Complaint,Petition: IN THE MATTER OF THE KATHRYN C. QVALE MARITAL TRUST DATED 1-31-2006

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                                FREELAND COOPER & FOREMAN LLP

150 Spear Street, Suite 1800

San Francisco, California 94105

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Stewart H. Foreman (CSB #61149)
Thea B. Eliot (CSB #183481)

FREELAND COOPER & FOREMAN LLP

150 Spear Street, Suite 1800 ELECTRONICALLY

San Francisco, California 94105 FILED

Telephone: (415) 541-0200 Superior Court of California,

Facsimile: (415) 495-4332 County of San Francisco

Email: foreman@freelandlaw.com SEP 08 2014

Email: eliot@freelandlaw.com Clerk of the Court
BY: ELIZABETH FONG

Attorneys for Certain Deputy Clerk

Grandchildren Beneficiaries

Kendel Qvale Duford

Blake Qvale

Connor Qvale

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

In the Matter of the CASE NO.: PTR-13-297016

Kathryn C. Qvale Exempt Marital Trust,| NOTICE OF OBJECTION BY KENDEL,
dated January 31, 2006 BLAKE, AND CONNOR QVALE TO
PETITION TO SUSPEND TRUSTEES
BRUCE QVALE AND LAURA HIURA AND
Miles Jeffrey Qvale, individually and as trustee, OBJECTION TO APPOINTMENT OF A
"TRUST PROTECTOR"

VS.

Bruce H. Qvale, Laura Hiura, and Does 1-10
. Date:

Time: 9:00 a.m.

Dept.: Probate, Room 204

Kendel Qvale Duford ("Kendel"), Blake Qvale ("Blake") and Connor Qvale ("Connor"), three
of the seven grandchildren’ of Kjell Qvale, hereby object to Jeff Qvale's petition to suspend his co-
trustees Bruce Qvale and Laura Hiura. Kendel, Blake and Connor further object to the suggestion by
Chris Qvale's attorney that a "trust protector" be appointed.

The petitions filed by Jeff Qvale in this case seck to directly harm the interests of these three of
Kjell Qvale's grandchildren as beneficiaries of his estate, including by seeking to undo a 2012

transaction between QAG and the marital trusts. The effect of Jeff's challenge, if successful, would be
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NOTICE OF OBJECTION BY KENDEL, BLAKE AND CONNOR QVALE TO PETITION TO SUSPEND TRUSTEES BRUCE
QVALE AND LAURA HIURA AND OBJECTION TO APPOINTMENT OF A “TRUST PROTECTOR"
CASE NO.; PTR-13-297016

{00205823}FREELAND COOPER & FOREMAN LLP

150 Spear Street, Suite 1800
San Francisco, California 94105

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to reduce the ownership by all the grandchildren in Qvale Automotive Group, Inc. and to increase the
estate taxes payable by the estate. Jeff's conduct in this litigation and in his challenge to his father's
estate is thus in direct conflict with the interests of Kjell's grandchildren. In contrast, Bruce and Laura
have acted to defend the estate plan in the interests of Kjell's grandchildren and the other beneficiaries.
To suspend Bruce and Laura as trustees is contrary to the interests of Kjell's beneficiaries, including
his grandchildren.

As Kjell's grandchildren and beneficiaries, Kendel, Blake and Connor also oppose the
appointment of a “trust protector." Bruce, Laura, and Ron Malone have already devoted significant
time and effort in administering this complex estate. The appointment of an additional professional,
such as a "trust protector,” would impose additional duplicative and unnecessary cost and expense on
the estate, which will ultimately reduce the amount available to distribute to Kjell's beneficiaries.

This case should be brought to trial as quickly as possible, so that Jeff Qvale's petitions can be
proven false and dismissed. In the meantime, this Court should take no action to suspend any of the
duties of Bruce Qvale or Laura Hiura, who have acted to defend the trust, the grandchildren
beneficiaries and the other beneficiaries against the numerous false and wasteful petitions brought by

Jeff Qvale, who has sought to undermine the beneficiaries’ interests,

Dated: September 5, 2014 FREELAND COOPER & FOREMAN LLP

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By: KEL. OOD hp PET ne

STEWART H. FOREMAN
Attorneys for Certain
Grandchildren Beneficiaries
Kendel Qvale Duford
Blake Qvale

Connor Qvale

NOTICE OF OBJECTION BY KENDEL, BLAKE ANID CONNOR QVALE TO PETITION TO SUSPEND TRUSTE!
QVALE AND LAURA HIURA AND OBJECTION TO APPOINTMENT OF A "TRUST PROTECTOR
CASE NO.: PTR-13-297016

{00205823}FREELAND COOPER & FOREMAN LLP

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San Francisco, California 94105

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150 Spear Street, Suite 1800

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YERIFICATION

I, Kendel Qvale Duford, have read the foregoing NOTICE OF OBJECTION BY KENDEL,
BLAKE, AND CONNOR QVALE TO PETITION TO SUSPEND TRUSTEES BRUCE QVALE
AND LAURA HIURA AND OBJECTION TO APPOINTMENT OF A "TRUST PROTECTOR," and
know the contents thereof. I am informed and believe that the same is true.

I declare under penalty of perjury under the laws of California that the foregoing is true and

correct. Executed on September 5, 2014, acon How 1U6lo, California

ENDEL QVALE I

VERIFICATION
{00205845}FREELAND COOPER & FOREMAN LLP

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150 Spear Street, Suite 1800
San Francisco, California 94105

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Stewart H. Foreman (CSB #61149)

Thea B. Eliot (CSB #183481)
FREELAND COOPER & FOREMAN LLP
150 Spear Street, Suite 1800

San Francisco, California 94105
Telephone: (415) 541-0200

Facsimile: (415) 495-4332

Email: foreman@freelandlaw.com

Email: eliot@freelandlaw.com

Attorneys for Certain
Grandchildren Beneficiaries
Kendel Qvale Duford

Blake Qvale

Connor Qvale

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA.

