TBarAssociationComplaintGuardianFees.pdf

Price Gouging in Probate: How a $2,800 Estate Turned Into Over $110,000 in Fees

I never imagined that after losing my husband, Franklin, I would face another devastating battle—protecting my daughters and myself from excessive legal fees in probate court.

My husband’s estate was simple. It had $2,863.50 in assets and one small claim for an ambulance bill of about $176. Yet within two years, more than $110,000 of our family trust was drained—mostly by attorneys, a guardian ad litem, a magistrate, and mediation fees.

The Guardian ad Litem Fee Dispute

In June 2023, Judge Sherwood Coleman appointed Linda Allan as Guardian ad Litem for my minor daughter, Caroline, at a rate of $350/hour. Instead, Ms. Allan billed $450/hour, submitting charges totaling $16,470 for 37.1 hours of work.

After we objected, the court reduced her fee to $12,985. Still, this amount is staggering compared to the estate’s actual value.

Worse, her billing records show we were charged for internal emails that insulted me personally. For example, I was billed $180 for an email in which she called my questions “insulting” and “ridiculous,” and even suggested that all her fees should come from my share because “that is why I’m here.”

A System That Protects Itself

Ms. Allan and the trustee’s attorney, Michael Kouskoutis, regularly emailed about “reviewing each other’s fees.” Instead of protecting the estate, they seemed to protect their own charges. No discounts. No objections. No transparency.

Meanwhile, I, the widow, was left paying for every dollar they decided to bill.

The Bigger Picture

Here is what was taken from my family trust in just one year (Sept. 2023–Aug. 2024):

$43,812.76 – Attorney Michael Kouskoutis

$18,562.83 – Attorney Michael Kouskoutis (additional)

$12,985.00 – Guardian ad Litem Linda Allan

$12,067.75 – Special Magistrate Robert Persante

$2,000.00 – Mediator George Greer

Plus other expenses, totaling $110,574.18

This was supposed to be about protecting beneficiaries. Instead, it feels like my daughters and I were treated as the estate’s ATM.

Why I Filed a Bar Complaint

Florida law is clear:

Attorneys must disclose fees in writing to beneficiaries (F.S. 736.1007).

Fees must be reasonable (F.S. 733.6171).

Bar rules prohibit excessive fees, conflicts of interest, and misconduct.

Yet in my case, these protections were ignored.

I am not a lawyer. I am a widow raising two daughters. I ask questions because I need to understand how my family’s future is being managed. Instead of answers, I was billed for insults.

My Plea

This is more than numbers. It is about fairness, transparency, and respect for the people left behind after loss. Probate should protect families, not strip them of what little they have.

I am calling on the Florida Bar to investigate. Families like mine deserve better.

Pray for Lord bring peace and happiness for my family!!!

1. The Florida Bar
Inquiry/Complaint Form

STOP - PLEASE DOWNLOAD THIS FORM TO YOUR COMPUTER BEFORE
FILLING IT OUT.
PART ONE (See Page 1, PART ONE - Complainant Information.):

Your Namo: — ALESSANDRA KURCHINSKI

Organization:

Address: 969 SUNRISE DR

City, State, Zip Code: TARPON SPRINGS, FLORIDA, ZIP 34689
Phone: [phone]

Email: ALESSANDRAXP@HOTMAIL COM

ACAP Reference No,

Does this complaint pertain to a matter currently in litigation? Yes X No

PART TWO (See Page 1, PART TWO - Attorney Information:
‘Attorney's Name: LINDA Ruth Alan Florida Bar No. 327621
Address: 10801 Starkey RO, Sut 108-204

City, State, Zip Code: Seminole, FL 93777.

Phone: [phone]

PART THREE (See Page 1, PART THREE — Facts/Allegations.): The specific thing or things I
‘am complaining about are: (attach additional sheet).

PART FOUR (See Page 1, PART FOUR — Witnesses): The witnesses in support of my
allegations are: (attach additional sheet).

