YGLESIAS, MANUEL J., Jr vs KELLER, DORIA A.

maladministration of a trust, failure to make a proper accounting, removal of trustee, surcharge of

trustee, and failure to make an inventory of trust assets.

2) Upon information and belief, prior to the appointment of Ms. Keller as Trustee, the

Trustee’s nephew and son of beneficiary Michael Yglesias, Michael Yglesias, Jr. accessed Trust

assets for his own personal use without the permission of either co-Trustee.

3) Ms. Keller became Co-Trustee of the Yglesias Revocable Trust, long before

Manual Yglesias, Sr., the Surviving Spouse and Grantor, died.

4) Ms. Keller was made aware of theft that occurred immediately prior to accepting

her appointment as Co-Trustee in or about 2019.

12/5/2023 1:27 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1

5) Throughout her appointment as Co-Trustee and then sole successor Trustee, Ms.

Keller has failed to attempt to retrieve the assets stolen from the Trust.

6) Ms. Keller has also refused to provide a sufficient accounting or inventory with

supporting documentation to the beneficiary, Manuel Yglesias, Jr. who has requested the same on

numerous occasions.

Causes of Action

COUNT I – ACCOUNTING

COUNT II – BREACH OF FIDUCIARY DUTY

COUNT III- NEGLIGENCE

COUNT IV – REMOVAL AND SURCHARGE OF TRUSTEE

COUNT IV- BREACH OF TRUST