Professional Documents
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Ante Litem Notice - Probate Court
Ante Litem Notice - Probate Court
SAVAGE
ROBERT BARTlEY TURNER
KATHRYN HUGHES PINCKNEY
BRENT J. SAVAGE . JR .
W ilLIAM K. OTTO
DAPHNE S. WITHROW
TINA CH ENG
SAMUel W. HUGH ES
ANDR EW J. CONN
SAVAG E
TURNER
PINCKNEY
L
AT'TO
E.
Re:
Kim Birge
To this end, I am providing the enclosed information, which demonstrates that our
clients' funds were remitted to the Probate Court of Chatham County. This letter is also
submitted pursuant to o. C . G A. 36-11-1, and should be considered presentation of
the claims of our clients to the County Board of Commissioners.
The facts giving rise to these claims are as follows: Under cover ofletter dated
February 29,2012, this firm transmitted five separate checks to the Probate Court Clerk.
Each of these checks represented funds received in settlement of claims arising by virtue
of the explosion at the Imperial Sugar Refmery. Each of the minors below listed lost their
father in the fire.
The funds were received in settlement of the tort claims brought against one of the
nmnerous defendants in the civil litigation. According to Georgia law, approval of the
Probate Court of Chatham County was required before the claims of these minor children
could be settled.
Although each of the minor children identified below had numerous claims arising
from the explosion, the funds that are missing derived from the settlement with just one of
the parties. The minors received the following amounts:
Ashley Williams
KalynByers
Ivonna Habersham
Kwamen Habersham
McKinley Habersham
$ 17,281.25
$ 37,583.33
$ 19,722.22
$ 19,722.22
$ 19,722.22
(A copy of the letter of transmittal, as well as copies of the checks, is attached hereto as
Exhibit A).
The mother of each of these children was appointed as the Conservator of their
child's property. The settlement of each of these claims was approved by Judge Harris
Lewis of the Chatham County Probate Court. Each order of approval requires "counsel
for the Minor [to] remit the settlement funds to the Court within ten (10) days of the entry
ofthis Order." (Copies of each of these order are attached hereto as Collective Exhibit
B).
After transmittal of the funds to the Clerk of Probate Court, this office requested
confi=ation that the funds had been deposited and the location of the deposit account. In
response to inquiry from this office to confuID that the funds had been deposited with the
Probate Court, Ms. Birge confi=ed that each of the above referenced checks had been
received, and further represented that
the Court is bonded and all monies are deposited in interest bearing
accounts for the minors. The Court is solely responsible for these accounts.
Therefore. no information whatsoever. including account numbers or
statement balances will be released to anyone.
(A copy of this letter, and its enclosures, is attached hereto as Exhibit C). Ms. Birge also
provided a copy of a deposit slip, with the account number redacted, showing that
$131,801.24 had been deposited in an account at The Savannah Bank. Handwritten
notations on this deposit slip indicated that funds in addition to those funds belonging to
our client funds were deposited at the same time.
We have recently been advised that Ms. Birge has absconded with the funds which
were held in trust for these minor children, and that the account established at The
Savannah Bank was established without authority of the Probate Court of Chatham
County.
The following infonnation is provided to establish the principal amount of funds
placed with the Probate Court.
Two encroachments have been made on behalf of Ivonna. The first was made in
July of2012, in the amount of $5,900.00. (A copy of the Petition to Encroach is attached
hereto as Exhibit D). The second was made in June of2013, in the amount of $7,300.00.
(A copy of which is attached hereto as Exhibit E).
After these two encroachments, the principal balance in Ivonna Habersham's
probate court account is $6,522.22.
3.
$ 19,722.22
Kwamen reached the age of majority on June 7, 2013. On turning the age of
majority, he received the funds held in his name on or around July 12,2013.
5.
$ 17,281.00
$ 6,522.22
$ 19,722.22
$ 37.583.33
$ 81,108.77
As noted above, McKinley Habersham has reached the age of majority, and is entitled to
immediate possession of his funds. The other minors are entitled to have their funds
placed in a bust account, established for their benefit, where their funds will be safely
maintained until each child reaches the age of majority.