PART FIVE (See Page 1, PART FIVE - Acknowledge Oath and Signature.)

[2] vou musr ac vour MARK INTHE ROX ACKNOWLEDGING TH: OATILAND.
YOU MUST SIGN YOUR FULL NAME BELOW,

Under penalties of perjury, I declare that the foregoing facts are true, correct and
complete.

Alessandra Kurchinsk

“Having trouble? Download the form and open the document in Adobe Acrobat. LS

2. PART THREE (See Page 1, PART THREE - Facts/Allegations.): The
‘specific thing or things | am complaining about are: (attach additional
sheet)

Possible Price Gouging in Probate Estate Administration
Estate of Franklin R. Kurchinski — Assets: $2,863.50

vw
Linda Allan, Guardian ad Litem Attorney — Fes

12,985.00

Dear Bar Counsel,

‘The document shows Linda Allan's fees listed at $450/hour for
37.1 hours of service, totaling $16,470.00. As the surviving spouse, and with
my daughter Jacqueline as beneficiary, we objected to her compensation at
$450/hour because Judge Sherwood Coleman had appointed her as Guardian
ad Litem Attomey for my minor daughter Caroline (age 17) at a rate of
$350hour, The amount was later reduced to $12,985.00. If we had not
objected, the Successor Trustee's attorney would not have. It feels as though
there is no effort to reduce fees, only to justify them, more self-serving than
protective of the estate.

The biling descriptions, covering 06/01/2023 through 12/43/2023,
show 68 separate “activity lags,” the majority of which were internal emails. All
of these charges came directly from my family’s assets,

understand that attorneys, guardians, and trustees do not work
for free. But this was a simple estate with only $2,863.50 and one claim of
approximately $176.00 for Sun Star Ambulance. Since the beginning of the
estate, | asked the same question repeatedly to Successor Trustee Nancy
Gorby (cases 22-0010189 ES and 23-007038 Cl). She never gave me a clear
answer until the “trial” before Special Master Magistrate Robert Persante on
‘October 26, 2023, where she admitted she changed from a percentage to
hourly biling for her attorney and paralegal fees, without disclosing any written
fee agreement.

What 1 expect is loyalty and transparency in how fees are
charged, because when feos increase, my family’s assets decrease, Florida
law was designed to protect beneficiaries and surviving spouses from
‘excessive charges, and that is why | am bringing this to your attention,

On June 21, 2023, | was charged $180.00 for an email Linda Allan
sent to attorney Michael Kouskoutis. This email did not benefit the estate — it
was written about me. In that email, Ms. Allan described my questions as

3. “insulting” and “ridiculous” and suggested that: “all of my fees come from
her share because that is, after all, why I'm here.”, she said. | feel! was
punished financially for simply asking questions about my own family’s assets.

1 lost my husband, the man who managed our finances and
secured our future. Now | am raising two daughters alone while trying to
protect our assets. Yes, | asked many questions — some may have sounded
unusual — but it isthe only way I could leam this process. Asking questions
should not be treated as hostility. 1 never intended to insult anyone. If my
words gave that impression, | apologize. My questions came from fear of
losing the assets my husband and | worked for during 22 years of mariage.

What feels most inappropriate is being charged for “internal
emails” that criticize me, while being forced to pay those charges from my
share of the trust estate. If am paying for emails, | should at least have copies
of them to see whether they benefited the estate. Instead, I only saw brief
entries like:

“Email from office of N. Michael Kouskoutis”
“Email to N. Michael Kouskoutis re: potential for
“Emails with atty Kouskoutis’ office re: AK’ ...”
"Potential settlement; Email to Atty Kouskoutis ..."

Ms. Allan also wrote directly to me:

“Just reading all of the questions you ask the PR and
the attorney, which, incidentally, are written in an
unnecessarily accusatory, hostile and insulting
manner, is costing you and your daughters hundreds
and more likely thousands of dollars.” She said.

