samsloan
2012-03-15 19:35:11 UTC
Samuel H. Sloan
Administrator with Will Annexed of
Estate of K. Michael Goodall
461 Peachstone Terrace
San Rafael CA 94903
415-419-5980
415-349-6116
***@gmail.com
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF MARIN
In the Matter of the Estate of
K. Michael Goodall
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
Case No. PR 1100596
SUR-REPLY TO BANK OF AMERICA'S ATTEMPT AT DEMURRER
Hearing Date: March 19, 2012
Time: 8:30 AM
Department: H
Sam Sloan declares:
1. I am the Administrator with Will Annexed of the Estate of K.
Michael Goodall. I have personal knowledge of the matters set forth
herein and, if called upon to testify, could and would competently
testify thereto.
2. In their reply declaration which I just received although
this matter has been pending for months, counsel for Bank of America
states: “Mr. Sloan does not question that Michael Goodall was served
with notification by the trustee.” It goes on to add the words “in
their capacity of settlers of the trust as amended”.
3. However, it does not state “as amended” WHEN. Since Mike
Goodall is dead I do not know what Mike was served with, but I do know
that the operative amendment to the 1990 trust is the 1999 Amendment
to the Trust. That amendment made Mike Goodall the co-trustee, with
his mother. Thus, Mike Goodall was legally the sole surviving Trustees
of the trust until his death on October 5, 2010, at which point the
trust, by its terms, was dissolved. Thus, Bank of America was never
the legal trustee and never had and does not have the legal right to
act as the trustee.
4. A copy of the 1999 Amendment to the Trust is annexed hereto
as Exhibit A. As will be seen, this document was prepared by James R.
Hastings, who acted as notary public in notarizing the signatures of
Mike Goodall and his mother, Rachel A. Goodall. Since Mr. Hastings
prepared and witnessed this document, he cannot be heard to complain
that this document is not valid. Until now, there has never been any
explanation offered by him or by Bank of America as to the grounds on
which Bank of America and James R. Hastings assert that the disputed
1994 trust is the operative document and that the 1999 document should
be ignored. The documents now filed by Bank of America never mention
the 1999 Amendment to the trust.
5. Even without the 1999 Amendment to the Trust, there is newly
discovered evidence in this case because I did not know and Mike
Goodall could not have known that the witness to the August 24, 1994
documents has come forward and stated that she did not sign them. The
witness is absolutely certain of this. Her husband, a retired
Professor of Business Administration at San Francisco State
University, also states that she did not and would not have signed
these documents, as does their daughter, a real estate agent. At the
deposition of James R. Hastings on November 14, 2011, he stated that
the documents were witnessed by his secretary. We therefore assumed
that Nancy Rodgers was the name of his secretary. It was to my great
surprise that Sam Ware discovered that Nancy Rodgers was the lady
across the street and a close friend of Rachel Goodall.
6. Bank of America cherry picks documents from the 1999 case
without indicating the context to the documents to which they were
responding. In the 1999 case, Bank of America was represented by the
same James R. Hastings who claims to represent all sides to these
transactions. In three documents filed in San Francisco Superior Court
on March 21, 2000, James Hastings stated that Mike Goodall was
challenging the trust, by demanding the removal of Bank of America as
Trustee. Hastings stated that because of the “no contest clause”, Mike
Goodall should be evicted from the Goodall Mansion at 461 Peachstone
Terrace, San Rafael, leaving him homeless and without funds, because
Mike Goodall had used his life savings to hire an attorney to
represent him and thus was out of money. It was because of this threat
to dis-inherit him entirely that Mike Goodall responded the way that
he did. There was never any final decision in that case, which is the
same case that Bank of America revived recently.
7. When and if a fact hearing is held here on this issue, we
will prove that Col. Goodall did not and could not have signed the
August 24, 1994 documents in the way that Hastings describes. James
Hastings keeps changing his story as to where Col. Goodall was when he
signed these documents. We can prove that he was in none of those
places. We are now seeking medical records to determine whether Col.
Goodall was conscious or unconscious on that date. He was very ill and
at the point of death. He was at the end of his life. Even were it
true that Col. Goodall was awake and signed the documents, it would
mean that James R. Hastings came to him on his death bed and induced
him to sign documents changing his estate plans so as to disinherit
his only son, Mike, Col. Goodall could not possibly have understood
what he was signing, because even today we cannot figure out what the
document says due to its confused and circular wording, which seems to
have been drafted in such a way as to deliberately confuse the reader.
