EFiled: Aug 13 2024 02:A6PNEEDT>
`Case No. 2023-0410-LM
`(eh2OFDAS
`Transaction ID 74033985 (Fe=}
`
`“SCHEDULE A”
`
`Definitions
`
`1.
`
`“You” and “Your” mean and refer to M&T Bank, and your employees,
`
`representatives, agents, or other persons acting or purporting to act on yourbehalf;
`
`2.
`
`“Communications” means any exchangeof information by any means
`
`of transmission.
`
`3.
`
`“Documents” has the broadest meaning permitted under Court of
`
`Chancery Rule 34 and includes all writings of any nature whatsoever, whether
`
`originals or copies, including all non-identical copies (whetherdifferent from the
`
`original because ofnotes made on or attached to them or otherwise), whether
`
`drafts, preliminary, proposedorfinal versions, whether printed, recorded, produced
`
`or reproduced by any other mechanicalor electronic process, whether written or
`
`produced by hand, within Your possession, custody or control. “Documents”
`
`includes electronically stored information.
`
`4.
`
`“Petitioner” shall collectively mean and refer to Barbara Thompson,
`
`individual, as Co-Successor Trustee of the Revocable Trust of Ralph W. Barrow
`
`dated June 3, 1992, and as Co-Executrix of the Estate of Ralph W. Barrow,
`
`deceased.
`
`5.
`
`“Respondent” shall mean and refer to William E. Barrow,
`
`individually, as Co-Trustee of the Revocable Trust ofRalph W. Barrow dated June
`
`EFiled: Aug 13 2024 02:46PM EDT
`Transaction ID 74033985
`Case No. 2023-0410-LM
`
`
`Case No. 2023-0410-LM
`(eh2OFDAS
`Transaction ID 74033985 (Fe=}
`
`“SCHEDULE A”
`
`Definitions
`
`1.
`
`“You” and “Your” mean and refer to M&T Bank, and your employees,
`
`representatives, agents, or other persons acting or purporting to act on yourbehalf;
`
`2.
`
`“Communications” means any exchangeof information by any means
`
`of transmission.
`
`3.
`
`“Documents” has the broadest meaning permitted under Court of
`
`Chancery Rule 34 and includes all writings of any nature whatsoever, whether
`
`originals or copies, including all non-identical copies (whetherdifferent from the
`
`original because ofnotes made on or attached to them or otherwise), whether
`
`drafts, preliminary, proposedorfinal versions, whether printed, recorded, produced
`
`or reproduced by any other mechanicalor electronic process, whether written or
`
`produced by hand, within Your possession, custody or control. “Documents”
`
`includes electronically stored information.
`
`4.
`
`“Petitioner” shall collectively mean and refer to Barbara Thompson,
`
`individual, as Co-Successor Trustee of the Revocable Trust of Ralph W. Barrow
`
`dated June 3, 1992, and as Co-Executrix of the Estate of Ralph W. Barrow,
`
`deceased.
`
`5.
`
`“Respondent” shall mean and refer to William E. Barrow,
`
`individually, as Co-Trustee of the Revocable Trust ofRalph W. Barrow dated June
`
`EFiled: Aug 13 2024 02:46PM EDT
`Transaction ID 74033985
`Case No. 2023-0410-LM
`
`
`
`3, 1992, and as Co-Executor ofthe Estate of Ralph W. Barrow, deceased.
`
`6.
`
`“Decedent” shal] mean and refer to Ralph W. Barrow, Jr. (DOB:
`
`6/13/1932).
`
`7.
`
`“Trust” shall mean and refer to the Revocable Trust of Ralph W.
`
`Barrow dated June 3, 1992.
`
`8.
`
`“Estate” shall mean and refer to the Estate ofRalph W. Barrow as
`
`evidenced by Folio No 178352 at‘the Register of Wills in and for New Castle
`
`County, Delaware.
`
`9.
`
`“M&T”shall mean and refer to M&T Bank.
