On May 04, 2005 a
Party Discovery
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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l
San Francisco Superior Courts
Information Technology Group
Document Scanning Lead Sheet
Feb-14-2006 7:55 am
Case Number: PTR-05-287341
Filing Date: Feb-09-2006 7:54
Juke Box: 001 Image: 01383299
GENERIC PROBATE PLEADING
IN THE MATTER OF IN RE REVOCABLE LIVING TRUST AGREEMENT OF CHARLES AC
Instructions:
001P01383299
Please place this sheet on top of the document to be scanned.oe rN Aw eh wY NY
RPM Ne Be ee Be ee ee Be
BN RRRBREBR BP GeReWRBDEBDTHAS
Cc C
DAVID J, FRIEDENBERG, ESQ.
SBN 25026
2171 Junipero Serra Blvd., Ste. 620
Daly City, CA 94014
Telephone: (650) 755-6622
Facsimile: (650) 755-4312
San Francisco County Superior Court
Attomey for Respondent
EVA KNOTT
SUPERIOR COURT OF THE STATE OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO
IN RE REVOCABLE LIVING TRUST
AGREEMENT OF CHARLES ACTIS
DATED NOVEMBER 2, 2004, AND
WILL DATED NOVEMBER 2, 2004
Case No. PTR-05-287341
(Related Case No. PES 05-287457)
RESPONDENT’S REPLY TO
OPPOSITION OF PETITIONER TO
MOTION FOR ORDER TO COMPEL
FURTHER ANSWERS TO
CAROL MITCHELL,
)
)
)
)
)
)
)
wa 2
Petitioner, )
) DOCUMENTS AND RECORDS, FOR
v. ) ATTORNEYS FEES, COSTS AND
) SANCTIONS
EVA KNOTT, Trustee and Beneficiary )
under the REVOCABLE LIVING TRUST)
AGREEMENT OF CHARLES ACTIS )
DATED 11/2/04, NICHOLAS FERRERO, )
a minor and a will and trust beneficiary )
d
)
)
)
)
and NATALIE FERRERO, a minor and a
will and trust beneficiary,
Date: February 17, 2006
Time: 9:00 a.m.
Dept: 612
Respondents.
Petitioner refuses to provide a good faith response to discovery requests. As set forth in
the moving papers herein, CCP§2030.070 and 2030.050 provide for supplemental discovery
to illicit later acquired information and/or documents. Petitioner has provided no applicable
authority or good cause why she should not comply with the Supplemental Request sent
her on November 3, 2005.
WwW
1
REPLY TO OPPOSITION OF PETITIONER TO MOTION TO COMPEL FURTHER ANSWERS
INTERROGATORIES, PRODUCTION OFoc Um NH HW BY DH
Responding party’s claim that moving party failed to meet and confer is also specious and
contrary to the facts herein, as set forth in the moving papers, including the Declaration of
David J. Friedenberg, Esq. and correspondence attached thereto.
Dated: February _¢7_, 2006 Aa)
NBERG, ESQ,
Attorney for Respondent EVA
2
REPLY TO OPPOSITION OF PETITIONER TO MOTION TO COMPEL FURTHER ANSWERS
Document Filed Date
February 09, 2006
Case Filing Date
May 04, 2005
Category
TRUST (PETITION TO DETERMINE VALIDITY OF PURPORTED WILL)
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l San Francisco Superior Courts Information Technology Group Document Scanning Lead Sheet Feb-14-2006 7:55 am Case Number: PTR-05-287341 Filing Date: Feb-09-2006 7:54 Juke Box: 001 Image: 01383299 GENERIC PROBATE PLEADING IN THE MATTER OF IN RE REVOCABLE LIVING TRUST AGREEMENT OF CHARLES AC Instructions: 001P01383299 Please place this sheet on top of the document to be scanned.oe rN Aw eh wY NY RPM Ne Be ee Be ee ee Be BN RRRBREBR BP GeReWRBDEBDTHAS Cc C DAVID J, FRIEDENBERG, ESQ. SBN 25026 2171 Junipero Serra Blvd., Ste. 620 Daly City, CA 94014 Telephone: (650) 755-6622 Facsimile: (650) 755-4312 San Francisco County Superior Court Attomey for Respondent EVA KNOTT SUPERIOR COURT OF THE STATE OF CALIFORNIA CITY AND COUNTY OF SAN FRANCISCO IN RE REVOCABLE LIVING TRUST AGREEMENT OF CHARLES ACTIS DATED NOVEMBER 2, 2004, AND WILL DATED NOVEMBER 2, 2004 Case No. PTR-05-287341 (Related Case No. PES 05-287457) RESPONDENT’S REPLY TO OPPOSITION OF PETITIONER TO MOTION FOR ORDER TO COMPEL FURTHER ANSWERS TO CAROL MITCHELL, ) ) ) ) ) ) ) wa 2 Petitioner, ) ) DOCUMENTS AND RECORDS, FOR v. ) ATTORNEYS FEES, COSTS AND ) SANCTIONS EVA KNOTT, Trustee and Beneficiary ) under the REVOCABLE LIVING TRUST) AGREEMENT OF CHARLES ACTIS ) DATED 11/2/04, NICHOLAS FERRERO, ) a minor and a will and trust beneficiary ) d ) ) ) ) and NATALIE FERRERO, a minor and a will and trust beneficiary, Date: February 17, 2006 Time: 9:00 a.m. Dept: 612 Respondents. Petitioner refuses to provide a good faith response to discovery requests. As set forth in the moving papers herein, CCP§2030.070 and 2030.050 provide for supplemental discovery to illicit later acquired information and/or documents. Petitioner has provided no applicable authority or good cause why she should not comply with the Supplemental Request sent her on November 3, 2005. WwW 1 REPLY TO OPPOSITION OF PETITIONER TO MOTION TO COMPEL FURTHER ANSWERS INTERROGATORIES, PRODUCTION OFoc Um NH HW BY DH Responding party’s claim that moving party failed to meet and confer is also specious and contrary to the facts herein, as set forth in the moving papers, including the Declaration of David J. Friedenberg, Esq. and correspondence attached thereto. Dated: February _¢7_, 2006 Aa) NBERG, ESQ, Attorney for Respondent EVA 2 REPLY TO OPPOSITION OF PETITIONER TO MOTION TO COMPEL FURTHER ANSWERS