On behalf of McKinley Habersham, Latesha Habersham as Conservator for Ivona
Habersham, Paulette Williams as Conservator for Ashley Williams, and Debbie Byers as
Conservator for Kalyn Byers, please accept this letter as presentation of our claim
pursuant to O. C. G .A. 36-11-1.
These claim have only come to light within the past few days, in response to
numerous inquiries of this office regarding the location of our clients' funds.
We believe the County is responsible for the actions of the Clerk of the Chatham
County Probate Court, and for the negligence of the Judge of the Probate Court in its
failure to properly monitor the actions of Kim Birge, and for fiscal irresponsibility. We
believe the Court through certain of its employees was aware of the gambling problems
Ms. Birge had. To have allowed her free reign with these monies given this knowledge is
wrong. This is especially bad in light of the fact the parents were prohibited by the
Probate Court from placing the money in bust for their own children. Each of these
parents has done a great job in raising these children. They are all exemplary kids. (The
behavior of the Probate Court is certainly not representative of the rest of the judiciary in
Chatham County - it is exemplary. In particular Judge Hennann Coolidge spent literally
years agonizing over these cases to make sure there was a just resolution of these Imperial
Sugar cases for all parties under the law of this State.)
We will seek damages for the lost funds, interest on these funds, other general
damages, as well as attorneys fees and expenses of litigation. We warrant on behalf of
this law firm that we wi ll seek no attorney fees unless and until these children have been
fully compensated.
Please see attached as Exhibits .oF" through "H" a brief history on the deceased
fathers.
These children have lost enough. We call upon the County to make good on the
actions of its employees and representatives.
Enclosures
R. SCOT KRAEUTER
WWW.SA.VAGELAWflJl.~{.NET
(~)12)
Ashley Williams
Kalyn Byers
Ivanna Habersham
Kwamen Habersham
McKinley Habersham
Dear Kim:
As instructed, I have enclosed 5 separate checks lor each of the minors regarding the
Kirby settlement
Please let me know if you need anything else to get these accounts set up.
As always, thank you for your kind assistance.
Very truly yours,
cv\v~
Christann J. Smith
Assistant to Ashleigh R. Madison
/cjs
Enclosure
EXHIBIT
I-fl-
1.11.9151 F.... X
7537
SAVAGE & TURNER, PC
382013612
SAVANNAH, GA 31401
(912) 2311140
02129/2012
o
o
PAY TO THE
ORDER OF
DOLLARS
AlITHQR!ZEDS!GNATURE
MEMO
.. -'-
.-~'_=~-.~~~.---------------~~~~~--------------_..~~~7537
INVOICE
DATE
DESCRIPTION
IINV AMOUNT I
Habersham
02129/2012
Check# I Dale
7537
02129/2012
19.722.22
19.722.22
7536
FIRST CHATHAM BANK
38-2013612
(912) 2311140
02/29/2012
PAY TO THE
ORDER OF Probate Court Clerk of Chatham County
$19,722.22
_.'
Nineteen Thousand Seven Hundred Twenty Two Dollars and 22/100 ...... ., .... * ... "" ...........* ....... "'''' "...,.* .... ..
DOLLARS!
AUTHORIZED SIGt.:ATURE
MEMO
002771.1.,11'
SAVAGE & TURNER, PC
______________~~~~.-______________~~~~7536
r-""'~~-,~~~.INVOICE
DATE
Habersham
0212912012 Kwamen Habersham
Check# 1 Date
7536
0212912012
DESCRIPTION
ilNV AMOUNT I
19,722.22
19,722.22
7535
FIRST CHATHAM BANK
382013612
SAVANNAH, GA 31401
(912) 2311140
02129/2012
PAY TO THE
ORDER OF
$19,722.22
Nineteen Thousand Seven Hun,dred Twenty Two Dollars and 22/100.......**** .............................. u****hh......... ****
DOLLARS
i~
w
AUTHORIZED SIGNAlURE
MEMO
---.----------.-------------""~---------------
00 277 1.1,11'
SAVAGE & TURNER. PC
INVOICE
DESCRIPTION
IINV AMoUNT]5 3 5
Habersham
DATE
02/29/2012
Ivonna Habersham
19,722.22
Check# I Date
7535
02129/2012
19.722.22
7538
SAVAGE & TURNER, PC
382013612
<
II
02/29/2012
PAY TO THE
$37,583.33
Thirty Seven Thousand Five Hundred Eighty Three Dollars and 33/100....