`
`Instructions,
`
`1.
`
`The requests shall be deemed continuing so as to require prompt
`
`amendment and supplementation in accordance with Court of Chancery Rule 26.
`
`2.
`“Or? and “and” should be construed disjunctively and conjunctively
`as necessary to bring within the scope ofthe requestall documents that might
`
`otherwise be construed to be outside of its scope, and “any” and “ail” as used
`
`herein shall include “each” and “every.”
`
`3.
`
`The use of the singular form of any word includes the plural and vice
`
`versa, and the use of the masculine gendershall include the feminine and neuter
`
`genders and vice versa,
`
`
`
`4.
`
`If any documentis withheld on the groundsofprivilege, work
`
`product, or otherwise, specifically identify the following: (a) the form of document
`
`(e.g., memorandum,letter, note, electronic mail, etc.) that is being withheld; (b) the
`
`date of that documentor, if no date appears thereon, the approximate date the
`
`document was prepared; (c) the identity of the author or authors; (d) the identity of
`
`the person or persons to whom the documentis addressed; (e) the identity of any
`
`recipient(s) ofthe documentthat appear on the documentas having received a
`
`copy; (f) the identity of any attachment(s) to the documentand a statement of
`
`whether such attachment(s) have been produced; (g) the subject matter ofthe
`
`document; and (h) the natureofthe privilege or immunity asserted, or the other
`
`grounds for withholding the documentincluding, if relevant, the attorney and client
`
`involved.
`
`5.
`
`Documents producedin response to the requests shall be produced as
`
`they are kept in the usual course ofbusinessor shall be organized and labeled to
`
`indicate the specific request(s) to which they respond. Ifmultiple copies of a
`
`documentwere prepared orif additional copies were madeafterthe original
`
`document wasprepared, and if any such copies werenotor are no longeridentical
`
`by reason of subsequentnotation or modification of any kind, including notations
`
`on the front or back of the document, such non-identical copies must be produced:
`
`
`
`Documents Requested
`
`TimePeriod?
`
`Any andall relevant dates.
`
`Categories:
`
`For the time period identified above, all documents described
`below that are related to M&T accounts, and any other accounts
`or policies in the below namenotpreviously identified, that
`have been maintained, individually or with others, for:
`
`- RALPH W. BARROW
`DOB: 06/13/1932
`
`
`Account opening documents, joint account documents,
`beneficiary designations, beneficiary change requests,
`beneficiary change confirmations, electronic beneficiary
`designation changes, beneficiary change denials, account
`maintenance requests, electronic account maintenance
`changes, account closing documents, powers of attorney and
`all correspondencerelated to the accounts, including, but not
`limited to, all internal memoranda, emails, correspondence
`electronic tor otherwise between you and the account holders
`(including their agents), borrowers, or others,all telephonic
`recordings maintained for any purpose involving or in any
`related to the aforementioned parties or accounts.
`
`To the extent not already included in the above request, the following
`documentationis specifically requested to be produced,
`
`
`
`1. All documentation which relates in any way to Ralph W. Barrow’sjoint
`account with William E. Barrow with checking account number
`9878524470 including, but not limited to, all documents making the
`accountjoint with William E. Barrow, beneficiary designation additions
`or revisions, EFT deposits from USAA Bank and/or Victory Capital
`Management.
`
`2
`
`All basic online account information including any temporarily
`assigned network address, M&T Bank online accounts, and the
`
`
`
`accountlogin histories (IP Login History) for any account owned,in
`full or in part, by Ralph W. Barrow or William E. Barrow.
`
`. All beneficiary designation forms, both original and any changes,
`whether approved or denied.
`
`. All correspondence, documents, or other communications between
`Ralph W. Barrow and M&T Bank thatrelates in any way to the naming
`or changing of any joint owner.
`
`e
`
`All correspondence, documents, or other communications between
`William Barrow and M&T Bankthatrelates in any way to the above
`identified account.
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
