Matter of Knapp

2025 NY Slip Op 34089(U)
CourtSurrogate's Court, New York County
DecidedOctober 30, 2025
DocketFile No. 2019-2020
StatusUnpublished

This text of 2025 NY Slip Op 34089(U) (Matter of Knapp) is published on Counsel Stack Legal Research, covering Surrogate's Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Matter of Knapp, 2025 NY Slip Op 34089(U) (N.Y. Super. Ct. 2025).

Opinion

Matter of Knapp 2025 NY Slip Op 34089(U) October 30, 2025 Surrogate's Court, New York County Docket Number: File No. 2019-2020 Judge: Rita Mella Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. ENTERED OCT 3 0 2025 SURROGATE'S COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK DATA ENTRY DEPT New York County Surroyate's Court ------------------------------------------------------------------------x Probate Proceeding, Will of

ALICIA KNAPP, DECISION a/k/a ALICIA CASTRUCCI-KNAPP, File No.: 2019-2020 Deceased. ------------------------------------------------------------------------x MELLA, S.:

The court considered the following submissions in deciding this motion for summary judgment:

Papers considered Numbered

Petitioner's Notice of Motion for Summary Judgment; Affirmation of Alison Arden Besunder, Esq, in Support of Petitioner's Motion, with Exhibits 1,2

Affirmation of Rossupron Pitagtum in Support of Petitioner's Motion for Summary Judgment 3

Petitioner's Statement of Undisputed Material Facts; Memorandum of Law in Support of Motion for Summary Judgment 4,5

Objectant Jessica Phillips's Affirmation in Opposition to Motion for Summary Judgment; Affirmation of A.M. Richardson, Esq, in Opposition to Motion, with Exhibits 6,7

Objectant Jessica Phillips's Response to Movant's Statement of Facts; Objectant's Counter Statement of Facts 8,9

Objectant Jessica Phillips' s Brief in Opposition to Motion for Summary Judgment

Petitioner's Reply Memorandum of Law in Support of Motion for Summary Judgment 11

In this contested probate proceeding in the estate of Alicia Knapp (Decedent), the

Temporary Administrator, Rossupom Pitagtum (Proponent) sought summary dismissal (CPLR

3212) of the objections to her appointment as Executor, filed by Jessica Baldwin Phillips

[* 1] (Phillips or Objectant). At the call of the calendar on May 20, 2025, the court granted the motion

and dismissed the objections for the reasons stated below.

Background

Decedent died on September 1, 2018, survived by three first cousins as her distributees.

In the propounded instrument, dated January 4, 2017, Decedent left her cooperative apartment to

Proponent, whom she nominated as Executor, and directed that her residuary estate be

distributed to an inter vivos trust, also established on January 4, 2017 (Trust). 1 Proponent, who

was Decedent's caregiver and friend, is also the Trustee of the Trust and the recipient of its

remainder upon Decedent's death and after the payment of cash bequests to nine individuals, one

of whom is Phillips. Phillips, who is Decedent's cousin twice removed, and therefore not a

distributee (see EPTL 4-1.1 ), then filed objections limited to the "issuance of letters

testamentary" to Proponent, alleging lack of capacity, fraud, and undue influence (Objections).

She did so based upon her status as a beneficiary of Decedent's estate. No other objections were

filed. 2 After the court-ordered deadline for discovery had passed, Proponent made the instant

motion for summary judgment.

Discussion

A motion for summary judgment may be granted where a movant makes a "prima facie

showing of entitlement to judgment as a matter of law, tendering sufficient evidence to

demonstrate the absence of any material issue of fact" (Alvaraz v Prospect Hospital, 68 NY2d

1 Proponent initially offered a copy of the propounded instrument for probate (SCPA 1407) and sought Letters of Temporary Administration, which issued to her on June 11, 2019. When the original instrument was located, Proponent amended her petition to seek probate of the original.

2 One distributee, who had waived process and consented to probate, moved to withdraw his consent. The court denied the motion, which decision was affirmed (Matter of Knapp, 220 AD3d 529 [ l st Dept 2023]).

