EXECUTOR BRIEFING

Estate of Jane Ann Workman | 4200 Armstrong Pkwy, Highland Park, TX 75205

Estate ID: 89088d15-0093-4d19-bbdf-593dd972d779 | Prepared: April 2026 | Jurisdiction: Dallas County, Texas

SECTION 1 — ESTATE SUMMARY

⚠️ Master Headline

The estate's primary real property asset no longer exists. 4200 Armstrong Pkwy was sold to a Cooley LLC entity in late 2024 and the structure was demolished on January 7, 2026. The parcel is now bare land held by a third-party purchaser. The assessor roll's "Workman Jane Ann of (estate)" designation is stale and has not been updated to reflect the conveyance. The estate's primary asset has converted from real property to sale proceeds of approximately $7–$10M+, the status of which is the single most urgent unresolved question in this administration.

SECTION 2 — RISK ASSESSMENT

Estate-Readiness Score: 3 / 10

Justification: Three critical-severity unknowns — proceeds status, executor authority validity, and the community property chain — each independently capable of exposing the estate to substantial liability or litigation. The will has not been reviewed, no complete asset inventory exists, and MERP inquiry remains open. The estate is not ready for distribution and requires urgent remediation across multiple fronts simultaneously.

SECTION 3 — PROPERTY DOSSIER

Property: 4200 Armstrong Pkwy, Highland Park, TX 75205

Title Status

Known and Potential Liens / Encumbrances

SECTION 4 — CREDITOR PAYMENT SEQUENCE

All claims must be paid in the statutory order prescribed by Tex. Est. Code § 355.102. The homestead exemption (Tex. Const. Art. XVI § 50), which previously shielded the property from Class 8 creditors, was extinguished upon the 2024 sale; proceeds are generally available to all creditor classes subject to the statutory order below.

Texas Statutory Creditor Priority — 8-Class Hierarchy

⚕️ Texas Medicaid Estate Recovery Program (MERP) — Class 7 Mandatory Filing

⚠️ Critical MERP Warning: MERP applies if Jane Ann Workman received nursing facility care, STAR+PLUS Waiver, CLASS, DBMD, HCS, TxHmL, HCBS, or related Medicaid-funded hospital or pharmaceutical services while age 55 or older after March 1, 2005. If HHSC was not notified within 30 days of death and any claim was not satisfied before the 2024 property sale, HHSC's expanded-scope recovery authority may expose the Cooley buyer to a recovery action. The personal representative must contact HMS at 1-800-641-9356 immediately to confirm presence or absence of a MERP claim.

Claims Deadlines (Texas Nonclaim Statute)

⚠️ Executor Personal Liability Warning: Failure to publish creditor notice within 30 days of qualification exposes the executor to personal liability for unpaid creditor claims under Texas law.