8. James R. Hastings and Bank of America do not merely refuse to
produce the estate planning documents. They have failed to produce any
documents at all. Not even one scrap of paper has been produced by
them. They refuse to account for the funds. They refuse to tell us how
much money they have or where they got it from. Rachel Goodall died on
June 7, 1999. On November 11, 1999, five months later, they still did
not have any money. Their own documents filed in court in 2000 state
that Bank of America had no estate money, zero, even months after the
death of Rachel Goodall. Thus, we know that any money they got came
well after the deaths of Col. and Rachel Goodall. We also know that
the policy of Bank of America is they do not take a case unless there
is at least a million dollars involved. That plus the fact that they
now have six lawyers working on this case tells us that there is a lot
of money involved in this case, probably more than we could possibly
imagine. We have documents showing that Rachel Goodall had $610,000 in
just one account with USAA Investment Management in 1995. We know that
Bank of America got that money after Rachel Goodall died. How much
more they got they refuse to tell us.
9. When I come to court on March 19, 2012, I will bring with me
two ring binders, a blue ring binder and a green ring binder. These
are Col. Goodall's compilation of documents. If this court will care
to look through these ring binders, it will see the incredible detail
to which Col. Goodall went to prepare his estate plans. I think this
court will agree that it is inconceivable that the person who went to
such great length to prepare his estate plans would on his death bed
decide to throw the whole thing out and entrust it all to a lawyer,
James R. Hastings.
10. I have demanded pursuant to California Government Code
Section 8206 (c), that James Hastings provide to me a photostatic copy
of the line items representing each of the transactions in which he
acted as a Notary Public and notarized the signatures of Kenneth F.
Goodall, Rachel A. Goodall and/or Kenneth Michael Goodall. Mr.
Hastings has responded to this demand but his response is legally
insufficient. Notary Public law provides that when a trust document is
signed there must also be a thumb print taken. There are no thumb
prints in the documents submitted. There is no way to tell whether
there are from the original journal or newly created. Also, James R.
Hastings was legally barred from notarizing these documents as he had
a financial interest in the transaction as he was also the attorney
for Bank of America.
11. After I had for practical purposes won this case in Marin
County Probate Court, Bank of America started a new case by filing on
April 21, 2011 in San Francisco Probate Court a petition seeking
essentially to overturn by collateral attack the decision of the Marin
County Probate Court. They thus have required me to retain counsel to
defend the Estate in that court. This should not have been allowed.
From the first filing in that court, I have consistently objected to
the jurisdiction of the San Francisco Probate Court, at every
opportunity. It is clear that the San Francisco Court has no
jurisdiction. The Goodalls lived their lives and died in Marin County.
All of their property including their house is located in Marin
County. All of the documents in this case were executed in Marin
County. The Goodalls did not like San Francisco and almost never went
there. The San Francisco Superior Court does not have nor had
jurisdiction to decide on the ownership of the house, since the house
is located in Marin County. There is nothing about this case that has
anything to do with San Francisco.
12. Yet, Bank of America keeps insisting that this case be heard
in San Francisco and not in Marin. For what reasons one can only
imagine. I shall be asking the courts to require Bank of America to
reimburse the Goodall Estate for all attorneys fees required to be
paid because of their frivolous filings.
13. Because I have been forced to defend the Goodall Estate in
the San Francisco Probate Court even though that court plainly has no
jurisdiction, there has been motion practice in that court in which my
counsel subpoenaed the documents pertaining to these cases. The
opponents have produced zero documents, none at all. They keep
claiming that the judge in San Francisco limited discovery and within
those limitations there are no discoverable documents. However, I was
in court and the judge there made no such ruling. The Bank of America
was asking the judge not to allow any discovery at all and to make an
immediate ruling. Their request was not granted and ever since that
judge has declined to hear this case. Also, Judge Peter Busch has
stated that he does not want to hear this case any more and is passing
it off to other judges. This case has become a hot potato over there.
It should never have been allowed over there in the first place, since
the case in this court was filed in January, 2011, three months before
the first filing over there.
14. Attached hereto as Exhibit B is the petition filed by my
counsel in that court for the production of documents. Attached hereto
as Exhibit C is the response filed by counsel for James R. Hastings,
who presumably has the documents. As can be seen, under various
theories, Hastings and Bank of America are refusing to produce any
documents at all !!! Among other things they are claiming that
Hastings and Bank of America enjoy an attorney-client privilege,
because Hastings was the attorney for Bank of America.