.. .........................,.................... .
DOLLARS
AUTHOAtZED SIGNATURE
MEMO
-I
1I'00753BII' ':0[;
SAVAGE & TURNER, PC
.-~~~-.-.~~,-
INVOICE
Byers
Check# 1 Date
2 20 l, j :II:
00277 Ll,II'
____~________~~~~.-______________~~~~7538
DATE
02/29/2012
Kalyn Byers
DESCRIPTION
7538
02/29/2012
IINV AMOUNT]
37,583.33
37,583.33
7539
FIRST CHATHAM BANK
382013512
(912) 2311140
0212912012
PAY TO THE
$17,281.25
Seventeen Thousand Two Hundred Eighty One Dollars and 25/100 ......... *'"* ............. ",."' ... "'''' .. ,. .... ... .........
DOLLARS
MEMO
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-----
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AUTHORI2ED SIGNAIURE
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. 0__
0027?P,II'
.-~~~-.~~~.---------------~~~~._--------------_r.~~~7539
INVOICE
DATE
DESCRIPTION
IINV AMOUNT I
Williams
02/29/2012
Ashley Williams
Check# 1 Date
7539
02129/2012
17,281.25
17,281.25
,.
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ESTATE NO.
1/'/- 77'-3
PETITION TO COMPROlVIISE
DOUBTFUL CLAIM OF MINOR
ORDER
The foregoing petition having been read and considered, and it appearing upon the
hearing that the facts set out in the petition are true and that said settlement is fair, reasonable and
just, that the same is made in good faith, and will be in the best interest of the said minor and will
advance the interests of said minor;
IT IS HEREBY ORDERED AND ADJUDGED that Petitioner be and is hereby
authorized to consununate said settlement as prayed in said petition, and to execute any and all
agreements, receipts, releases, or other documents necessary or proper to effect such settlement,
and that such agreements, receipts, releases, or other documents shall constitute the full, final,
and complete settlement of any and all actions, causes of action, claims, or demands which the
above-nanled minor may have against those parties to the settlement named in the petition, as
fully and completely as if said minor was of age and had executed said agreements, receipts,
.- ..- ........ -;eTeases:Or'(;the~ documentS indlvidually:-.... .....------- ..----------------.----.-....--.. -....
IT IS HEREBY ORDERED AND ADJUDGED that the settlement funds due to the
minor, as outlined in the Petition to Compromise Doubtful Claim of Miner shall be placed in an
interest-bearing account by the Court and shall be maintained in said account until such time as
the minor reaches the age of majority. Accordingly, counsel for the Minor shall remit the
settlement funds to the Court within 10 (ten) days of the entry of this Order.
IT IS FURTHER: ORDERED that Petitioner be and is hereby 3uthOlized to pay all fees
and expenses shown in paragraph II of the petition from the gross settlement amount.
/ di;vJ/ft/L(~~
EX"',a'T
7539
SAVAGE & TURNER, PC
IOlTA TRUST ACCOUNT
304 EAST BAY STREET
SAVANNAH, GA 31401
(912) 231.1l40
382013612
0212912012
PAYTOTHE
$17,281.25
DOLlARS:
Seventeen Thousand TWD Hundred Eighty One Dollars and 25/100-"..-_ _.... _ - Probate Court Clerk of Chatham County
--
MEMO
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ESTATENO.
B~ [03.51
PETITION TO COMPROMISE
DOUBTFUL CLAIM OF MINOR
ORDER
TIle foregoing petition having been read and considered, and it appearing upon the
hearing that the facts set out ill the petition are true and that said settlement is fair, reasonable and
just, that the same made in good faith, and will be in the best interest of the said minor and will
advance the interests of said minor;
is
IT IS FURTHER ORDERED that Petitioner be and is hereby authorized to pay all fees
and expenses shown in paragraph 11 of the petition from the gross settlement amount.
