On May 04, 2005 a
Proof of Service
was filed
involving a dispute between
Ccsf Adult Protective Services,
Dolch, Debra J.,
Ferrero, Jr., Marco,
Ferrero, Natalie,
Ferrero, Nicholas,
Knott, Eva,
Mitchell, Carol,
and
Knott, Eva,
for TRUST (PETITION TO DETERMINE VALIDITY OF PURPORTED WILL)
in the District Court of San Francisco County.
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San Francisco Superior Courts
Information Technology Group
Document Scanning Lead Sheet
Mar-13-2007 2:55 pm
Case Number: PTR-05-287341
Filing Date: Mar-12-2007 2:55
Juke Box: 001 Image: 01707354
DECLARATION
RE REVOCABLE LIVING TRUST AGREEMENT OF CHARLES ACTIS/CONSOLIDATED WI
001P01707354
Instructions:
Please place this sheet on top of the document to be scanned.co OPN DN RB YW NB =
8 = 5
13
€
DENNIS J. HERRERA, State Bar #139669.
City Attorney
ALFETA VAN RUNKLE, state Bar #124563
TERENCE J. HOWZELL, State Bar #140822
Deputy City Attorneys
Fox Plaza
1390 Market Strect, 10" Floor, Suite 1008.
San Francisco, California 94102-5408
Telephone: (415) 554-3960
Facsimile: (415) 557-6747
EB Mm
hs I
San Francisco Count ‘Superlor Court
Attomeys for the City and County of San Francisco,
Adult Protective Services
SUPERIOR COURT OF THE STATE OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO
IN THE REVOCABLE LIVING TRUST
AGREEMENT AND WILL OF
CHARLES ACTIS
CAROL MITCHELL,
Petitioner,
Y
EVA KNOTT, Tnustee and Beneficiary
under the REVOCABLE LIVING TRUST
AGREEMENT OF CHARLES ACTIS,
and NICHOLAS and NATALIE
FERRERO, minors and beneficiaries,
Case No. PTR-05-287341
DECLARATION OF CARRIE WONG IN
SUPPORT OF SAN FRANCISCO
ADULT PROTECTIVE SERVICES’
MOTION TO QUASH DEPOSITION
NOTICES AND FOR PROTECTIVE
ORDER
Hearing Date: March 21, 2007
Time: 10:30 a.m.
Place: Dept. 612
Commissioner: Everett A. Hewlett, Jr.
Respondents,
I, CARRIE WONG, declare:
1. Tam currently employed by the San Francisco Adult Protective Services Agency
as a Protective Services Worker. [have been employed in this position for approximately 8
years. In this capacity, I am responsible for investigating reports of potential elder and
dependent adult abuse that come into the APS hotline; for coordinating services for abused or
neglected elders and dependent adults, and for ensuring that the subjects of these investigations
are safe.
DECL. OF CARRIE WONG IN SUPP OF MOT. TO
QUASH/PROTECTIVE ORDER; # PTR-05-287341
1 NAHEALTIRTHOWZELL APS actrmtg oe,
ee TUT Tt HOLE SSATIGY OUEDSIPENE SueHe
-
uf
0 Pm Se NH & YN
, ~ “ae om
Noy ww Bw NN YB wee
NN NS YW NH &| FSFGae AABDeEBH =A Ss
28
MAR=12-2887 “ 88:16 . - / “41s 557 :
5377 P.Qt
eps © eC
4 Lo ¢ a tyr, .
: ‘2+ se have persoval Jmowledge of the facts set forth herein and if called to testify
could do so ocompetent. pt rt
3. ~ On or about November 18, 2003, APS received a referral regarding Charles Actis.
4a 4 maintained an open case file regarding Mr. Actis from approximately November
= 44s
18, 2003 until his death on Apail 26, 2005. As’ a result, IT conducted an investigation and
interviewed, individuals regarding allegations i in this. cast.
50 * During my investigation, APS retained the professional services of Dr, abraham
Nievod to conduct an evaluation’ lof Mr. Actis. ‘APS yelied on Dr. Nievod's report and that report
and any other related documents became a Part of the APS file in this case,
6 ‘ During my investigation, 1 contacted Kaiser Hospital on February 25, 2004, and
arranged for Kaiser Hospital to conduct an evaluation for APS of Mr. Actis under my direction.
Kaiser Hoépial selected Dr. Vella to conduct the evaluation. As part of the APS investigation
and 0 aid Dr. Veilai in his evaluation, I provided Dr. Vella confidential information and
documents. Dr. Vella’ ‘S report and any other related documents became’a part of the APS file in
a :
this case. . : ,
hs The information that! received regarding the allegations i in the referral and any
other information that 1 obtained during the course of: my investigation in this case was'acquired
in confi dence. The information i in the case Bile: is confidential under state law. I have not
disclosed any. information contained in the case fle to any member of the public not authorized
by Jaw to review such information, ‘
1 declare under penalty of pesjury under the laws of the State of California that the
foregoing i is tree and correct and that this declaration was executed on March 12, 2007 i in San
Francisco, California. .
