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Legal Notice2025 ADV 297591—Ashleigh E. Caine vs. Patricia J. Broughton, Trustee of The Catherine Pam Caine Trust UAD October 18, 2021, as Amended, et al.Unknown and Unnamed Beneficiaries and Heirs at Law, the address of each being unknown, will take notice that on April 23, 2025, the undersigned, Ashleigh E. Caine, filed a complaint in the Probate Court, One Lakeside Avenue, N.W., of Cuyahoga County, Ohio, alleging that Plaintiff is the adult and only child of decedent Catherine Pam Caine, who died November 25, 2024; that Defendant Patricia Broughton ("Patricia") is Ashleigh's aunt and Catherine's sister; that in October 2021, less than forty-eight hours after Catherine's husband had died, and at a time when Catherine was herself hospitalized and in very poor mental, physical, and emotional health, Patricia orchestrated the preparation and execution by Catherine of The Catherine Pam Caine Trust UAD October 18, 2021 and a corresponding durable power of attorney naming Patricia as Catherine's agent; and that on April 8, 2022 Patricia orchestrated the preparation and execution by Catherine of an amended and restated trust agreement; and that the Trust and Amended Trust should be held void and unenforceable due to Patricia's undue influence and tortious conduct and/or due to Catherine's lack of capacity. Patricia should also be required to fully account for her conduct as agent and trustee and disgorge any and all funds she misused or misappropriated while serving as Catherine's fiduciary.
Plaintiff respectfully prays for the following:
1. Judgment declaring the Original and Amended Trust, as well as any payable-on-death, transfer-on-death, and other beneficiary designations for the benefit of Patricia and/ her family members, and transactions in Catherine's assets for the benefit of Patricia and/or her family members, set aside, invalid, null and void, and imposing monetary damages against Patricia in Ashleigh's favor in an amount in excess of $25,000 in compensatory damages and an amount in excess of $25,000 in punitive damages, together with interest, costs of this action, attorneys' fees, and such other and further relief as the Court deems just and proper.
2. Judgment declaring the Original and Amended Trust, as well as any payable-on-death, transfer-on-death, and other beneficiary designations for the benefit of Patricia and/ her family members, and transactions in Catherine's assets for the benefit of Patricia and/or her family members, set aside, invalid, null and void, and imposing monetary damages against Patricia in Ashleigh's favor in an amount in excess of $25,000 in compensatory damages and an amount in excess of $25,000 in punitive damages, together with interest, costs of this action, attorneys' fees, and such other and further relief as the Court deems just and proper.
3. Judgment against Patricia in an amount in excess of $25,000 in compensatory damages and an amount in excess of $25,000 in punitive damages, together with interest, costs of this action, attorneys' fees, and such other and further relief as the Court deems just and proper.
4. Judgment requiring Patricia to gather and disclose all records regarding the Original and Amended Trust, disclose all assets of the Original and Amended Trust, inclusive of those commingled with her own, and provide complete and adequate reports of the Original Trust and Amended Trust, including receipts, disbursements, appreciation, depreciation, and categorizing and detailing expenses, together with the costs of this action, attorneys' fees, and such other relief as the Court deems just and proper.
5. Ordering a review of Patricia's conduct as agent for Catherine requiring Patricia to provide a full, complete, and itemized accounting of all receipts and disbursements pertaining to Catherine's assets, including but not limited to production of all account and bank statements, financial records, checks, transfer documents, beneficiary designation forms, redemption and surrender forms, and all other financial records and materials pertaining to Catherine's Assets from October 2021 to the present. Additionally, an order requiring Patricia to appear in person before this Honorable Court for a hearing to determine what relief, if any, should be granted upon the review of her conduct, and imposing monetary damages against Patricia in an amount in excess of $25,000, together with interest, costs of this action, attorneys' fees, and such other and further relief as the Court deems just and proper.
6. For orders, judgments, and decrees, as may be requested by Plaintiff that this Court deems just and equitable, together with an order for reasonable attorney fees and costs for this action.
The defendants named above are required to answer on or before the 2nd day of July, 2025.
Ashleigh E. Caine.
By Adam M. Fried and Shane A. Lawson, Attorneys for Plaintiff.Apr30May7-14-21-28Jun4, 2025
Class
130
First Run
04/30/2025
Second Run
05/07/2025
Third Run
05/14/2025
Fourth Run
05/21/2025
Fifth Run
05/28/2025
Sixth Run
06/04/2025
Case #
2025 ADV 297591
Plaintiff
Ashleigh E. Caine
Defendant
Patricia J. Broughton, Trustee, etc., et al.
