The Surrogate's Court in Monroe County has ruled on a significant estate management dispute involving the estate of Bonnie Lee Lavorato. The case centers on a petition filed by one of Lavorato's children, Megan Lavorato, who sought to investigate how the estate's fiduciary, her sister Mariah Lavorato, managed a business owned by the estate. This ruling affects the five children of the deceased and clarifies the rights of beneficiaries in estate matters.
Bonnie Lee Lavorato passed away on August 28, 2024, leaving behind a will that divided her estate equally among her five children: Jordan, Mariah, Frank III, Megan, and Joshua. The will specified that the estate’s shares in a corporation, Private Label Foods of Rochester, Inc., were to be sold, but not to any of her children or their spouses. Instead, the shares were to be offered to certain employees first, and if they declined, the executor could sell them at fair market value. This stipulation has led to a conflict regarding the management and sale of the business, prompting Megan to file her petition.
The case reached the Surrogate's Court after Mariah, as the nominated executor, was granted letters testamentary on October 1, 2024. Following the death of their mother, Megan raised concerns about the management of the corporation and the timeline for selling the shares. After the employee buyers declined to purchase the shares, Megan's legal counsel expressed dissatisfaction with the lack of communication from Mariah regarding the sale process. This prompted Megan to file a petition under New York's Surrogate's Court Procedure Act (SCPA) 2102, seeking information about the estate's assets and the management of the corporation.
The court ruled on December 19, 2025, denying Mariah's motion to dismiss Megan's petition. Judge Christopher S. Ciaccio stated that Megan, as a beneficiary of the estate, qualifies as a "person interested" in the estate's affairs, allowing her to seek information from the fiduciary. The court emphasized, "The fact that Megan is not a shareholder is irrelevant here, since the scope of the relief afforded by SCPA 2102 (1) ... simply provides that a party interested in an estate can ... move to have production of the information ordered." This ruling affirms the rights of beneficiaries to inquire about the management of estate assets.
The court also addressed the fiduciary's argument that the dispute was between living parties and outside the Surrogate's Court's jurisdiction. Judge Ciaccio clarified that the dispute relates to the estate's assets and that the court has jurisdiction over such matters. He noted that the decedent's will explicitly stated her desire for her children to benefit from the sale of the corporation's shares, reinforcing the court's authority to oversee the process.
While the court denied the motion to dismiss, it did limit the scope of the information that Mariah must provide. The court ruled that Mariah must turn over specific documents, including the corporate bylaws and any amendments, as well as an agreement listing the business for sale. However, the court denied Megan's broader request for all documents related to the corporation, stating that the decedent's intent was to keep her children out of the management of the corporate affairs.
This ruling has significant implications for the Lavorato family and similar cases in the future. It establishes that beneficiaries of an estate have the right to seek information about the management of estate assets, even if they are not shareholders in a business owned by the estate. The court's decision also clarifies the fiduciary's responsibilities to act in the best interest of the estate and its beneficiaries.
Moving forward, the ruling sets a precedent for how Surrogate's Courts may handle similar disputes involving estate management and the rights of beneficiaries. It emphasizes the importance of transparency and communication between fiduciaries and beneficiaries, particularly in cases where business interests are involved.
The case may still be subject to appeal, but details about any potential appeal were not available in the court filing. As of now, the focus remains on the execution of the court's order and the sale of the corporation's shares as stipulated in the will.