7538 "
SAVAGE & TURNER, PC
382013612
(912) 2311140
02129/2012
PAYTOTHE
$37.563.33
Thirty Seven Thousand Five Hundred Eighty Three Dollars and 331100'~
Probate Court Clerk of Chatham County
I
DOUARsi
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MEMO
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ESTATE NO.
/-J- '7?3/
PETITION TO COMPROMISE
DOUBTFUL CLAIM OF MINOR
ORDER
The foregoing petition having been read and considered, and it appearing upon the
hearing that the facts set out in the petition are true and that said settlement is fair, reasonable and
just, that the same is made in good faith, and will be in the best interest of the said minor and will
advance the interests of said minor;
IT IS HEREBY ORDERED AND ADJUDGED that Petitioner be and is hereby
authorized to consummate said settlement as prayed in said petition, and to execute any and all
agreements, receipts, releases, or other documents necessary or proper to effect such settlement,
and that such agreements, receipts, releases, or other documents shall constitute the full, final,
and complete settlement of any and all actions, causes of action, claims, or demands which the
above-named minor may have against those parties to the settlement named in the petition, as
fully and completely as if said minor was of age and had executed said agreements, receipts,
releases, or other documents individually.
_'_ _ _
'h
IT IS HEREBY ORDERED AND ADJUDGED that the settlement funds due to the
minor, as outlined in the Petition to Compromise Doubtful Claim of Minor shall be placed in an
-'inierest:'bearlngaccourii by-the'Court and'SliaiTb';-maintained 'in said-iiCCounCuntil such time as
the minor reaches the age of majority. Accordingly, counsel for the Minor shall remit the
settlement funds to the Court within 10 (ten) days of the entry of this Order.
IT IS FURTHER ORDERED that Petitioner be and is hereby authorized to pay all fees
and expenses shown in paragraph 11 of the petition from the gross settlement amount.
Lcft1VI/l./& ~~
7537
SAVAGE & TURNER, PC
382013612
18
0212912012
PAY TO THE
$19,722.22
OOUARS
Iil
MEMO
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ORDER
The foregoing petition having been read and considered, and it appearing upon the
hearing that the facts set out in the petition are true and that said settlement is fair, reasonable and
just, that the same is made in good faith, and will be in the best interest of the said minor and will
advance the interests of said minor;
IT IS HEREBY ORDERED AND ADJUDGED that Petitioner be and is hereby
authorized to consummate said settlement as prayed in said petition, and to execute any and all
agreements, receipts, releases, or other documents necessary or proper to effect such settlement,
and that such agreements, receipts, releases, or other documents shall constitute the full, final,
and complete settlement of any and all actions, causes of action, claims, or demands which the
abovenamed minor may have against those parties to the settlement named in the petition, as
fully and completely as if said minor was of age and had executed said agreements, receipts,
releases, or other documents individually.
- - -.... '-'---;I"'T:-;IS~HE=RE=B"Y;-O;;:RD="'E~RE=D:-AO"'N;-;D"'"""'A'-;D::-J;-;U=DG"'E;-;D::--:-;th-aCt'th:;--e-se"""Ctt:7le-m-e-n~t'fun--:ds-d"";"u-e"""Ct-o "'th-e---' ." .... -- minor, as outlined in the Petition to Compromise Doubtful Claim of Minor shall be placed in an
interest bearing account by the Court and shall be maintained in said account until such time as
the minor reaches the age of majority. Accordingly, counsel for the Minor shall remit the
settlement funds to the Court within ]0 (ten) days of the entry of this Order.
IT [S FURTHER ORDERED that Petitioner be and is hereby authorized to pay all rees
and expenses shown in paragraph I I of the petition from the gross settlement amount.
/@v~~~
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,Prob
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..
7536 "
SAVAGE & TURNER, PC
382013612
SAVANNAH. GA 31401
(912) 2311140
0212912012
PAYTOTHE
$19,722.22
MEMO
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ESTATE NO.
