Articles Posted in Wills

It happens often enough that a parent for many reasons decides to disinherit one, several or all of his/her children.  At the same time, this is often not a controversial decision and is just as common both understandable and predicable.  Perhaps a person promised their estate to a specific child, stepchild or niece or nephew for taking care of them instead of being required to be sent to a long term continuing care facility.  Perhaps the parent provided financial largesse to his/her via college education, graduate school and even helped them purchase a house but had one child who had special needs who always lived at home and insured that child’s future by funding a trust during his/her lifetime and then disinherited all of his/her other children by putting the whole of the estate into the trust.  

 

Mickey Rooney was a very well known and well paid actor that had a long career, with many children and many marriages and disinherited his children.  He instead left his estate to his stepson and explained that his kids were better off than he was.  By the time Mr. Rooney passed, his estate dwindled to just about $18,000, so there was little incentive for any of his kids to contest the will, although the same did not hold true for Mr. Rooney’s then current spouse.  Unfortunately for some families, this can be a shock and there are sufficient incentives for the family to contest the will.  

 

INVALIDATING THE WILL

 

Louisiana is the only state that allows for a disinherited child to elect to take a statutory share against the stated wishes of a parent’s will.  If the parent did not dispose of everything in the will, due to perhaps an heir predeceasing him/her, the children may inherit that property via intestacy statutes.  If a parent, however, leaves all of his/her property to someone else via his/her will, the only thing the child/children can do is to invalidate the will.  In New York, if a person dies intestate – meaning without a will – the spouse inherits the first $50,000 and half of the remainder.  The children then split the other half between themselves.  The child/children must also consider if there was a previous will, and, if so, what treatment is afforded to them in that will.  But the matter gets more complicated from there.  Property held in joint tenancy (with a business partner for example), by the entireties (held as a marital asset with the spouse) takes those assets out of the estate.  

 

GROUNDS TO CONTEST WILL

 

There are many many factual scenarios that enable a party to contest a will.  The first consideration is who may contest the will, or, more properly stated, who has standing to contest the will?  In New York, only people who have a material interest that may be prejudiced if the will as written is fully probated.  Perhaps the heir stands to inherit more if the intestacy law controlled or perhaps the heir stood to gain more under an older will.  There are several grounds to contest the validity of a specific will:

 

  • Undue influence, coercion or duress;
  • Revocation;
  • Incapacity or lack of capacity;
  • Fraud;
  • Forgery; and
  • Improper execution.

WRONGFUL INTERFERENCE WITH WILL

It is known by many different names, depending on the state and the era. Most recently it made its appearance in news headlines with the name – intentional interference with expected inheritance, sometimes even shortened it IIEI. The United States Supreme Court referred to it as “a widely recognized” cause of action and as the “tort of interference with a gift or inheritance” in the Anna Nicole Smith case. Marshall v. Marshall, 547 U.S. 293, 296 (2006). The matter has surfaced in the news over at least the last century, most famously (perhaps infamously) in the Father Divine case in New York, in 1949. Latham v. Father Divine, 299 N.Y. 22 (1949).

 

The American Law Institute published the The Restatement of Torts (Second) of Torts in 1979.  That was the first time that the tort, known by many names, was formally recognized as such. Prior to this, the principal and concept was recognized but only in the most egregious of circumstances. There are several seminal cases that speak to the larger concept, one of which was the New York case dealing with Father Divine case noted above.

 

The vast majority of Trial Court cases barely survived dismissal for failure to state a claim, as the right to such a cause of action was in question, despite the seminal cases. The law is a living thing that evolves and even comes around waves. As one of the twentieth century cases that broke the mold of nineteenth century reasoning noted that under Roman Law, interference with inheritance was a criminal act.

 

CURRENT NEW YORK LAW

 

New York Law does not recognize this cause of action per se. The New York Appellate Division of the Supreme Court summed it up perfectly when they held that no such cause of action exists in the state for tortious interference with an inheritance. It will, however, create a constructive trust for the intended heir under certain equitable circumstances. Schneider v. David, 602 N.Y. 2D 130 (1993). Is this the same thing? For example, Iowa permits such a cause of action, which is litigated in its Trial Courts, not its Probate Court, allowed for attorney’s fees and punitive damages for intentional and malicious conduct. Huffey v. Lea 491 N.W. 2D 518 (Iowa 1992).