15. This raises the question of conflict of interest. In various
documents, Hastings claims to be the attorney for Mike, Kenneth and
Rachel Goodall, for Frank Thornally and Roy Hoppe and for Bank of
America. Thus, he is claiming to represent all sides in this case. He
has not yet claimed to represent Guide Dogs for the Blind but he told
Frank Thornally and Roy Hoppe in January 2011 that he had received
$4700 from Guide Dogs for the Blind for this case. He was agreeing to
use some of that $4700 to bury Mike Goodall, who had remained unburied
up to that point because of no money to pay for the burial. To this
day, Bank of America, James R. Hastings and Guide Dogs for the Blind
still have refused to pay for a gravestone or other suitable marker
for Mike Goodall, even though they are holding millions of dollars of
Goodall money.
16. We are wondering why Guide Dogs for the Blind paid $4700 to
James R. Hastings more than one year ago. Was it because they have
received the Goodall millions already, without awaiting a decision of
this probate court?
17. Bank of America has been playing games with these courts.
They have been insisting that the case they filed in San Francisco
Probate Court go first, before the case in this court, even though the
case in this court was filed three months earlier. The case in this
court was filed in January 2011. Their counter-case over there was
filed in April 2011. The result of playing games with these courts has
been a series of stipulations, postponements and adjournments, as they
keep demanding that we stipulate to continue the case in Marin so that
their case in San Francisco will go before ours. It is for this reason
that this motion is finally being heard nine months after it was filed
on June 30, 2011.
18. At the hearing in San Francisco Probate Court on March 7,
2012 (last week), they again demanded an immediate decision in their
favor without any fact hearing at all. They also demanded that I be
evicted from the Goodall Mansion where I am serving as the
Administrator of the Goodall Estate. Unfortunately from their point of
view, there was a new judge on the case, unfamiliar with the
situation, and he ordered that I pay fair market rent to be placed in
a blocked account while this case is pending. I pointed out to the
judge that only the Marin Court has jurisdiction over eviction
proceedings, as the house is in Marin. The end result was the San
Francisco Judge continued the case for two months until May 7. This
was a severe setback for Bank of America and Guide Dogs for the Blind,
because they wanted to take over the property right now. This explains
why they filed three pleadings in this court on the following day,
after they received that setback in the San Francisco Probate Court.
They keep asking for two bites of the apple.
WHEREFORE, for all of the reasons set forth above, this court should
order that:
1. The Bank of America must account for all funds received and
spent since the death of Rachel Goodall in 1999 including
administration and attorneys fees.
2. Pending a final hearing and determination, all funds being
held by Bank of America or received by Guide Dogs for the Blind, Inc.
pertaining to these matters shall be deposited with this court until
these issues are resolved.
3. Bank of America, James R. Hastings and Guide Dogs for the
Blind must produce all documents pertaining to these cases.
4. The Demurrer should be denied.
March 15, 2012
Respectfully Submitted,
________________________
Samuel H. Sloan
Administrator with Will Annexed
of Estate of K. Michael Goodall
Verification:
Sam Sloan declares:
I have read the above Sur-Reply declaration in this matter, and I
declare under penalty of perjury under the laws of the State of
California and the contents thereof are true and correct to the best
of my knowledge and belief.
DATED: March 15, 2012
Exhibit A
“Second Amendment to Goodall Trust”
dated January 19, 1999.
Exhibit B
Motion by Counsel for Estate of K. Michael Goodall for the Production
of Documents
Exhibit C
Opposition Filed by Counsel for James R. Hastings refusing to produce
any documents
AFFIDAVIT OF SERVICE
I hereby state that I am not a party, I am over 18 years of age and I
served a copy of this motion and the exhibits attached thereto to the
following:
James R. Hastings
1003 3rd Street
San Rafael, CA 94901
Gary D. Rothstein
Manatt, Phelps & Phillips, LLP
One Embarcadero Center, 30th Floor
San Francisco CA 94111
Alicia A. Adornato
Attorney for Guide Dogs for the Blind
Reed Smith LLP
1999 Harrison Street, 24th Floor
Oakland CA 94612
Don A. Lesser
Attorney for James R. Hastings
1010 B Street
Suite 350
San Rafael CA 94901
Sam Ware
700 Larkspur Landing Circle, #199
Larkspur, CA 94939
Administrator with Will Annexed of
Estate of K. Michael Goodall
461 Peachstone Terrace
San Rafael CA 94903
415-419-5980
415-349-6116
***@gmail.com
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF MARIN
In the Matter of the Estate of
K. Michael Goodall
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
Case No. PR 1100596
SUR-REPLY TO BANK OF AMERICA'S ATTEMPT AT DEMURRER
Hearing Date: March 19, 2012
Time: 8:30 AM
Department: H
Sam Sloan declares:
1. I am the Administrator with Will Annexed of the Estate of K.
Michael Goodall. I have personal knowledge of the matters set forth
herein and, if called upon to testify, could and would competently
testify thereto.
2. In their reply declaration which I just received although
this matter has been pending for months, counsel for Bank of America
states: “Mr. Sloan does not question that Michael Goodall was served
with notification by the trustee.” It goes on to add the words “in
their capacity of settlers of the trust as amended”.
3. However, it does not state “as amended” WHEN. Since Mike
Goodall is dead I do not know what Mike was served with, but I do know
that the operative amendment to the 1990 trust is the 1999 Amendment
to the Trust. That amendment made Mike Goodall the co-trustee, with
his mother. Thus, Mike Goodall was legally the sole surviving Trustees
of the trust until his death on October 5, 2010, at which point the
trust, by its terms, was dissolved. Thus, Bank of America was never
the legal trustee and never had and does not have the legal right to
act as the trustee.
4. A copy of the 1999 Amendment to the Trust is annexed hereto
as Exhibit A. As will be seen, this document was prepared by James R.
Hastings, who acted as notary public in notarizing the signatures of
Mike Goodall and his mother, Rachel A. Goodall. Since Mr. Hastings
prepared and witnessed this document, he cannot be heard to complain
that this document is not valid. Until now, there has never been any
explanation offered by him or by Bank of America as to the grounds on
which Bank of America and James R. Hastings assert that the disputed
1994 trust is the operative document and that the 1999 document should
be ignored. The documents now filed by Bank of America never mention
the 1999 Amendment to the trust.
5. Even without the 1999 Amendment to the Trust, there is newly
discovered evidence in this case because I did not know and Mike
Goodall could not have known that the witness to the August 24, 1994
documents has come forward and stated that she did not sign them. The
witness is absolutely certain of this. Her husband, a retired
Professor of Business Administration at San Francisco State
University, also states that she did not and would not have signed
these documents, as does their daughter, a real estate agent. At the
deposition of James R. Hastings on November 14, 2011, he stated that
the documents were witnessed by his secretary. We therefore assumed
that Nancy Rodgers was the name of his secretary. It was to my great
surprise that Sam Ware discovered that Nancy Rodgers was the lady
across the street and a close friend of Rachel Goodall.
6. Bank of America cherry picks documents from the 1999 case
without indicating the context to the documents to which they were
responding. In the 1999 case, Bank of America was represented by the
same James R. Hastings who claims to represent all sides to these
transactions. In three documents filed in San Francisco Superior Court
on March 21, 2000, James Hastings stated that Mike Goodall was
challenging the trust, by demanding the removal of Bank of America as
Trustee. Hastings stated that because of the “no contest clause”, Mike
Goodall should be evicted from the Goodall Mansion at 461 Peachstone
Terrace, San Rafael, leaving him homeless and without funds, because
Mike Goodall had used his life savings to hire an attorney to
represent him and thus was out of money. It was because of this threat
to dis-inherit him entirely that Mike Goodall responded the way that
he did. There was never any final decision in that case, which is the
same case that Bank of America revived recently.
7. When and if a fact hearing is held here on this issue, we
will prove that Col. Goodall did not and could not have signed the
August 24, 1994 documents in the way that Hastings describes. James
Hastings keeps changing his story as to where Col. Goodall was when he
signed these documents. We can prove that he was in none of those
places. We are now seeking medical records to determine whether Col.
Goodall was conscious or unconscious on that date. He was very ill and
at the point of death. He was at the end of his life. Even were it
true that Col. Goodall was awake and signed the documents, it would
mean that James R. Hastings came to him on his death bed and induced
him to sign documents changing his estate plans so as to disinherit
his only son, Mike, Col. Goodall could not possibly have understood
what he was signing, because even today we cannot figure out what the
document says due to its confused and circular wording, which seems to
have been drafted in such a way as to deliberately confuse the reader.