SECTION 5 — DOCUMENT DEFICIENCIES

5A — Will Execution & Probate Status

5B — Trust Funding & Non-Probate Transfer Gaps

5C — Community Property Chain Deficiencies

SECTION 6 — 30-ACTION CHECKLIST

Priority Tiers: 🔴 Immediate (within 7 days) | 🟡 30-Day | 🟢 90-Day

1. [🔴 IMMEDIATE] Pull the 2024 deed instrument from the Dallas County Clerk (500 Elm St, Suite 2100, Dallas TX 75202 | 214-653-7099) — confirm Cooley LLC grantee name, execution date, sale consideration, and notarization.
2. [🔴 IMMEDIATE] Confirm and account for the 2024 sale proceeds — verify receipt into estate account, current balance, and whether any proceeds have been distributed.
3. [🔴 IMMEDIATE] Contact HMS MERP at 1-800-641-9356 — confirm whether Jane Ann Workman received covered Medicaid services; obtain written confirmation of claim or no-claim status; confirm death notice was given within the 30-day window.
4. [🔴 IMMEDIATE] Obtain Jane Ann Workman's certified death certificate to anchor all statutory deadlines (probate filing, MERP, creditor notice, tax returns).
5. [🔴 IMMEDIATE] Search Dallas County Probate Court records for the Estate of Jane Ann Workman — confirm whether a probate proceeding has been opened, the case number, and whether Letters Testamentary were issued.
6. [🔴 IMMEDIATE] Pull a copy of Jane Ann Workman's will from the Dallas County Probate Court or the estate attorney — review for executor identity, administration type, distribution scheme, and RUFADAA digital asset language.
7. [🔴 IMMEDIATE] Confirm that Letters Testamentary (or Letters of Administration) were current and valid at the time of the late 2024 deed execution to the Cooley LLC entity — if lapsed or never properly issued, the deed may be voidable.
8. [🔴 IMMEDIATE] Obtain Tom Workman's certified death certificate and pull his Dallas County probate file — confirm he predeceased Jane Ann and that his 50% community property interest was properly conveyed or addressed.
9. [🔴 IMMEDIATE] Pull the Dallas County deed records chain of title against APN 60084501030130000 — confirm all instruments in the ownership chain from the Workmans to Cooley LLC and identify any gaps.
10. [🔴 IMMEDIATE] Verify property tax payment status with the Dallas County Tax Assessor-Collector and Highland Park municipal taxing authorities — pull DCAD tax certificate confirming 2021–2024 taxes paid (or confirm paid from 2024 sale proceeds at closing).
11. [🔴 IMMEDIATE] Search the Dallas County Clerk judgment index for any abstract of judgment recorded against Tom E. Workman and/or Jane Ann Workman — specifically the Torrey v. Workman litigation identified in Trellis.Law.
12. [🔴 IMMEDIATE] Confirm whether creditor notice has been published in a Dallas County newspaper of general circulation within 30 days of Letters Testamentary being granted — if not done, publish immediately to avoid executor personal liability (Tex. Est. Code § 308.051).
13. [🟡 30-DAY] Retain a USPAP-qualified appraiser with experience in architecturally significant properties to establish the retrospective fair market value of 4200 Armstrong Pkwy as of Jane Ann Workman's date of death for estate tax and probate inventory purposes (IRC § 2031; Tex. Est. Code § 309.001).
14. [🟡 30-DAY] Confirm the exact Cooley LLC grantee entity from the deed instrument — run a Texas Secretary of State UCC Division lien search against that specific entity to identify any secured creditors or fixture filings.
15. [🟡 30-DAY] Search Texas Secretary of State UCC Division for any UCC-1 financing statements filed against the decedent (Jane Ann Workman) individually — these may encumber personal property assets.
16. [🟡 30-DAY] Confirm that all of Tom Workman's will beneficiaries or heirs executed quitclaim deeds or were otherwise addressed at or before the 2024 closing — if not, obtain curative quitclaim deeds or negotiate resolution with Cooley LLC and any identified beneficiaries.
17. [🟡 30-DAY] Commission a complete estate asset inventory beyond the real property — financial accounts, investment portfolios, retirement accounts (IRAs, 401(k)s), life insurance, art, business interests, and digital assets (Tex. Est. Code § 309.001; due within 90 days of executor qualification).
18. [🟡 30-DAY] Notify all known heirs and beneficiaries in writing within 60 days of executor appointment as required by Tex. Est. Code § 308.002.
19. [🟡 30-DAY] Confirm Highland Park municipal assessments, any special improvement district charges, or Town of Highland Park utility fees through the town offices and confirm payment status or resolution at closing.
20. [🟡 30-DAY] Pull the Highland Park deed restriction index and subdivision plat from the Dallas County Clerk to confirm any applicable deed restrictions and whether demolition triggered any restriction violations.
21. [🟡 30-DAY] File a certified copy of the will (and of Tom Workman's will) with the Dallas County Clerk deed records if heirship proceedings or affidavits of heirship may be needed to cure any chain-of-title defect.
22. [🟡 30-DAY] Confirm no child support arrearage or past-due support order exists against Jane Ann Workman — verify with the Texas Attorney General Child Support Division (Class 4 creditor priority under Tex. Est. Code § 355.102(e)).
23. [🟡 30-DAY] Instruct the estate attorney to confirm that all Class 1 (funeral/last illness) creditors have submitted claims with supporting documentation for court approval, not to exceed $15,000 each (Tex. Est. Code § 355.102(b)).
24. [🟡 30-DAY] Confirm the 4-year MERP statute of limitations has not expired — if death was in 2023, HHSC has until ~2027 to assert a recovery claim (Tex. Human Resources Code § 32.024); if proceeds have been distributed prematurely, recovery risk escalates.
25. [🟡 30-DAY] Confirm the school district homestead tax exemption (Tex. Tax Code § 11.13, $100,000 reduction) was properly maintained through the date of sale and that the estate is not subject to any exemption recapture or rollback.
26. [🟢 90-DAY] Engage an estate tax attorney to evaluate federal estate tax exposure once the full asset inventory is completed — using the correct 2026 federal exemption (~$15M/person); evaluate portability election on Form 706 if Tom Workman predeceased and had unused exemption (IRC § 2010(c)).
27. [🟢 90-DAY] File Jane Ann Workman's final federal income tax return (Form 1040) for the year of death and any unfiled prior years — confirm all federal income tax obligations are resolved before Class 5 can be closed.
28. [🟢 90-DAY] Review the will for Tex. Est. Code Ch. 2001 (RUFADAA) digital asset authority — if absent, the executor's access to financial accounts, cloud storage, email, and other digital assets may be restricted and a court order may be required.
29. [🟢 90-DAY] Conduct a final IRS federal tax lien search against Jane Ann Workman and Tom Workman individually at the Dallas County Clerk to confirm no federal tax liens are recorded against any estate assets or proceeds.
30. [🟢 90-DAY] Once all creditors are paid and claims resolved, prepare executor's deed of distribution (or confirm that proceeds were properly distributed per the will) and file a final accounting in Dallas County Probate Court to formally close the estate.

SECTION 7 — ATTORNEY ACTION ITEMS

Priority 1: Probate Administration Integrity

Priority 2: Community Property Chain of Title

Priority 3: Sale Proceeds & Creditor Resolution

Priority 4: Litigation Lien — Torrey v. Workman

Priority 5: Federal Estate Tax & Final Returns

Priority 6: RUFADAA & Digital Assets

Texas Statutory Reference Master Table

This briefing is for informational purposes only and does not constitute legal advice. AI-generated analysis should be independently verified by a licensed attorney.