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  • IN RE: MARILYN SILVERMAN-BALLONOFF REVOCABLE TRUST SUBSTITUTED JUDGMENT/ SPECIAL NEEDS TRUST PETITION document preview
  • IN RE: MARILYN SILVERMAN-BALLONOFF REVOCABLE TRUST SUBSTITUTED JUDGMENT/ SPECIAL NEEDS TRUST PETITION document preview
  • IN RE: MARILYN SILVERMAN-BALLONOFF REVOCABLE TRUST SUBSTITUTED JUDGMENT/ SPECIAL NEEDS TRUST PETITION document preview
  • IN RE: MARILYN SILVERMAN-BALLONOFF REVOCABLE TRUST SUBSTITUTED JUDGMENT/ SPECIAL NEEDS TRUST PETITION document preview
						
                                

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oOo mPmnN DN F&F WN NbN YY NN NY NY Be Be Be Be eB ee eB ek ont nN BwKwNH Fe SO we ANI AA RYH NH BO Selene Ballonoff 2230 Dwight Way, Apt.308 Berkeley, CA 94704 EF I L RR D Telephone: 510-549-3709 Pro Per ‘San Francisco County Sunerior Court MAY 15 2019 CLERK Gr tit COURT oe Clete dito Deputy Clork SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO INRE THE CASE NO. PTR 17301171 MARILYN SILVERMAN-BALLONOFF) SELENE BALLONOFF'S NOTICE REVOCABLE TRUST AND MOTION TO COMPEL FURTHER RESPONSES TO RELATED MATTER: PCN-12-295409 OF DOCUMENT Sarr owe CONSERVATORSHIP OF MARILYN 3 SILVERMAN-BALLONOFE REQUEST FOR SANCTIONS, » Bye Date: JUN 12 2019 per* Time: 2:39 PM.- Place: pep7, 204 The Honorable: O41 kK. STEWART TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD, PLEASE TAKE NOTICE THAT oN PO“L 12,2019 gp A: Zp m. of as soon after as this matter can be heard, Selene Ballonoff will move this court for an order compelling further responses to Request for Production of Documents Set One (Trust). The motion shall be based on the points and authorities stated herein and in the Separate Statement of Facts as well as evidence and argument in the Court's file on this matter and other matters of Mr. Lucas. Selene Ballonoff served Request for Production of Documents Set One on Mr. Lucas on February 13, 2019. Mr. Lucas responded with objections on March 20, 2019 and produced documents on April 12, 2019. Forty five days after March 20, 2019 is Saturday May 4, 2019. Selene Ballonoffs Motion to Compe! Further Responses to Trust Document Production Set One 1 of 2ow rnd nn pf WN | 10 May 6, 2019 is the first court day after holiday Saturday May 4, 2019. The requested discovery is required to adjudicate the Trustee's First Account and to evaluate whether his requested fees are “just and reasonable” as detailed in Selene Ballonoff's Separate Statement of Facts. The objections were made in bad faith and justify sanctions. WHEREFORE MOVING PARTY PRAYS FOR AN ORDER COMPELLING Mr. Lucas to produce all requested documents without objection and to sign under penalty of perjury that all responsive documents have been produced within 5 days and to pay sanctions according to proof. I certify under penalty of perjury the foregoing is true and correct, except for those matters stated on information and belief and as to those matters I believe them to be true. Qa Signed: Arlene ate: May 6, 2019 at Berkeley, California Selene Ballonoffs Motion to Compel Further Responses to Trust Document Production Set One 2 of 2