8. James R. Hastings and Bank of America do not merely refuse to
produce the estate planning documents. They have failed to produce any
documents at all. Not even one scrap of paper has been produced by
them. They refuse to account for the funds. They refuse to tell us how
much money they have or where they got it from. Rachel Goodall died on
June 7, 1999. On November 11, 1999, five months later, they still did
not have any money. Their own documents filed in court in 2000 state
that Bank of America had no estate money, zero, even months after the
death of Rachel Goodall. Thus, we know that any money they got came
well after the deaths of Col. and Rachel Goodall. We also know that
the policy of Bank of America is they do not take a case unless there
is at least a million dollars involved. That plus the fact that they
now have six lawyers working on this case tells us that there is a lot
of money involved in this case, probably more than we could possibly
imagine. We have documents showing that Rachel Goodall had $610,000 in
just one account with USAA Investment Management in 1995. We know that
Bank of America got that money after Rachel Goodall died. How much
more they got they refuse to tell us.
9. When I come to court on March 19, 2012, I will bring with me
two ring binders, a blue ring binder and a green ring binder. These
are Col. Goodall's compilation of documents. If this court will care
to look through these ring binders, it will see the incredible detail
to which Col. Goodall went to prepare his estate plans. I think this
court will agree that it is inconceivable that the person who went to
such great length to prepare his estate plans would on his death bed
decide to throw the whole thing out and entrust it all to a lawyer,
James R. Hastings.
10. I have demanded pursuant to California Government Code
Section 8206 (c), that James Hastings provide to me a photostatic copy
of the line items representing each of the transactions in which he
acted as a Notary Public and notarized the signatures of Kenneth F.
Goodall, Rachel A. Goodall and/or Kenneth Michael Goodall. Mr.
Hastings has responded to this demand but his response is legally
insufficient. Notary Public law provides that when a trust document is
signed there must also be a thumb print taken. There are no thumb
prints in the documents submitted. There is no way to tell whether
there are from the original journal or newly created. Also, James R.
Hastings was legally barred from notarizing these documents as he had
a financial interest in the transaction as he was also the attorney
for Bank of America.
11. After I had for practical purposes won this case in Marin
County Probate Court, Bank of America started a new case by filing on
April 21, 2011 in San Francisco Probate Court a petition seeking
essentially to overturn by collateral attack the decision of the Marin
County Probate Court. They thus have required me to retain counsel to
defend the Estate in that court. This should not have been allowed.
From the first filing in that court, I have consistently objected to
the jurisdiction of the San Francisco Probate Court, at every
opportunity. It is clear that the San Francisco Court has no
jurisdiction. The Goodalls lived their lives and died in Marin County.
All of their property including their house is located in Marin
County. All of the documents in this case were executed in Marin
County. The Goodalls did not like San Francisco and almost never went
there. The San Francisco Superior Court does not have nor had
jurisdiction to decide on the ownership of the house, since the house
is located in Marin County. There is nothing about this case that has
anything to do with San Francisco.
12. Yet, Bank of America keeps insisting that this case be heard
in San Francisco and not in Marin. For what reasons one can only
imagine. I shall be asking the courts to require Bank of America to
reimburse the Goodall Estate for all attorneys fees required to be
paid because of their frivolous filings.
13. Because I have been forced to defend the Goodall Estate in
the San Francisco Probate Court even though that court plainly has no
jurisdiction, there has been motion practice in that court in which my
counsel subpoenaed the documents pertaining to these cases. The
opponents have produced zero documents, none at all. They keep
claiming that the judge in San Francisco limited discovery and within
those limitations there are no discoverable documents. However, I was
in court and the judge there made no such ruling. The Bank of America
was asking the judge not to allow any discovery at all and to make an
immediate ruling. Their request was not granted and ever since that
judge has declined to hear this case. Also, Judge Peter Busch has
stated that he does not want to hear this case any more and is passing
it off to other judges. This case has become a hot potato over there.
It should never have been allowed over there in the first place, since
the case in this court was filed in January, 2011, three months before
the first filing over there.
14. Attached hereto as Exhibit B is the petition filed by my
counsel in that court for the production of documents. Attached hereto
as Exhibit C is the response filed by counsel for James R. Hastings,
who presumably has the documents. As can be seen, under various
theories, Hastings and Bank of America are refusing to produce any
documents at all !!! Among other things they are claiming that
Hastings and Bank of America enjoy an attorney-client privilege,
because Hastings was the attorney for Bank of America.
