death, the Sprinkle Trust would distribute the remaining principal to Nigito's

descendants. Article Ninth of the will required the trustees to "maximize the

amount of trust property that eventually may be distributed to my grandchildren

or more remote descendants without transfer tax of any kind."

Under Article Fourth, Antoinette was directed, as executor, "to set aside

an amount equal to the balance of" the GST. At the time of Paul's death, that

amount was $1,060,000.

Prior to Antoinette's death, the only funds contributed to the GST came

from TNO2, LLC, which held a 50% ownership interest in real property on

Essex Street in Hackensack (the Essex property). The Essex property produced

rental income of approximately $227,000 a year, and was appraised in 2008 with

a valuation of $1.3 million. Therefore, in March 2009, Pless calculated the GST

had $650,000 in funds—50% share of the Essex property's $1.3 million

valuation.

A-2013-22 5 Later that year, Pless advised Antoinette's accountant that the GST was

short of its "initial obligation of $1,060,000" because it held only $650,000 . He

requested the accountant "coordinate" with Antoinette "on the appropriate assets

to complete the funding." Over the next year, Pless continued to request the

accountings for the GST, advising the accountant the GST "must be completely

funded."

In July 2010, Antoinette wrote to Pless stating:

I want to close as soon as possible the funding of the [GST].

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In the Matter of the Estate of Paul Nigito, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-matter-of-the-estate-of-paul-nigito-njsuperctappdiv-2024.