IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
WAYNE BARROW, as Trustee of )
the VOLETTA WALLACE )
REVOCABLE TRUST, )
)
Plaintiff/Counterclaim )
Defendant, )
)
v. ) C.A. No. 2025-0760-KSJM
)
FAITH EVANS, )
)
Defendant. )
)
and )
)
NOTORIOUS B.I.G., LLC, )
)
Nominal Defendant/ )
Counterclaim Plaintiff. )
ORDER DENYING MOTION TO STAY
1. This action arises from a dispute over an entity, Notorious B.I.G., LLC
(the “Company”), which holds rights to the intellectual property of the late rapper
Christopher Wallace. Wallace’s mother and widow formed the Company in 2007. His
mother, Voletta Wallace, passed away and left all her assets to “Voletta Wallace
Revocable Trust u/a/d December 14, 2020” (the “Trust”). His widow, Faith Evans,
manages the Company. She has declined to recognize the Trust as a member of the
Company. The sole trustee of the Trust, Plaintiff Wayne Barrow, filed this action
seeking a declaration that the Trust is a member of the Company. He later moved
for summary judgment.
2. In the month before she died, Voletta removed her grandson,
Christopher Jordan Wallace (“CJ”), as a trustee of the Trust.1 On February 20, 2026,
CJ filed a petition in Pennsylvania Orphans’ Court challenging Voletta’s efforts to
remove him before her death (the “Pennsylvania Litigation”).2
3. On March 4, 2026, Evans and the Company (“Defendants”) moved to
stay this litigation in favor of the Pennsylvania Litigation.3 During an April 7, 2026
hearing, the court denied the stay to allow the motion for summary judgment to
proceed.4 The court denied the stay without prejudice, which allowed Defendants to
re-assert their stay arguments in connection with summary judgment.5
4. Defendants reasserted their stay arguments in response to the motion
for summary judgment. They argue that the court should stay this case pending
resolution of the Pennsylvania Litigation, which challenges Plaintiff’s ability to act
on behalf of Voletta’s Trust and estate.6 According to Defendants, every aspect of
Plaintiff’s position in this action rests on the premise that he is the sole trustee of the
Trust and the sole executor of Voletta’s estate.7
1 This decision uses first names at times to distinguish the members of the Wallace
family. The court intends no familiarity or disrespect.
2 C.A. No. 2025-0760-KSJM, Docket (“Dkt.”) 78, Decl. of Faith Evans, ¶ 49; id., Ex.
AA (“Pennsylvania Petition”).
3 Dkt. 61.
4 Dkt. 72 at 38:18–40:5.
5 Id.
6 Dkt. 78 at 18–19.
7 Id. at 18.
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5. But Plaintiff accepted his appointment as a successor trustee of the
Trust on March 6, 2025.8 Pennsylvania law does not suspend a fiduciary’s authority
to act even while that authority is challenged.9 Nor would Plaintiff’s removal
necessarily invalidate actions he took before his removal.10 If CJ seeks to enjoin
Plaintiff from acting on the Trust’s behalf during the pendency of the Pennsylvania
Litigation, he should seek that relief from the Pennsylvania court. But there is no
dispute that Plaintiff has the authority to act on the Trust’s behalf now.
6. Moreover, a dispute regarding Plaintiff’s role as the trustee does not
create a factual dispute over whether the Trust is a member of the Company. Under
both the original and amended estate plans, Voletta’s member units passed to the
Trust. And, in the Pennsylvania Litigation, CJ seeks to “reinstate” the original will,
which leaves Voletta’s entire estate to the Trust.11 There is thus no reason to delay
summary judgment. The motion to stay is denied.
/s/ Kathaleen St. J. McCormick
Chancellor
August 7, 2026
8 Dkt. 71, Decl. of Wayne Barrow, Ex. J.
9 20 Pa. Cons. Stat. § 908(c) (1974) (“No appeal [including the challenge to the probate
of a will, see 20 Pa. Cons. Stat. § 908(a) (2006)] from a decree of the register shall suspend the powers or prejudice the acts of a personal representative to whom letters have been granted.”).
10 See 20 Pa. Cons. Stat. § 3329 (1972) (“No act of administration performed by a
personal representative in good faith shall be impeached by the subsequent revocation of his letters or by the subsequent probate of a will, of a later will or of a codicil[.]”).
11 See Pennsylvania Petition.
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