/-1-7<q:L9
PETITION TO COMPROMISE
DOUBTFUL CLAIM OF MINOR
ORDER
The foregoing petition having been read and considered, and it appearing upon the
hearing that the facts set out in the petition are true and that said settlement is fair, reasonable and
just, that the san1e is made in good faith, and will be in the best interest of the said minor and will
advance the interests of said minor;
IT IS HEREBY ORDERED AND ADJUDGED that Petitioner be and is hereby
authorized to consummate said settlement as prayed in said petition, and to execute any and all
agreements, receipts, releases, or other documents necessary or proper to effect such settlement,
and that such agreements, receipts, releases, or other documents shan constitute the full, final.
and complete settlement of any and all actions, causes of action, claims, or demands which the
above-named minor may have against those parties to the settlement named in the petition, as
fully and completely as if said minor was of age and had executed said agreements, receipts,
releases, or other documents individually.
IT IS HEREBY ORDERED AND ADJUDGED that the settlement funds due to the
minor, as outlined in the Petition to Compromise Doubtful Claim of Minor shall be placed in an
.... "Iiiie~es;:'bearing-accouni by the Court and shall b~lnaintainedin said accouniUi-iiil such time as ....- ... ---- ... ---the minor reaches the age of majority. Accordingly, counsel for the MinOT shall remit the
set1lement funds to the Court within 10 (tell) days of the entry of this Order.
IT IS FURTHER ORDERED that Petitioner be and is hereby authorized to pay all fees
and expenses shown in paragraph II of the petition from the gross settlement amount.
;7~~'
JUDGE OF THE PROBATE COURT
7535 "
SAVAGE & TURNER, PC
382013612
SAVANNAH, GA 31401
(912) 231-1140
PAY TO THE
::.=..... ..
Nineteen Thousand Seven Hundred Twenty Two Dollars and 2211 OOI~*a_a.'::
MEMO
$19,722.22
1s
0212912012
.. _
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:;:-.~~.~._._
DOLLARS
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til
PROBATE COURT
CHATHAM COUNTY
P.o. BOX 8344
SAVANNAH, GEORGIA 31412-8344
133 Montgomery Street, Room 509
Savannah, Georgia 31401-3242
Tel (912) 652-7264 Fax (912) 652-7262
www.chathamcourts.org
May 17,2012
Ms. Ashleigh R. Madison, Esq.
Savage, Turner, Kraeuter, at al
P.O. Box 10600
Savannah, GA 31412
Dear Ashleigh:
Enclosed are copies of the checks that were received by the Probate
Court of Chatham County with regard to the minor's settlements as follows:
Ashley Williams
Ivonna Habersham
McKinley Habersham, Jr.
Kwamen Habersham
Kalyn Byers
.17,281.00
19,722.22
19,722.22
19,722.22
37,583.33
The Court is bonded and all monies are deposited in interest bearing
accounts for the minors. The Court is solely responsible for these accounts.
Therefore, no information whatsoever, including account numbers or statement
balances will be released to anyone.
A form to encroach money from the proceeds, for the benefit of a minor, upon
approval of the Court, is enclosed. Encroachments are allowed by the Court
should an unusual circumstance or event arise in the life of the minor.
Encroachments are not allowed for provisions that are the parent's responsibility.
If I can be of further assistance, please do not hesitate to contact me. Thank you.
~;&
Kim H. Birge
Chief Clerk, Court Administrator
Probate Court of Chatham County
KHB/pn
EXHIBIT
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38-2013612
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02/29/2012
$17,281.25
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Probate Court Clerk of Chatham County
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TURNER, PC
INVOICE
Williams
DATE
02/29/2012
Ashley Williams
DESCRIPTION
Check# 1 Date
7539
02/29/2012
IINV AMOUNT I
17,281.25
17,281.25
. -., -"--,-
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,
7535
FIRST CHATHAM BANK
SAVAGE e~ TURNER, PC
IOLlA TRUST ACCOUNT
38.2013612
(912) 2311140
02/29/2012
PAY TO THE
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SAVAGE I. TURNER, PC
INVOICE
Habersham
DATE
02/29/2012
DESCRIPTION
Ivonna Habersham
Check# 1 Dale
7535
02/29/2012
IINV AMOUNT]
19,722,22
19,722.22
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00 2?? 1,1,11'
7537
SAV>lGE S, TURNER, PC
Check# 1 Dale
02/29/2012
PAY TO THE
INVOICE
Habersham
DATE
02/29/2012
DESCRIPTION
McKinley Habersham, Jr.