 

The difference between whether a case is litigated in front of a probate judge versus a trial court matters, insofar as you are entitled to a jury in a trial court. In addition, attorney’s fees and punitive damages also matter, but, probate court judges could award attorneys fees if the case warrants it. But the measure of economic damages, which is indeed the merits of a case, is still the same. To further elaborate on New York law, the 1988 case of Dawson v. Vasques quoted the 1919 case of Beatty v. Guggenheim Exploration Co. which stated that equity requires that a constructive trust be created, but it is nothing more than the means by which fairness acts and that it will not “restrict itself” to any specific form of harm for which it will provide justice. Instead, equity will fix whatever chicanery that people can implement.

 

For more information all all issues related to inheritances, wills, and trusts, be sure to reach out to a NY estate planning attorney today.

WHAT HAPPENS IF A WILL IS INVALIDATED?

Wills are perhaps the most basic and simple form of passing on property and the transmission of wealth from one generation to the next. It allows the testator to give away the property and money that they own and have on hand as they see fit. A person can write a person out of a will, with certain limitations, include another non-child in the distribution and treat them as if they were a child or even leave it all to a charity. While the vast majority of wills are honored and respected without question, there is always the possibility that a potential heir may contest a will. In the event a will is invalidated a Surrogate’s Court must still resolve the issue of how and to whom shall the property be distributed. One possible way of dealing with issue of distributing the property if a will is invalidated is to utilize the state’s default, intestate distribution scheme. Another means is to revive a previous, otherwise valid will. This latter method is called the doctrine of dependent relative revocation.

DOCTRINE OF RELATIVE REVOCATION

The doctrine of relative revocation holds that if a testator revokes a prior will in a second will, but the second will is invalidated for any reason, the previous will is revived. The animating consideration is that the invalidation of the previous will is predicated on a new distribution scheme that is conditional in nature. When the condition is not fulfilled, the revocation will not be given effect. Courts look to see, therefore, if the revocation in the previous will was conditional in nature, in other words, was the revocation premised on the thought that the new will can replace the old or if the revocation was absolute in nature. The case of The Matter of Sharp shows what language Courts look to, to determine if a revocation was absolute. The Matter of Sharp, 68 A.D.3d 1182 (N.Y. App. Div. 2009). The case of The Matter of Macomber shows how Courts determine what language is necessary to find a subsequent document to be conditional in nature. The Matter of Macomber, 274 App div 724 (N.Y. App.Div.1949). The doctrine of relative revocation is not found in statutory law, only in case law as a rule of construction to help resolve ambiguities, when the usual extrinsic evidence is invalid.

AVOIDANCE OF WILL INVALIDATION

One possible way to avoid the likelihood of this happening and to include disincentives in the terms of the will against a will challenge is to include a no-contest clause. No-contest clauses are generally disfavored by most states. In New York, no-contest clauses are disfavored although permitted; as recently as  2009 a Surrogate’s Court enforced the terms of a no-contest clause. Matter of the estate of Joseph Singer, 13 N.Y. 3D 447 (N.Y. App. Div. 2009). Given that the no-contest clauses are disfavored, Surrogate Courts strictly construe them.

If you are administering an estate that is or may be subject to a will contest or perhaps want to contest a will, it is imperative that you speak with experienced estate planning attorney and perhaps consider a trust instead. Trusts are more difficult to invalidate than wills.

GROWING LEGAL ISSUE

The federal Department of Health and Human Services estimates that there are currently approximately 600,000 frozen embryos in the United States and the number continues to grow each year. Of these, it is estimated that approximately 60,000 could be implanted for full term pregnancy. In still other cases, a father or mother may freeze and store some sperm or eggs for future family planning purposes. In either event, a mother must have artificial insemination or in vitro fertilization or the embryo implanted. It is possible, even likely, that some of these embryos may be implanted and born after the passing of the father or mother with the use of a surrogate mother. The legal rights of these posthumously conceived children are still being fleshed out in legislatures and courtrooms throughout the country. In 2012, the United State Supreme Court dealt with rights of a posthumously conceived child to the Social Security survivor’s benefits of the deceased parent in Astrue v. Capato.