‘This was intimidating and placed blame on me for rising costs,
‘while ignoring the professionals’ duty of fairness and transparency.

From court records, | also saw Linda Allan and Michael
Kouskoutis emailing about fees:

06/15/2023 - “Email to N. Michael Kouskoutis re:
potential for settlement and amount of fees currently
owed; Review of fee petitions filed by N. Michael
Kouskoutis.” $180.00

4. 06/20/2023 - “Receipt and review of Memo from N.
Michael Kouskoutis re: fees.” $90.00

‘These entries suggest they reviewed and justified each other's
fees, while the obligation to pay fell on me and my daughter Jacqueline. No
discounts were offered, no objections raised, and no disclosure made.

The Second Annual Accounting (10/28/2024) also listed large
disbursements, including:

04/05/2024 — Linda Allan $12,985

12/26/2023 — N. Michael Kouskoutis $18,562.83,
12/26/2023 — N. Michael Kouskoutis $43,812.76
12/26/2023 - Mediator George Geer $2,000

04/02/2024 — Magistrate Robert Persante $12,067.75
Other 2024 expenses totaling $110,574.18, all taken from
my family trust.

Since October 26, 2023, | have received NO invoices from
‘Successor Trustee Nancy Gorby, attomey Kouskoutis, Magistrate Persante, or
substitution counsels Robert Scavone Jr and Shannon Mclin The only detailed
invoice | saw was Linda Allan's (e-filed 02/28/2024, Filing 4192923328), which
contained the troubling email entries.

Conclusion

“Florida Statute $736.1007(c)-(d) requires that trustee's
attorney fees be disclosed in writing and acknowledged by the trustee
and all qualified beneficiaries. If disclosures are not made, attorneys
may not be paid without prior court approval. These protections were
ignored in my case.

Florida Probate Code §733.6171 requires that attorneys for
the personal representative charge only reasonable compensation.
Charging over $12,000 in guardian fees against an estate valued at
$2,863.50 cannot be considered reasonable.

In addition, Linda Allan's conduct appears to violate several
Florida Bar Rules of Professional Conduct:

5. Rule 4-1.5 (Fees and Costs for Legal Services):
prohibits lawyers from charging or collecting a clearly
excessive fee.

Rule 4-1.7 (Conflict of Interest): forbids lawyers from.
engaging in representation where there are conflicting
interests, such as reviewing and approving each others
fees while billing the same estate.

Rule 4-8.4 (Misconduct): prohibits conduct involving
dishonesty, misrepresentation, or conduct prejudicial to the
administration of justice. Billing me for internal emails that
insulted me and suggested all of her fees come from my
share is unprofessional and prejudicial.” ChatGPT.

‘The way these emails and fee approvals are framed shows Linda

Allan and Michael Kouskoutis reviewing and approving each other's charges,
while my family pays the price. | believe this is price gouging, conflict of
interest, excessive fees, and lack of transparency.

Lam a widow, not a lawyer. | have two daughters to raise and

protect. All | am asking for is fairness, honesty, and respect for the assets my
husband and | worked for during our 22 years together. Instead, | have been
charged for emails that insult me and told that my questions are “ridiculous.”

| respectfully ask the Bar to investigate.

Very Respectiuly,
¡pa

ig
lino Kurchinski

Widow of Franklin R. Kurchinski and Beneficiary

In preparing this complaint, I asked ChatGPT (an online writing

assistant) for help organizing my thoughts into clear language. The facts and
experiences described are my own,

&

6. Part Four - Witness

Jacqueline G. Kurchinski

Address: 969 Sunrise Dr. Tarpon Springs, FL 34689
Phone: [phone]

emaiiackurchinski@amail com

Brief

Jacqueline, is the beneficiary of the Franklin R. Kurchinski
and 40% of her trust assets look like was taken to pay Special Magistrate
Robert Persante, Mediator George Geer, attorney Michael Kouskoutis
fees, also the Guardian Ad Litem Attorney fees for Linda R.Allan and
other substitution attorney. The fees was not negotiation with us, and
Linda Allan was appointed for $350 dollars, not # 450 dollars per hour.
Jacqueline objected to it during the court hearing, because the Guardian
was appointed by the court for $350, and she requested more. The judge
reduced her fees, but stil a lot of money for a simple estate.