7537
02129/2012
IINV AMOUNT I
19,722.22
19,722.22
'r--- ------------I
-------
---~---~--~---- --~-~-.
- ....-.----"".-
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7536
FIRST CHATHAM BANK
38-2013-612
SAVflNNAH, GA 31401
(912) 23111"0
PAY TO THE
ORDER OF Probate Court Clerk of Chatham County
MEMO
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INVOICE
Habersham
DATE
02/29(2012
DESCRIPTION
I(warnen Habersham
Check# 1 Date
7536
02/29/2012
IINV AMOUNT
19.722.22
19,722.22
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7538
SAVAGE & TURNER, PC
382013612
I
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02/29/2012
PAY TO THE
ORDER OF
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02/29/2012
Kalyn Byers
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02/2912012
37,583.33
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DOLLARS
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$37,583.33
37,583.33
--------------
Ivonna Habersham
MINORrWARD
Latesha Habersham
CONSERVATOR(S)
~~~~~~---------,
, Conservator(s) of
..:lv_o.:,:n.:,:n.:,:a::...:,:H:...a_b_e_rs_h_a_m
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _--', ~..hllt " .,.) (minor) shows:
I.
2.
The income from said assets or budget approved by the Court, if any, is insufficient for the
maintenance, support and education of said minor/ward (andlor _ _ _ _ _ _ _ _ _ _ _ _ __
who islare legally dependent upon said ward). N/A
3.
There are no other assets available to petitioner(s) to maintain, support and educate the person(s)
indicated in Paragraph 2 above.
This Minor has structured annuities in place to begin in 2016 and
2020, but cannot be touched
fo~.these
expenses.
per
5.
Since the inception ofthe conservatorship, petitioner(s) has/have previously encroached on Ihecorpus
of this estate in the total amount of approximately $._-_0_-_ _ _ _ _ _ _ _ _ _ _ __
Effective 7/07
2-
GPCSF 20 Complete
"
6,
The encroachment requested in this petition is needed for the following purpose(s) of maintenance,
support or education oftheperson(s) indicated in Paragraph 2 above in order to provide the following specific
items (attach separate sheet if necessary): $5,300.00 to Memorial Day School for tuition, registration fee,
Student Activity Fee, and Tuition Credit Plan; $200.00 to Latesha D. Habersham for reimbursement
1.
2.
grant an order allowing petitioner to expend from the corpus of the minor/ward's estate, the
sum of$$5,900.00
Latesha Habersham
Printed Name
Printed Name
Address
Savannah, GA 31405
912-272-5346
Telephone Number
Signature of Attorney:
Savannah, GA 31401
Telephone:
Effective 7/07
912-231-1140
-3~
StateBar#376110
GPCSF20Complete
.'
VERIFICATION
Personally appeared before me the undersigned petitioner(s) who on oath state(s) that the facts set
forth in the foregoing petition are true.
d<.<. '1
,20fl-
~~:?
