Yivo Institute for Jewish Research v. Zaleski

SHARER, Judge.

In this appeal we are called upon to consider the doctrine of ademption by satisfaction (or advancement), a concept of Maryland jurisprudence taken up only infrequently by our appellate courts. Appellant, the YIVO Institute for Jewish Research, asks this Court to reverse a ruling by the Orphans’ Court for Montgomery County 1 that it was not entitled to distribution of a bequest in the will of Jan Karski. Appellees are the personal representative of the estate, and two (of several) beneficiaries, the Kosciuszko Foundation and The American Center of Polish Culture.

Two questions…