7. SECOND ANNUAL ACCOUNTING OF SUCCESSOR TRUSTEE,
From: September 1, 2023, Through: August 31,2024

121262023
10760025
12062023
12062023
12262023
01162028

ovosi2008

04022024

05062024

06122024

08/12/2024

0222204

Disbursements

Brief Desripton of eas
WEA ACCT #9208

N. Michael Kouskoutis

N. Michel Konskoutis
George Grer - Mediation Fee
Internal Revenue Services
Advisor Tax Prep

‘Overnight check foe

Linda Allen, Esq
Guardian AQT item foe

Persante Zuroweste PE
Special Magistrate fee

Florida Appeals
Retainer fee associated with Appeal case #1

Florida Appeals
Fees forthe month associated with Appeal case #1

Florida Appeals
Fees forthe month associated with Appeal case #1

REPUBLIC BANK
United States Treasury — Estate Taxes

TOTAL

som

som

so

soo

so”

50.00

som

so.

som

som

$0.00

som

som

Principal

sise
$43,512.76
$2,000.00
$3,616.00
$1,525.00
sis.00
$12,985.00

$12067.75

0,000.00

5527449

s21000

$408.35,

110,874.18

8. From: Linda Alan
‘Sent: Wednesday, June 21,2023 621 PM
To: Michael Kouskouts-<[email protected]>
‘Subject: Estate of Frankin R. Kurchinsky

EXP

UN

Below isa message | drafted to Ms, Kurchlnski. 1 ask that you take look at You and the
PR are much more patent wi her than am, At this point she neds to sto Incuring feos
in gonoral but especially when tl forthe purpose of bang insulting while asking iiclous

y questions. At some point, Im going to tum to asking that al of my faes come from her share
because that is, after a, why Im here, Anyway, fm “previewing” the message for your
Input, but fol ee to share it with your cient as wal. just dit want to do that without
your permission. If you want mete soften ita bi, I wil

Lunda Alan

Ms, Kurchinsk,

In between handing a number of othr cases, Ihave read the emails tha you have
copied me with or sent io me direct. Im going to take the time to expiin some tings to
you regarding the estate process that you don soem to understand

Most of your questions were directed to Ms. Gorby and Mr. Kouskouts. Of courso both
‘of them are charging for their services as am L We do not work fr fee, | dont know the
‘ates they are charging butt would be commen for he atomey representing the Personal
Representative (‘PR’) ofthe estat o charge $360 - $550 par hour depending upon their
‘experience, the duty of tho caso and several other factors. Those are likewise a
‘common rates for people rendering the senicos that am as Guardian Ad Litem. Personal
Ropresentatives who are ot lawyers normally charge in the area of 5100-5200 an hour for

= their services, Just reading all of the questions you ask the PR and the atorey, which,
Incidental are writen in an unnecessary accusatory, hose and insulting manner, i
‘costing you and your daughters hundreds and more likely thousands of dolar:

Florida aw allows lawyers to charge on an hourly basis or onthe basis ofa certain
percentage of tho estate. 1 do not know what the agreement i inthis case as di not ask.
‘But, that sa question you should already know the answer o and Im asking ether the PR
‘or her atomey to advise both you an 1 of thir rates and aso to lt me know when and how
they were disclosed o you.

‘As to your question about whether your late husband pai or his estate atomey and
personal representative feos in his ifetime, | have never heard of sucha thing and have
been practicing law for over 43 yaars. It would be dificult, nt impossible, for someone to
know in advance what It wil cost to probate an esate, And, ot only does one not know
ven he or she Is going to de but that person might o paying a lawyer in advance who

9. right not even be able to handle the estate because of his or her own death or incapaoly
‘Your insinuation, though, in asking the question is hat Mr. Kouskouts is cheating your
{emily and charging double for his oo. That came through loud and clear and twas entirely

inappropriate.