U~er
Latesha Habersham
NOTARY/CLERK OF PROBATE COURT
My Commission Expires /O-//4S"'
Printed Name
Effective 7107
Printed Name
-4-
GPCSF 20 Complete
Chatham
- - - - - - COUNTY
STATE OF GEORGIA
INRE:
Ivanna Habersham
MINORIWARD
Latesha Habersham
CONSERVATOR(S)
)
)
)
)
)
)
)
PETITION TO ENCROACH
Probate Judge
Effective 7/07
-5-
GPCSF 20 Complete
.,
Chatham
COUNTY
------------------
STATE OF GEORGIA
IN RE:
Ivanna Habersham
MINORIWARD
Latesha Habersham
CONSERVATOR(S)
)
)
)
)
)
)
)
PETITlONTO ENCROACH
DATE
GUARDIAN AD LITEM
ADDRESS
TELEPHONE
Effective 7/07
-6-
GPCSF 20 Complete
Chatham
COUNTY
----------------
STATE OF GEORGIA
INRE:
Ivanna Habersham
MINORIWARD
Latesha Habersham
CONSERVATOR(S)
)
)
)
)
)
)
)
PETITION TO ENCROACH
ORDER
Upon reading and considering the foregoing petition, and it appearing that the averments therein
made are true, and the guardian ad litem for the minor/ward filing an answer to the petition which raised
no objection to the grant of the Petition; it is ordered that, to the extent indicated below, the same be, and
is
h~reb)',
allowed to expend from the corpus of said minor's/ward's estate up to the sum of
$,_ _ _ _ _ _ _ _ _ _ for the specific items set f0l1h in said petition for
Probate Judge
Effective 7/07
-7
GPCSF 20 Complete
ESTATE NO . .;.H.:...-.:...
78:.:2:.:9_ _ _ _ _ __
Ivonna Habersham
MINORI\ARD
)
)
Latesha Habersham
======--------,
CONSERVATOR(S}
..:..:..::.::..:::..:..:::.====-------, )
)
, Conservator(s) of
. :I.;.vo.::.n::::.n::::a:;...:..H;.:a;.:b;.:e::::rs.::.h::::a_m
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _, (adult ward) (minor) shows:
I.
The income from said assets or budget approved by the Court, if any, is insufficient for the
maintenance, support and education of said minor/ward (and/ol _ _ _ _ _ _ _ _ _ _ _ _ __
who is/are legally dependent upon said ward). N/A
3.
There are no other assets available to petitioner(s) to maintain, support and educate the person(s}
indicated in Paragraph 2 above.
5.
Since the inception ofthc consel"Vatorship, petitioner(s) has/have previously encroached on the corpus
of this estate in the total amount of approximately $,_-0;...-_ _ _ _ _ _ _ _ _ _ _ __
Err~clh'e
7/07
Filed In PMI!l:lourt
;:aJrYo%:~,/
Chief DoWly Clerk, Probate Court, Chatham Co GA
GPeSF
6.
The encroachment requested in this petition is needed for the following purpose(s) of maintenance,
SUppOlt or education ofthe person(s) indicated in Paragraph 2 abovein order to provide the following specific
items (attach separate sheet if necessary): $7,300.00 to Memorial Day School for tuition, registration,
2.
grant an order allowing petitionelto expend from the corpus of the minor/ward's estate, the
sum of $ $7,300.00
Latesha Habersham
Printed Name
Printed Name
Address
Savannah, GA 31405
912-272-5346
Telephone Num ber
Signature of Attorney:
Savannah, GA 31401
Telephone:
Effective 7/07
912-231-1140
~ 3-
GPCSF 20 Complete
VERIFICATION
Personally appeared before me the undersigned petitioner(s) who on oath state(s) that the facts set
forth in the foregoing petition are true .
, 20.J1L.'
~<%u
Latesha Habersham
Pl'inted Name
~:..~~~~~~~~~~~C~~~~ifiN~~J~r-GtC"-.--"------------.""---.--.""---. ____....___.."___.._.".m___.
Mv CommisSlQn Expires Oct 11 2015
Sworn ana subscribed before
me this _ _ day of
, 20 _ _.
to
Effective 7/07
Printed Name
GPCSF 20 Complete
Chatham
- - - - - - - COUNTY
STATE OF GEORGIA
INRE:
Ivonna Habersham
MINORfWARD
Latesha Habersham
CONSERVATOR(S)
)
)
)
)
)
)
)
PETITION TO ENCROACH
_____ _ _____ A Petition to E!'.::roach_ be~ngJiledbl'the co l1servator(s) oftheabove named '.!!inorlw~~d. it is her~9Y
ORDERED that
above minor/ward. The deputy clerk shall serve said guardian ad litem with a copy of this Order and the
above Petition. Upon said guardian ad Iitem's acceptance of same. said guardian ad litem shall make answer
hereto.