oo E WONG
aoe : Protective Services Wor . 514 vet
DECL OF CARRIE WONG IN supP OF MOT. TO . 2 . NEAL TIT OTe Lemme dot
QUASH/PROTECTIVE ORDER; # PTR-C5-282361 . s
: - *
. TOTAL P.O1
Document Filed Date
March 12, 2007
Case Filing Date
May 04, 2005
Category
TRUST (PETITION TO DETERMINE VALIDITY OF PURPORTED WILL)
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San Francisco Superior Courts Information Technology Group Document Scanning Lead Sheet Mar-13-2007 2:55 pm Case Number: PTR-05-287341 Filing Date: Mar-12-2007 2:55 Juke Box: 001 Image: 01707354 DECLARATION RE REVOCABLE LIVING TRUST AGREEMENT OF CHARLES ACTIS/CONSOLIDATED WI 001P01707354 Instructions: Please place this sheet on top of the document to be scanned.co OPN DN RB YW NB = 8 = 5 13 € DENNIS J. HERRERA, State Bar #139669. City Attorney ALFETA VAN RUNKLE, state Bar #124563 TERENCE J. HOWZELL, State Bar #140822 Deputy City Attorneys Fox Plaza 1390 Market Strect, 10" Floor, Suite 1008. San Francisco, California 94102-5408 Telephone: (415) 554-3960 Facsimile: (415) 557-6747 EB Mm hs I San Francisco Count ‘Superlor Court Attomeys for the City and County of San Francisco, Adult Protective Services SUPERIOR COURT OF THE STATE OF CALIFORNIA CITY AND COUNTY OF SAN FRANCISCO IN THE REVOCABLE LIVING TRUST AGREEMENT AND WILL OF CHARLES ACTIS CAROL MITCHELL, Petitioner, Y EVA KNOTT, Tnustee and Beneficiary under the REVOCABLE LIVING TRUST AGREEMENT OF CHARLES ACTIS, and NICHOLAS and NATALIE FERRERO, minors and beneficiaries, Case No. PTR-05-287341 DECLARATION OF CARRIE WONG IN SUPPORT OF SAN FRANCISCO ADULT PROTECTIVE SERVICES’ MOTION TO QUASH DEPOSITION NOTICES AND FOR PROTECTIVE ORDER Hearing Date: March 21, 2007 Time: 10:30 a.m. Place: Dept. 612 Commissioner: Everett A. Hewlett, Jr. Respondents, I, CARRIE WONG, declare: 1. Tam currently employed by the San Francisco Adult Protective Services Agency as a Protective Services Worker. [have been employed in this position for approximately 8 years. In this capacity, I am responsible for investigating reports of potential elder and dependent adult abuse that come into the APS hotline; for coordinating services for abused or neglected elders and dependent adults, and for ensuring that the subjects of these investigations are safe. DECL. OF CARRIE WONG IN SUPP OF MOT. TO QUASH/PROTECTIVE ORDER; # PTR-05-287341 1 NAHEALTIRTHOWZELL APS actrmtg oe, ee TUT Tt HOLE SSATIGY OUEDSIPENE SueHe - uf 0 Pm Se NH & YN , ~ “ae om Noy ww Bw NN YB wee NN NS YW NH &| FSFGae AABDeEBH =A Ss 28 MAR=12-2887 “ 88:16 . - / “41s 557 : 5377 P.Qt eps © eC 4 Lo ¢ a tyr, . : ‘2+ se have persoval Jmowledge of the facts set forth herein and if called to testify could do so ocompetent. pt rt 3. ~ On or about November 18, 2003, APS received a referral regarding Charles Actis. 4a 4 maintained an open case file regarding Mr. Actis from approximately November = 44s 18, 2003 until his death on Apail 26, 2005. As’ a result, IT conducted an investigation and interviewed, individuals regarding allegations i in this. cast. 50 * During my investigation, APS retained the professional services of Dr, abraham Nievod to conduct an evaluation’ lof Mr. Actis. ‘APS yelied on Dr. Nievod's report and that report and any other related documents became a Part of the APS file in this case, 6 ‘ During my investigation, 1 contacted Kaiser Hospital on February 25, 2004, and arranged for Kaiser Hospital to conduct an evaluation for APS of Mr. Actis under my direction. Kaiser Hoépial selected Dr. Vella to conduct the evaluation. As part of the APS investigation and 0 aid Dr. Veilai in his evaluation, I provided Dr. Vella confidential information and documents. Dr. Vella’ ‘S report and any other related documents became’a part of the APS file in a : this case. . : , hs The information that! received regarding the allegations i in the referral and any other information that 1 obtained during the course of: my investigation in this case was'acquired in confi dence. The information i in the case Bile: is confidential under state law. I have not disclosed any. information contained in the case fle to any member of the public not authorized by Jaw to review such information, ‘ 1 declare under penalty of pesjury under the laws of the State of California that the foregoing i is tree and correct and that this declaration was executed on March 12, 2007 i in San Francisco, California. . oo E WONG aoe : Protective Services Wor . 514 vet DECL OF CARRIE WONG IN supP OF MOT. TO . 2 . NEAL TIT OTe Lemme dot QUASH/PROTECTIVE ORDER; # PTR-C5-282361 . s : - * . TOTAL P.O1