FEDERAL AND NEW YORK LAW

The Supreme Court held in Astrue v. Capato that the issue of whether or not the posthumously conceived child in issue was entitled to Social Security survivor’s benefits was answered by looking to the state law. State law would answer whether or not the child could inherit under the state’s intestacy laws. Fortunately for New York, Governor Cuomo signed legislation on November 21, 2014 helping to clarify the inheritance rights of posthumously conceived children under New York law. New York also has one reported opinion of a case dealing with the rights of a posthumously conceived child in the case of In the Matter of Martin B. 841 N.Y.2d 207 (Sur. Ct. New York Co. 2007). The case dealt with two posthumously conceived children born to a widow, from the sperm of her deceased husband and the rights of the children to receive distribution from a trust created by the paternal grandfather. The Court found that while the father may have passed prior to conception, the Court only had to determine if the children fit the definition of “issue” and “descendent” under the terminology utilized in the trust document. While this addresses a fair portion of the children so conceived or otherwise under the jurisdiction of New York law, there is still a fair portion of the law that can only be addressed by Congress. Veteran’s Administration benefits is one large, looming class of children who still do not have clarity with their rights to any monies or other benefits otherwise due to children conceived and born during the life of the deceased service member. In 2003, the USA Today reported that some troops freeze their gametes before being deployed to a combat zone. In May, 2008 the United States Army Legal Services Agency stated via a periodical newsletter that Veterans Administration benefits eligibility criteria should allow for children conceived of via artificial insemination.

NEW YORK LAW PROTECTIONS

The speed of medical technology and techniques has already eclipsed legislative enactments. New York’s law, however, seems to cover a large segment of the potentially affected children. To qualify for the protections of New York’s law four things must occur:

  1. The parent must expressly consent to the use of genetic material after death. The consent must be in writing within seven years before the death of the parent/donor; and
  2. Notice of the existence of stored genetic material must be provided to an estate representative within seven months of issuance of letters testamentary; and
  3. The written consent must be recorded in Surrogate Court within seven Months of the death of the parent; and
  4. The child must be in utero within 24 months or born no more than 33 months after the parent’s death.

If you are granted a durable power of attorney over another person, it means that you have the right to make financial and legal decisions on their behalf. However, the power of attorney does have its limits, and a recent case that went to the Supreme Court in South Dakota illustrates the importance of clarifying what the capabilities of the power of attorney entail.

Facts of the Case

In the case of Studt v. Black Hills Fed. Credit Union, Dorothy McLean invested a certificate of deposit (CD) with the credit union in 2008. Then in 2012, she moved in with her son, Ronald Studt, and also named him as her attorney-in-fact with a durable power of attorney form. In his role, Mr. Studt would be allowed to transfer and gift property to persons or organizations as long as Ms. McLean’s financial needs could still be met and that the transfers were for estate planning purposes.

Mr. Studt then informed the credit union that they should close all of Ms. McLean’s accounts and transfer them to a bank in their hometown. In addition, the credit union should forward the funds of the CD when it matured. The credit union accepted the power of attorney and did as was asked, but left the CD until it matured.

Ms. McLean became terminally ill in May 2013, and at that time Mr. Studt asked about who was the beneficiary on the CD. The beneficiary was David Sholes, and Mr. Studt requested that the beneficiary be changed to him. He was told that only the CD’s owner could change the beneficiary, so when Ms. McLean passed away later that month the funds were to go to Mr. Sholes.

Mr. Studt submitted a declaratory motion to the court to determine the rightful beneficiary to the CD. The credit union and Mr. Sholes argued that Mr. Studt does not have the right to self-deal as well as the fact that he did not have the right to change the beneficiary on the CD. The circuit court agreed that the language in the power of attorney was too broad and did not specifically authorize self-dealing, and Mr. Studt appealed.

Ruling of the Court

The case was appealed up to the South Dakota Supreme Court, where it agreed with the ruling by the circuit court. Under the law, a power of attorney agreement must be strictly construed and pursued and only the powers that are explicitly stated in the agreement are allowed. In order to allow someone named as the power of attorney to self-deal, the document must provide “clear and unmistakable language” to that effect.

Mr. Studt argued that the agreement allowed him to make transfers to “any person,” which should include himself. The court disagreed and stated that the language was too broad and did not state with specificity that he was allowed to self-deal. Because a power of attorney document must be strictly construed and Mr. Studt’s lacked the specific language, his argument was struck down by the court and the justices ruled in favor of the opposing parties.