[* 2] 320, 324 [I 986]). A movant's "[fJailure to make such showing requires denial of the motion,

regardless of the sufficiency of the opposing papers" (Winegrad v New York Univ. Med. Ctr., 64

NY2d 851, 853 [1985]). If the burden is satisfied, the parties opposing the motion must "lay

bare and reveal [their] proofs" and demonstrate that there are material issues of fact "capable of

being established [at] a trial" (DiSabato v Soffes, 9 AD2d, 297,301 [1st Dept 1959]). Ifthere is

any doubt as to the existence of a triable issue, the motion must be denied (Prevost v One City

Block LLC, 155 AD3d 531, 533 [1st Dept 2017]).

As an initial matter, the court addressed the issue of Objectant's standing to file

objections. The court determined that, as a beneficiary who is not a distributee, Objectant had

standing to file objections to probate but only as to that portion of the will that nominates

Proponent as Executor and to the issuance of Letters Testamentary to her (see SCPA 1410;

Matter of Brumer, 69 AD2d 438 [2d Dept 1979]). Thus, the court concluded that Objectant

could object but only to the extent that the Objections: 1) were grounded on SCPA 709, which

allows any person interested in a decedent's estate to file objections to the issuance of letters to

"persons about to receive them," and 2) refer to any of the legal objections concerning eligibility

to serve set forth in SCPA 707.

With regard to Proponent's request for summary dismissal of Objections, the court

determined that Proponent made out a prima facie case of entitlement to judgment as a matter of

law on Objectant's claim that Proponent is ineligible to serve as fiduciary. Specifically,

Proponent established that she is not an infant, that she has not been found to be incompetent,

and that she is not a non-domiciliary noncitizen (see SCPA 707[1 ]). Through her affirmation,

Proponent also established that she is able to read and write the English language, has never been

[* 3] convicted of a felony, and does not possess any of the disqualification grounds described in

SCPA 707(1)(d).

In opposition, Objectant failed to raise any triable issue of fact as to Proponent's fitness

to serve and her eligibility to receive letters pursuant to SCP A 707. The court found without

merit Objectant's contention that Proponent has acted "dishonestly" and therefore was

disqualified to serve as fiduciary. In order to defeat Proponent's motion, Phillips was required to

raise an issue of fact concerning Proponent's dishonesty by making a "strong showing that

Petitioner has committed improper acts related to money matters" (Matter of Fink, NYLJ, Apr.

11, 2012, at 17, col 1 [Sur Ct, Bronx County], citing Matter of Flood, 236 NY 408, 411 [ 1923 ];

Matter o.f Latham, 145 App Div 849,854 [1st Dept 1911]). That is the case because dishonesty,

as contemplated by SCPA 707( 1)(d), refers to dishonesty in financial matters, and the party

claiming dishonesty as a basis for disqualification must establish "a reasonable apprehension ...

that the funds of the estate would not be safe in the hands of the executor" (Matter of Gottlieb, 75

AD3d 99, 107 [1st Dept 2010]). In her opposition papers, however, Objectant failed to

demonstrate through probative and admissible evidence the existence of a material question of

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Related

In Re Proving the Will of Leland
114 N.E. 854 (New York Court of Appeals, 1916)
In Re Proving the Will of Flood
140 N.E. 936 (New York Court of Appeals, 1923)
Prevost v. One City Block LLC
2017 NY Slip Op 8303 (Appellate Division of the Supreme Court of New York, 2017)
In re Proving the Last Will & Testament of Latham
145 A.D. 849 (Appellate Division of the Supreme Court of New York, 1911)
Winegrad v. New York University Medical Center
476 N.E.2d 642 (New York Court of Appeals, 1985)
People v. McDonald
496 N.E.2d 844 (New York Court of Appeals, 1986)
Di Sabato v. Soffes
9 A.D.2d 297 (Appellate Division of the Supreme Court of New York, 1959)
In re the Estate of Gottlieb
75 A.D.3d 99 (Appellate Division of the Supreme Court of New York, 2010)
In re Estate of Brumer
69 A.D.2d 438 (Appellate Division of the Supreme Court of New York, 1979)
In re the Estate of Marsh
179 A.D.2d 578 (Appellate Division of the Supreme Court of New York, 1992)

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Bluebook (online)
2025 NY Slip Op 34089(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/matter-of-knapp-nysurctnyc-2025.