IN THE PROBATE COURT OF DEKALB COUNTY

STATE OF GEORGIA

RE: ESTATE OF GENEVA S. CAFFREY *

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* Probate Case No.: 2002-1161
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SUMMARY JUDGMENT MEMO

IN THE FAVOR OF JAMES STEGEMAN

Mr. Lillig as Temporary Administrator gave away belongings of Ms. Caffrey’s

that should have gone to family members. Since there were Two Wills, nothing should
have been given away. Mr. Stegeman who was named in the original Will as Executor
and sole Beneficiary, should have been notified that Mr. Lillig was Petitioning for
Temporary Administration of The Estate of Geneva S. Caffrey. If Mr. Lillig had not
perjured himself under Oath by swearing there were no other wills, and that Mr.
Stegeman was under investigation by the DA’s Office, Mr. Lillig may not have been the
Temporary Administrator.
Temporary Administrators’ duties are to carry out existing contracts and do such
acts as necessary to protect and preserve the Estate as is stated in O.C.G.A. 53-7-4.
1. Mr. Lillig authorized payment to Mr. Joyner in the sum of $15,542.69 on June 10,
2003.
2. The Summary Judgment Memo provided with the Motion For Summary
Judgement states: “The Deceased died on the 18th day of April 2003.” To begin
with Ms. Caffrey passed away on April 17th, 2003 according to Death Certificate.
3. Summary Judgement Memo states: “Lillig was first named temporary
administrator on May 5, 2003” “granted letters of testamentary on April 20,
2004”. Then Mr. Lillig claims: “John Joyner, DeKalb County guardian of the
property of the Deceased, was the guardian until the decease death.” Yet Mr.
Lillig was controlling the Estate before June 10, 2003 judging from the Petition
For Extra Compensation filed for Joyner and signed by Mr. Lillig June 10, 2003
consenting to Mr. Joyner’s payment. Oddly enough This payment shows in
neither Mr. Joyner’s billing nor Mr. Lillig’s billing. Furthermore Mr. Joyner’s
billing shows $33,000 to beneficiary. There was no beneficiary while Mr. Joyner
was guardian of property for there were two Wills yet to be decided on.
“Exhibit A” is attached covering 1,2, and 3.

The following refers to an account that was titled Janet D. McDonald and James B.
Stegeman Joint Tenants With Rights of Survivorship that Mr. Joyner had renamed John
C. Joyner Guardian of the Property of Jean S. Caffrey. This was the reason for the
lawsuit in Superior Court, Mr. Joyner knew that his manipulation of the account had been
discovered, he filed a Vexatious Litigation in Superior Court knowing that while in
litigation, no one would discuss the account with James B. Stegeman or Janet D.
McDonald. Mr. Apolinsky’s letter to Securities and Exchange backs up this claim.
“Exhibit B”
O.C.G.A. 53-5-62.
Only individuals whose registration of a security shows sole ownership by one individual or
multiple ownership by two or more with right of survivorship, rather than as tenants in common,
may obtain registration in beneficiary form. Multiple owners of a security registered in
beneficiary form hold as joint tenants with right of survivorship, as tenants by the entireties, or as
owners of community property held in survivorship form and not as tenants in common.

There is no way the accounting provided by Mr. Lillig is accurate. In fact the
billing by Joyner could not be accurate. Upon a legal investigation by Mr. Apolinsky,
the home Ms. Caffrey was in and the bills she had while alive could not have cost
$88,000. Attached is a copy of the letter to the GA Bar from Mr. Apolinsky stating
this “Exhibit C”.
Mr. Joyner’s Annual Return dated 06/01/2002 to 05/31/2003, covers the
period in which Ms. Caffrey was alive and died and Mr. Lillig was appointed
Temporary Administration. The total receipts for assets amounts to $198,912.69. The
total disbursements = $88,789.67. Assets still held: Dec 1st co-mingled $3933.94,
Dec 1st Money Market $35,015.36, Checking account is scratched out, Investment
account showing McDonald/Stegeman account number $67,875.50 and the Edward
Jones acct shows $3298.22. The net balance on hand was showing $110,123.02.
This means at that time, the McDonald/Stegeman account was only worth
$67,875.50.
Mr. Lillig’s submitted John Joyner’s Annual Return dated 06/01/2003 to
05/03/2004 shows change in the McDonald/Stegeman account (due to market
fluctuations and total of debits and credits) a balance of $62,086.70 + interest +
“other income” $5,000.00 which brought the total receipts to $177,575.48.
Disbursements $19, 458.02 + 21.96 + 113.00 + 3.25 + 654.98 + 27,261.59 +
McDonald/Stegeman account $130,032.68. There is no possible way on earth that
the McDonald/Stegeman account more than doubled in one year! There is something
not quite right with this. Not to mention Mr. Lillig claims on the second page of the
Summary Judgment Memo in the second paragraph “The Caveator received
approximately $120,000.00”. That states that at least $10,000 was taken and not
accounted for by Mr. Lillig. Obviously Mr. Lillig, Mr. Turner and Mr. Joyner have
abused an account that did not belong to Ms. Caffrey but was in fact the
McDonald/Stegeman account. The account properly titled Janet D. McDonald AND
James B. Stegeman Joint Tenants With Rights of Survivorship has no assets! Mr.
Stegeman did not get $130,000 Joyner claims and did not get $120,000 Lillig claims
and they both have committed perjury in the bookkeeping records. Crimes have been
committed and it is the duty of The Probate Court of DeKalb County to see that this
matter goes to the District Attorney’s Office for prosecution. “Exhibit D” shows the
above mentioned documentation.

Sincerely Submitted,

_____________________
JAMES B STEGEMAN
821 Sheppard Rd, Stone Mountain, GA 30083