You have complained to mo that the attorney and the PR and her alomey have not
‘wasted you fry nor answered your questions. Your messages ar 1 the contrary. But,
this is my suggestion you stil have questions about this process thal you don believe
‘wore answered ori you don understand the answers given, wit them down and send
‘thom to me and | will make sure that they are clearly answered

Linda Alan
Mectatorariator
727-685-9885

vn Linda lana com

Linda Alan
Modiato“Abivator
727-685-9885

yo LingaAlanlancom

10. Filing # 192923329 E-Filed 02/28/2024 12:54:12 PM

IN THE CIRCUIT COURT FOR PINELLAS COUNTY,
FLORIDA _ PROBATE DIVISION
INRE: ESTATE OF
FRANKLIN R. KURCHINSKI File No, $2-22-CP-10189
Division
Deceased,

Nancy Gorby as Successor Trust of the
Franklin R. Kurchinski Revocable Trust
dated February 23, 2006

Plait

Case No: 2023-C1-7038,

Alessandra Kurchinsk

Jacqueline Kurchinski, and

Carolina Kurchinsk, a minor

by and through her natural parent,

Alessandra Kurchinski
Defendants

PETITION FOR ORDER AWARDING GUARDIAN AD LITEM'S FEE,

Pattioner, LINDA ALLAN, ESQ. alleges

1. Petitioner is an atomey engaged in the practice of law in the State of Florida,

2. Petitioner was appointed by this Cour on Juno 5, 2023 10 represent the interests
of CAROLINA KURCHINSKI, a minor, due to the potential confit of interest betwoen
Carolina Kurchinski, a minor, and her mother, Alessandra Kurchinski

3. Pottioner has rendered 37.1 hours of service to the minor as Guardian Ad Litem,
from June 5, 2023 through November 30, 2023, as more fully described and set forth inthe
itemized schedule of services and expenses attached hereto as Exhibit A, for which petitioner has
not been paid.

4, Peitioners hourly rate is $450.00 per hour and she believes that a reasonable fee
eras Guardian ad Litem if $16,470.00.

forthe services performed by the pet

5. As previously indicated in Petitioner's Reports to the Court, Petitioner believes
these fees should be paid by Alessandra Kurchinski, inasmuch as her actions were in direct
conflict with the best interests ofthe minor, and the nee for the appointment of the Petitioner

FLECTRONICALL FILED 0228/2004 17:54:12 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, NFL

11. was solely due to the actions of Alessandra Kurchinski

Petitioner requests that an order be entered determining a reasonable fe forthe services
rendered by petitioner as Guardian Ad Litem for Carolina Kurchinski, and directing the payment
of said fees by the Trustee of the Franklin R, Kurchinski Revocable Trust to be deducted from

any funds o be distributed to Alessandra Kurchinski

(CERTIFICATE OF SERVICE,

THEREBY CERTIFY that o copy of the foregoing Notice has been provided via the
Florida Court E-Portal on February 28,2024, to:

Allesandra C. Kurchinsk alessandrasp@hotmailcom
Jacqueline G. Kurchinski Jackurchinski@email com
Carolina Kurchinski cicikarehinski@ gmail.com
Nancy Gorby, eo N Michael Kouskowis, Esq. nmk@nmklaw com

LindaR. Allan, Guardian ad Litem

Linda R Allan, Esq.
dallas snail com
10801 Starkey Road, Ste 104, Box 204
Seminole, FL 33778

a

12. DATE

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DESCRIPTION

TIC from office of Judge S, Coleman confirming 2
availabilty o serve as GAL for minor and
‘ensuring no conflict of intrest

Receipt and Review of Onder Appointing: Review 6
‘of Court Docket for caes related to appointment

