Soriano v. Estate of Manes

By Jenna G. Rubin

This decision centered around whether a potential civil claimant arising out of a pending criminal prosecution was a “reasonably ascertainable creditor” entitled to personal service of the notice to creditors.  The Court ultimately held that the claimant was not a reasonably ascertainable creditor, because the personal representative has no actual knowledge of the claimant’s civil claim, nor would a more diligent search have revealed the existence of the claim.