Probate Judge
Effective 7/07
-5-
GPCSF 20 Complete
Chatham
COUNTY
------------------
STATE OF GEORGIA
INRE:
Ivanna Habersham
MINORIWARD
Latesha Habersham
CONSERVATOR(S)
)
)
)
)
)
)
)
PETITION TO ENCROACH
GUARDIAN AD LITEM
DATE
ADDRESS
TELEPHONE
Effective 7/07
6-
GPCSF 20 Complett!
Chatham
COUNTY
STATE OF GEORGIA
ESTATE NO. _H_-_7_82_9
_____
)
)
)
)
)
)
)
INRE:
Ivonna Habersham
MINORIWARD
Latesha Habersham
CONSERVATOR(S)
PETITION TO ENCROACH
ORDER
Upon reading and considering the foregoing petition, and it appearing that [he averments therein
made are true, and the guardian ad litem for the minor/ward filing an answer to the petition which raised ..
no objection to the grant of the Petition; it is ordered that, to the extent indicated below, the same be, and
is hereby, granted; said conservator(s) islare hereby (initial applicablc):
a.
allowed to expend from the corpus of said minor'slward's estate up to the sum of
$ _ _ _ _ _ _ _ _ _ _ for the specific items set forth in said petition for
._tl)p~IP<l.e
Probate Judge
Effective 7/07
7-
GPCSF 20 Comple.te
MEMO:Rl1,}jL
DAY
SClHfOOIL
Date _-,M"",ayy"2.!.1~2,,0,-1,,3,-_ _ __
1ndivitfua[Ji!ttentWn. Ji!cadmicSuccess.
Ms. Lalesha Habersham
Dear
Ms. Habersham
The Financial Aid Committee recently met and has approved the following award for_ _-'I"vo"'nl!n"a!..-_ _ _ in grade -1Jl!L for
2013 14 school year:
Payable:
$ 7,000.00
.._ _.__._.. ....?_013,2014 Tuition Amount
the
1000.00
"'See Below
$ 6.000.00
300.00
Registration Fee
200.00
300.00
500.00
$7,300.00
Memorial Day School is pleased to be able to provide you with this financial assistance and asks that you respect the following:
a, Please do not discuss your financial arrangements with anyone.
b. Promole Memorial Day School at all times.
c. Volunteer as much as possible when asked by the school.
d. Support Memorial Day School wilh your time and talenls.
Please indicate the acceptance of this award by signing and returning one copy of Ihis letter by
June 27, 2013
. If you have any
questions or concerns about your financial Obligation or assistance, please feel free to call me at 352-4535.
Sincerely,
'"
._},
!\
\.
,-
JiII.Willcoxon
Date
Additional Notes:
EXHIBIT
~
~
If
"
ft
Truitt E. Byers, 54, died FebrualY 7, 2008 as a result of injuries sustained in the explosion at the
bnperial Sugar Refinery. He was born in Argilite, Kentucky and lived in Savannah, Georgia for
34 years. Mr. Byers was an operator mechanic at the Refinery with twenty two (22) years of
service. He was a member ofhnmanuel Baptist Church and Ancient Landmark Lodge No. 231,
F & AM, the Scottish Rite Consistory-Valley of Savannah and a former member of the Alee
shrine where he was active with the Oriental Band Unit.
EXHIBIT
! r
McKinley "Von" Habersham, Sr. died Friday, February 22,2008 at the Doctor's Hospital in
Augusta, Georgia from injuries sustained in the explosion at the Imperial Sugar Refinery on
February 7,2008. McKinley was born in Savannah, Georgia on September 9, 1977, the son of
McKinley and Regina Habershm. He attended the public schools of Chatham County and was a
graduate of Savannah High School, Class of 1966. He was employed by Imperial Sugar
Company and Club Exclusive. He was a member of Down South Creations.
EXHIBIT
Lezlie
Date & Time: 12/]9/2014 2:35 PM
User Name :
Lezlie
Job Name:
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