Receipt and Response to email from Alessandra à
Kurehinski
Email from office of N. Michael Kouskout 4

confirming appointment and response thereto
conference watt re: status of eases

Review of Trust, Amended Inventory of Trust, s
First Interim Accounting

Email to Alessandra Kurchinski re: scheduling 1
appointment to meet wih Carolina

Review of pending motions fled with the Courtto 1.0
determine appropriate actions

‘Travel 1 and Conference w/Client 30

Telephone conference w/N. Michael Kouskouis; 4
email confirming conversation

Receipt and Review of email from N. Michael 2
Kouskoutis re: communications with counsel for
‘Alessandra Kurehinski

Receipt and Review of pleading filed by 3
‘Alessandra Kurchinski

Email to N. Michael Kouskoutis re: potential for 4
sotlement and amount of fees currently owed;

Review of Fee Petitions filed by N. Michael
Kouskoutis =

Receipt and review of Memo from N. Michael 2
Kouskouts re: fs

590.00

$270.00

$135.00

180.00

$430.00

$1,350.00

180,00

$90.00

$135.00

180.00

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Atıy Kouskoutis

Draft report and efile

Receipt and review of email from Office of N.
Michael Kouskouti re: Alessandra Kurchinsk's
police report alleging funds were stoten

Receipt and review of email to J. Kurchinski from
office af N, Michael Kouskoutis responding to
questions asked about ac

Receipt and review of email from Judge Coleman
re: Alessandra will search

Receipt and review of responses and objections
filed by Alessandra Kurchinski

Receipt and review of email from Alessandra
Kurchinski and response from Office of N.
Michael Kouskoutis

Receipt and review of Alessandra Kurchinski's
“Motion for Order Restricting Frivolousness

Receipt and review of emails coordinating
mediation date

Receipt and review of email from Alessandra
Kurchinski objecting to mediation datetime

‘Telephone conference w/N. Michael Kouskoutis
re: rescheduling medition de to conten with
Alessandra Kurchinski and her perecivod belief
that mediation isnot impartial review of em
from AK to trustee and response by N. Michael
Kouskoutis office

Receipt and review of Motion and Claims filed by
AK

Receipt and review of AK exhibit filing

Receipt and review of emails confirming
‘mediation datetimerplace

180.00

8585.00

590.00

590.00

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5675.00

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Begin draft of updated GAL Report

Reccit and Review of Trustee's Response,
Motion and Notice

Receipt and review of email from AK advising of
move to Las Vegas; AK Notice of unavailability

Update and expand report draft

Roceipt and review of AK Response to Motion to
Strike

Finalize and.

2" Report

Receipt and review of mediation order
Receipt and Review of Notice of Mediation
Draft email to mediator

Resp and review fet to judge ied by A
mailto AK; ema from office of N. Michael
Koustoutis advising of consent o zu
Änpeaınc for medio

Reccipt and review of AK's Response 10
Mediation and Exhibit

Receipt and review of email from Atty
Kouskoutis office with proposed mediation
“agreement; review of proposed mediation
agreement

Receipt and review of email from AK reiterating
concems about the initial inventory which was
then amended; email o AK

Emails with atty Kouskoutis’ office re: AROS
continued actions

Receipt and review of AK’s objection

Receipt and review of AK’ Petition to Admit,

$270.00

$135.00

$138.00

$270.00

$135.00

180.00

$90.00

$90.00

50,00

225.00

$135.00

$135.00

$180.00

$180.00

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Receipt and review of AK’s Motion and Exhibits 2 $90.00
re purported Premarital Agreement

Receipt and review of AK response to objection 2 59090

ty Tres

Receipt and review of AK’s objection to Trustees 2 $90.00
proposed Orde for Family Allowance

Receipt and review of Order Appointing Special 2 $90.00
Magisvate and scheduling hang