Bobbi Kristina Brown is the only heir to the estate of her mother, renowned singer and actress Whitney Houston, but since being placed in a medically induced coma questions have arisen about who is next in line to inherit her fortune. Whitney Houston’s estate was estimated to be around $20 million at the time of her death three years ago. Bobbi Kristina was found on January 31 unresponsive in her bathtub and has remained unresponsive in a coma.

Whitney Houston’s Estate

Since being discovered on January 31, Bobbi Kristina has yet to regain consciousness, and there are rumors that her organs have started to fail. With reports that Bobbi Kristina’s family is considering taking her off of life support, people are now looking to the terms of Whitney Houston’s will and estate planning documents. According to the terms in her will, if Bobbi Kristina dies, Whitney Houston’s mother, Cissy, and her two sons are next in line to inherit Ms. Houston’s estate. The estate includes full royalties from the singer’s music, likeness, and image that will continue to distribute revenue over time.

Bobbi Kristina was the beneficiary of a trust for Whitney Houston’s estate. She received ten percent of the estate, around $2 million, when she turned 21 years old. She is scheduled to get another fifteen percent when she turned 25 years old and the remainder of the estate when she turned thirty years old. The will stated that Cissy Houston and her two sons would inherit Whitney Houston’s estate if Bobbi Kristina dies before coming into the majority of the estate.

Other Potential Claimants

Bobbi Kristina’s father and Whitney Houston’s former spouse, Bobby Brown, does not stand to inherit anything from Ms. Houston’s estate, even if his daughter passes away. Bobby Brown was married to Whitney Houston for fourteen years and the couple divorced in 2007. According to experts, Bobby Brown’s opportunity to contest anything in the estate would have been when Whitney passed away. He has no claim purely by virtue of once being married to her.

It also seems unlikely that Bobbi Kristina’s partner, Nick Gordon, would inherit anything, as well. Mr. Gordon was taken in by Whitney Houston when he was twelve but never formally adopted, and he and Bobbi Kristina announced their engagement and marriage publicly. However, a representative of the family has stated that a formal ceremony of marriage never took place. Therefore, Mr. Gordon does not have a valid claim to the estate.

It was Mr. Gordon and a family friend that found Bobbi Kristina in the bathtub in their home in Roswell, Georgia where the couple lived. Authorities are also looking at possible foul play in the incident involving Bobbi Kristina because of injuries found on her face and mouth. Mr. Gordon is currently a target of the investigation, and the couple has a history of domestic abuse. In addition, one of the co-executors of Ms. Houston’s estate, Pat Houston, obtained a restraining order against Mr. Gordon for, among other things, making threatening comments towards her.

In a time where social media accounts are part of your estate plan, figuring out what should happen to your accounts when you die is something that must be considered. The developers at Facebook have been dealing with this issue for years. Previously, they allowed for a basic memorialized account that people could view but not manage. Now, Facebook has launched a new feature that allows you to choose a legacy contact, a trusted person who can manage the account after you die.

Purpose of a Legacy Contact

The purpose of a legacy contact is to allow someone to manage your social media account after you pass away. While technically you can just give your password to another person, it is a violation of Facebook’s terms of service. In addition, there is no guarantee that the something might happen with your password that would lock your account manager out of your page.

When Facebook is notified of your death, the company will memorialize the account. The legacy contact is then notified and given access to the page. The legacy contact will be able to add a post to the top of the timeline, respond to new friend requests, update the profile picture and cover photo. You can also give the legacy contact the ability to download an archive of your Facebook activity which includes posts, pictures, and any updated profile information. However, the legacy contact cannot log in to your personal page or read any private messages.

How to Set Up a Legacy Contact

The first thing to consider when creating a legacy contact is determining who that person will be. Many people choose their spouse or partner, but for an older generation that person may not be technologically savvy. Other people have chosen their child or a grandchild as the legacy contact, or they have named the executor of their estate to also manage their social media websites.

In order to actually set up a legacy contact on Facebook, the process is the same on a mobile device or on a desktop computer. First, go to your settings and scroll down to the “Legacy Contact” option at the bottom. Then, select Edit and follow the prompts to select which of your Facebook friends will be your legacy contact.