15. This raises the question of conflict of interest. In various
documents, Hastings claims to be the attorney for Mike, Kenneth and
Rachel Goodall, for Frank Thornally and Roy Hoppe and for Bank of
America. Thus, he is claiming to represent all sides in this case. He
has not yet claimed to represent Guide Dogs for the Blind but he told
Frank Thornally and Roy Hoppe in January 2011 that he had received
$4700 from Guide Dogs for the Blind for this case. He was agreeing to
use some of that $4700 to bury Mike Goodall, who had remained unburied
up to that point because of no money to pay for the burial. To this
day, Bank of America, James R. Hastings and Guide Dogs for the Blind
still have refused to pay for a gravestone or other suitable marker
for Mike Goodall, even though they are holding millions of dollars of
Goodall money.
16. We are wondering why Guide Dogs for the Blind paid $4700 to
James R. Hastings more than one year ago. Was it because they have
received the Goodall millions already, without awaiting a decision of
this probate court?
17. Bank of America has been playing games with these courts.
They have been insisting that the case they filed in San Francisco
Probate Court go first, before the case in this court, even though the
case in this court was filed three months earlier. The case in this
court was filed in January 2011. Their counter-case over there was
filed in April 2011. The result of playing games with these courts has
been a series of stipulations, postponements and adjournments, as they
keep demanding that we stipulate to continue the case in Marin so that
their case in San Francisco will go before ours. It is for this reason
that this motion is finally being heard nine months after it was filed
on June 30, 2011.
18. At the hearing in San Francisco Probate Court on March 7,
2012 (last week), they again demanded an immediate decision in their
favor without any fact hearing at all. They also demanded that I be
evicted from the Goodall Mansion where I am serving as the
Administrator of the Goodall Estate. Unfortunately from their point of
view, there was a new judge on the case, unfamiliar with the
situation, and he ordered that I pay fair market rent to be placed in
a blocked account while this case is pending. I pointed out to the
judge that only the Marin Court has jurisdiction over eviction
proceedings, as the house is in Marin. The end result was the San
Francisco Judge continued the case for two months until May 7. This
was a severe setback for Bank of America and Guide Dogs for the Blind,
because they wanted to take over the property right now. This explains
why they filed three pleadings in this court on the following day,
after they received that setback in the San Francisco Probate Court.
They keep asking for two bites of the apple.
WHEREFORE, for all of the reasons set forth above, this court should
order that:
1. The Bank of America must account for all funds received and
spent since the death of Rachel Goodall in 1999 including
administration and attorneys fees.
2. Pending a final hearing and determination, all funds being
held by Bank of America or received by Guide Dogs for the Blind, Inc.
pertaining to these matters shall be deposited with this court until
these issues are resolved.
3. Bank of America, James R. Hastings and Guide Dogs for the
Blind must produce all documents pertaining to these cases.
4. The Demurrer should be denied.
March 15, 2012
Respectfully Submitted,
________________________
Samuel H. Sloan
Administrator with Will Annexed
of Estate of K. Michael Goodall
Verification:
Sam Sloan declares:
I have read the above Sur-Reply declaration in this matter, and I
declare under penalty of perjury under the laws of the State of
California and the contents thereof are true and correct to the best
of my knowledge and belief.
DATED: March 15, 2012
Exhibit A
“Second Amendment to Goodall Trust”
dated January 19, 1999.
Exhibit B
Motion by Counsel for Estate of K. Michael Goodall for the Production
of Documents
Exhibit C
Opposition Filed by Counsel for James R. Hastings refusing to produce
any documents
AFFIDAVIT OF SERVICE
I hereby state that I am not a party, I am over 18 years of age and I
served a copy of this motion and the exhibits attached thereto to the
following:
James R. Hastings
1003 3rd Street
San Rafael, CA 94901
Gary D. Rothstein
Manatt, Phelps & Phillips, LLP
One Embarcadero Center, 30th Floor
San Francisco CA 94111
Alicia A. Adornato
Attorney for Guide Dogs for the Blind
Reed Smith LLP
1999 Harrison Street, 24th Floor
Oakland CA 94612
Don A. Lesser
Attorney for James R. Hastings
1010 B Street
Suite 350
San Rafael CA 94901
Sam Ware
700 Larkspur Landing Circle, #199
Larkspur, CA 94939