Receipt and review of emails from AK to Special 2 $90.00
Magis

Receipt and review of continued emails rom AK 2 59000

(o Special Magie

Receipt and review of continued emails from AK 2 $90.00

to Special Magie

Receipt and review o continued emails rom AK 2 $90.00

to Special Magistrate

Receipt and review o continued emails rom AK 2 $90.00

to Special Magistrate

Recsipl and review of first annual accounting of 3 $135.00
Trustee

Preparation for hearing review of AK responseto 30 1350.00
Tristes ummary

Attendance sharing discussions with N. 50 7 3600.00 wow!
Michael Kooskoutis re: potential temen

ÈS

Emails w/Aty Kouskouis office re: potential 8 360.00 vr
sellement options queen emal to parties

Receipt and review of AK’ fee objection ings 2 $90.00
Telephone conference w/Robert Smallwood re: 6 27000

potential setlement; Email to Auy Kouskout
review Response from Atty Kouskoutis office

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Receipt and Review of email from Atty
Kouskoutis office re offers of settlement

‘Receipt and review of email from AK

Receipt and review of Notice of Appearance of N,
David obo AK

Receipt and review of Report and
Recommendation from Special Magistrate

‘Telephone cal to Carolina re: settlement of her
interest in Trust (Ie message)

Emails w/Carolin re: setlement of her interests;
review of proposed setiement agreement and
advised Atty Kouskoutis office of proposed

Receipt and review of revised settlement
agreement

‘Communication w/Carolina and Jacqueline

Review of final setlement agreement
‘recommendation to Carolina to execute same

Receipt and review of order approving Special
Magistrate's Report

EN

90.00

590.00

0.00
180,00
0.00

$225.00

590.00

5135.00

$135.00

0.00

$16,470.00

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17. outlook

Case 2022-CP-10189ES

From alessandra kurchinsi <alessandraxp@hotmailcom>

Date Mon 2023-06-05 7:49 AM.

To Sections <[email protected]>

Ce Nancy Gorby ergerbyO01 @verzon.net>; Jacqueline Kurchinst jeckurchinski@gmailcom>; Ci Kurchinki
<cidkurchinsti@gmal com>

RESPONSE TO THE MOTION APPOINT GUARDIAN/ATTORNEY AD LITEM
FILING#173543347 EFILED 05/19/2023,
ESTATE FRANKLIN R. KURCHINSKI

Good morning,

| am Alessandra C. Kurchinski, the widow of Franklin R. Kurchinski, who passed away on
‘August 12, 2022. | am writing this letter to respond to the Motion for Guardian/Attorney Ad Litem
filed by Nancy Gorby, the fiduciary, in our case.

Firstly, | want to emphasize that the well-being and best interests of my children, Jacqueline
Goncalves Kurchinski and Caroline Goncalves Kurchinski C.K., are extremely important to me.
Since their father’s passing, | have been their main caregiver and have done everything in my
power to full my responsibilities as their mother.

| strongly believe that appointing a guardian or attomey ad litem is unnecessary in this situation.
1 have taken all the necessary steps to ensure the stability, safety, and emotional well-being of
my two children. The claims made by Nancy Gorby do not reflect the truth about our family
dynamics and are unfounded.

| would like to bring to the courts attention the FALSE STATEMENT mentioned as number 7 in
the Motion for Guardian/Attorney Ad Litem. Its falsely claimed that I received property from
Brazil. The truth is that no bank assets or property in Brazil were ever transferred to me.
‘This fact is clearly stated in the Revocable Trust document of Franklin R. Kurchinski, specifically
‘on page 7 of 15, which instructs the trustee to transfer certain properties solely to me. SHE DID
NOT.

Moreover, | strongly disagree with statements number 10, 11, and 12 because they contradict
the facts of the case.

Statement number 13, which wrongly suggests that | intended to claim 100% of the trust assets,
for my personal benefit, is completely false. On the contrary I firmly believe that the Kurchinsk's

Trust funds belongs entirely to my family
et