It is important to note that Facebook will not notify the person that you have set as your legacy contact that they have been selected. The legacy contact is only notified by the company once your account has been memorialized. It might be in your best interest to give your legacy contact the heads-up that you have selected them so that they will be expecting the responsibility later on.

If having a legacy contact for your Facebook account does not interest you, there is one other option. The company does allow for you to select an option that permanently deletes your account from Facebook when it is notified of your death.

When a person dies, someone else must step up and close the estate. If that responsibility falls to you, as an executor you must identify all of the estate’s assets, pay off creditors, and distribute what is left to the heirs. However, an added responsibility as the executor is that you must also file all of the tax paperwork for the estate, as well. There are four major tax considerations that you must complete as the executor of an estate.

Filing the Final 1040

The first thing that you must do as an executor is file the deceased’s personal tax return for the year that the person died. The standard 1040 form covers from January 1 of that year until the date of death. If there is a surviving spouse, you can fill out the 1040 as a joint return and is filed as though the deceased lived until the year’s end. A final joint 1040 includes the decedent’s income and deductions up until the time of death in addition to the surviving spouse’s income and deductions for the entire year.

Filing the Estate’s Income Tax Return

In addition to filing the individual income tax return, as the executor you must also file an income tax return for the estate. Once the person has died, any income generated by any holdings is income of the estate. The estate’s first year of income tax starts immediately after death and the end date can be the end of any month, so long as the time period for the return is twelve or less months. You must file a 1041 form with the federal government by the fifteenth day of the fourth month after the year-end date.

However, if the estate is less than $600, you do not have to file a 1041 on behalf of the estate. In addition, you do not need to file this form if all the decedent’s income-producing assets bypass probate and go straight to the surviving spouse or other heirs by contract or operation of law. Examples of this include joint tenancy in property, retirement accounts, IRAs, and other beneficiary designated income.

Filing the Estate’s Estate Tax Return

You must also file the estate’s estate tax return, otherwise known as Form 706. This form is only applicable if the deceased’s estate is worth over the federal exemption level, which is $5.43 million for 2015. However, the form is required if that person gave a sizable gift over the annual gift amount of $14,000 sometime within 2013-2015. If a sizable gift was made, it is added back to the estate for tax purposes to see if the estate would be over the federal exemption limit. If it is, there is a 40% tax on the excess amount.

The deadline for Form 706 is nine months after death, but a six month extension is allowed. It is also important to note that while life insurance proceeds are given income tax free, they are usually included in the decedent’s estate for estate tax purposes. An exception to this is if the beneficiary is the surviving spouse.

Miscellaneous Tax Details

There are smaller other details that are necessary for filling out an estate’s tax responsibilities. If you need to fill out a 1041 or Form 706, you must get the estate a federal employer identification number (EIN). This requires filling out another document, Form SS-4. You should also file a Form 56 that notifies the IRS that you will be handling the tax issues for the estate. Finally, these forms apply to the federal government, but do not forget to check and see if the state requires tax returns, as well.

Just like you would not attempt a do-it-yourself project around the house without the proper hardware tools, you should not go into retirement without the proper estate planning tools. This means that you need to have the right planning vehicles and strategies in place that will ensure that you are receiving a paycheck or funds for decades into retirement. Thankfully, there is a basic estate planning toolkit that can help you get started on your retirement planning.

Realistic Budget

The foundation of every retirement plan is a realistic budget that plans for all incoming money from things like Social Security, pensions, and savings as well as plans for all outgoing expenses like basic necessities, medical care, and miscellaneous costs. This is not a tool that is created and forgotten; you should revisit your budget frequently to make sure that your finances are still on track.

If possible, try to think of all expenses to add to your retirement budget like annual insurance premiums and other infrequent costs. You should also have a slush fund to account for any expenses that may occur without warning, such as a medical emergency, housing repairs, or a new car in addition to any money that you plan on using to help family members.

Asset Allocation

Even before reaching retirement, you should start to reallocate assets within your portfolio to match your lifestyle. This typically means taking more assets out of risky ventures and investing them in assets that can give you sustained, long-term growth. This helps prevent against inevitable market declines, especially when you do not have an employer’s paycheck to rely upon.

An Experienced Attorney

While many people are uncomfortable discussing their personal lives with a lawyer, retirement age is not the time to shy away from asking for help from an experienced attorney. An estate planning attorney can go over what you have already done to prepare for retirement as well as draft the necessary documents that ensure that all of your affairs are in place. An attorney can also give you advice about the proper time to take care of things like Social Security withdrawals and structure your estate in a way that minimizes taxes.

Up to Date Documents

Updating all estate planning documents is also a must. Like the budget, your estate plans should not be something that is created and then ignored. As life events occur, you should be reviewing and updating your estate plans accordingly. This includes all actual documents regarding your estate that could pass through probate in addition to any and all accounts that include a beneficiary designation.

A Non-Financial Plan

Finally, you should also draft a non-financial plan to keep you and your loved ones physically and mentally engaged in retirement. Many retirees do not contemplate how such a drastic shift in living can affect them, body and mind. A lot of people who reach retirement find themselves depressed or becoming coach potatoes when they do not have a non-financial plan in place for their retirement years.

It has been said that life is a journey, not a destination. So it makes sense that in our last days, on our final journey, we should strive to have a good one–a bon voyage.

While talking about end of life issues–particularly our own–can sometimes be uncomfortable, the best way to make sure that your end of life wishes are honored is to lay them out in writing and make sure that your loved ones are aware of them. Don’t miss the opportunity to have a bon voyage–take the opportunity to set out your end of life wishes and take control of your journey.

Unfinished Life Matters
Sometimes so much focus is placed on the medical and legal aspect of dying that the personal aspects get brushed aside. However, the reality is that it is much easier to have a bon voyage if you are happy or at least satisfied when you depart. This involves taking care of loose ends and putting things right where necessary. Personal matters to consider include–

**Saying things you need to say to loved ones, friends, and others, such as “I’m sorry.” “I forgive you.” “Thank you.” “I love you.” “Goodbye.”

**Determining whether you may need psychological, emotional, spiritual care, counseling, or other support.

**Writing a personal legacy or story, telling any life lessons or outlining your hopes and dream, as well as leaving any helpful advice, for loved ones.

**Creating a “bucket list,” outlining any things you would still like to accomplish or setting out any goals of for your remaining medical care.

Funeral Wishes
Funeral arrangements are very personal and options vary widely–from in-ground burial, mausoleum burial, cremation, as well as other possibilities. Some planning and logistical questions include–

**Do I want to donate my organs for transplant or donate my body to science?

**Which funeral home/mortuary do I want used?

**What are my feelings regarding embalming, burial, cremation, casket, burial location?

**Who should be notified of my passing?

**Who will write my obituary and what should it say if you are not writing it yourself?

**What do you envision for a funeral–a church service, a party or dinner, a memorial service?

**Will you pre-pay your funeral expenses or where will funds be held?

**Do you want to specify a charity or other cause “in lieu of flowers”?

Medical And Legal End Of Life Paperwork
A complete estate plan typically involves the documents identified above as well as a pour-over will, a revocable living trust (RLT) or an irrevocable Medicaid asset protection trust (MAPT), power of attorney for finance, and deeds and memoranda regarding personal property. In particular, questions related to medical and/or legal arrangements include–

**Do you have a will and possibly a trust? When is the last time you looked at these documents and thought about their provisions? Do the provisions reflect your current wishes and desires for distribution of your personal and real property, as well as your other assets?

**Do you have a Living Will? Does it state your wishes regarding the type and extent of medical treatment you want in the event that you can no longer speak for yourself?

**Have you made your feelings known about matters such as “Do Not Resuscitate (DNR)” orders or your feelings on CPR? What are your feelings on palliative care and natural death? What are your feelings regarding breathing tubes (intubation) and feeding tubes? A Living Will allows you to record your wishes regarding organ donation, pain relief, funeral, and other advance planning matters. It is an important source of guidance for your health care agent.

**Have you executed a Durable Power of Attorney For Healthcare? Have you also selected a Health Care Proxy? Have you specified an alternative proxy in case your first choice is unable or later unwilling to act as proxy? A health care proxy is a designated decision-maker who will make medical decisions for you if you become incapacitated and cannot make decisions for yourself. Your health care proxy should be someone with a strong personality; someone who will fight for you and your wishes.

Thinking of end of life matters can be uncomfortable and challenging, but most things are easier when we have some control over them. Expressing your wishes and making affirmative decisions regarding end of life matters will hopefully allow you to have a peaceful departure and a bon voyage.

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