COUNTY OF SAN FRANCISCO

in the Matter of the

Kathryn C. Qvale Exempt Marital Trust,

dated January 31, 2006

Miles Jeffrey Qvale, individually and as trustee,

VS.

Bruce H. Qvale, Laura Hiura, and Does 1-10

CASE NO,: PTR-13-297016

PROOF OF SERVICE

PROOF OF SERVICE
{00205835}FREELAND COOPER & FOREMAN LLP

150 Spear Street, Suite 1800
San Francisco, California 94105

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PROOF OF SERVICE

1am employed in the City and County of San Francisco, State of California. I am over the age
of eighteen and not a party to the within action; my business address is 150 Spear Street, Suite 1800,
San Francisco, California 94105.

On September 5, 2014, I served the foregoing document described as follows:

NOTICE OF OBJECTION BY KENDEL, BLAKE, AND CONNOR QVALE TO PETITION
TO SUSPEND TRUSTEES BRUCE QVALE AND LAURA HIURA AND OBJECTION TO
APPOINTMENT OF A "TRUST PROTECTOR"

by placing a true and correct copy thereof enclosed in a sealed envelope addressed to the party(ies) of
record whose name(s) and address(es) appear below:

See Attachment A

_X_ [BY MAIL - CCP § 1013a] I caused such sealed envelope with postage thereon fully
prepaid to be placed in the United States mail at San Francisco, California, for collection and
mailing to the office of addressee(s) on the date shown herein following ordinary business
practice.

_X. [STATE] I declare under penalty of perjury under the laws of the State of California that
the above is true and correct.

[FEDERAL] Service was made under the direction of a member of the bar of this Court who
is admitted to practice and is not a party to this cause.

Executed on September 5, 2014, at San Francisco, California.

beh. ——
Shane K. Dickinson

PROOF OF SERVICE

{00205835}Attachment A

Nancy Bong

23 Kingston Place
Walnut Creek, CA 94596
(adult beneficiary)

Kendel Hailey Qvale
3500 Scott Street

San Francisco, CA 94123
(adult beneficiary)

Norma Hepworth
P.O, Box 871
Hailey, [D 83333
(adult beneficiary)

Roger Hansen
868 East 2830 South
Hagerman, ID 83332

Connor Hammond Qvale
98 Via Poinciana Lane
Boca Raton, FL 33487

Hubert Gely
3532 Sacramento Street, #2
San Francisco, CA 94118

(adult beneficiary) (adult beneficiary) (adult beneficiary)
Shirley Hansen Caroline Paige Qvale Blake Henry Qvale

868 East 2830 South 461 2nd St. #C227 336 E. 18th St, Apt. E-2
Hagerman, [D 83332 San Francisco, CA 94107 New York, NY 10003
{adult beneficiary) (adult beneficiary) (adult beneficiary)

Don Endo Lilian Fredriksson Christopher Kjell Qvale

21000 Glenwood Drive
Castro Valley, CA 94552
(adult beneficiary)

1318 Hale Drive
Concord, CA 94518
(adult beneficiary)

2945 Pacific Ave., Unit 6
San Francisco, CA 94115
(adult beneficiary)

Raymonde Gely

3532 Sacramento Street, #2
San Francisco, CA 94118
(adult beneficiary)

Laura Hiura

901 Van Ness Avenue
San Francisco, CA 94109
(adult beneficiary)

Rita Jelinic

25385 Palomares Road
Castro Valley, CA 94552
{adult beneficiary)

Max Keaton Qvale
147 Lagunitas Road
Ross, CA 94957
(minor beneficiary)

Karen Duarteau

2600 Nicasio Valley Road
Nicasio, CA 94946

(adult beneficiary)

Bruce H. Qvale

13260 Sabel Chase

West Palm Beach, FL 33418
(adult beneficiary)

Edward A. Koplowitz, Esq.
Maclnnis, Donner & Koplowitz
465 California Street, Suite 222
San Francisco, CA 94104

Bruce H. Qvale

13260 Sabel Chase

West Palm Beach, FL 33418
(Co-Family Trustee)

Laura Hiura

901 Van Ness Avenue

San Francisco, CA 94109
(Co-Trustee of the Survivor's
Trust)

Miles Jeffery Qvale

147 Lagunitas Road

Ross, CA 94957

(parent of minor beneficiary,
Max Keaton Qvale)

Miles Jeffery Qvale

147 Lagunitas Road

Ross, CA 94957

(parent of minor beneficiary,
Miles Colin Qvale)

Monica Dell'Osso, Esq.

1901 Harrison Street, 14th Fi.
Oakland, CA 94612-3501
(Guardian Ad Litem — for
Minors Miles Colin Qvale and
Max Keaton Qvale)

£0N2058400}Miles Jeffery Qvale

147 Lagunitas Road

Ross, CA 94957

(Co-Family Trustee and adult
beneficiary)

Ronald Hayes Malone, Esq
909 Mustang Court

Petaluma, CA 94954
(Co-Trustee of the Exempt
and NonExempt Trusts)

Miles Colin Qvale
147 Lagunitas Road
Ross, CA 94957
(minor beneficiary}

Dominic J. Campisi
Andrew Zabronsky
Evans, Latham & Campisi
One Post Street, Suite 600
San Francisco, CA 94104

John W. Keker

Warren A Braunig
Benjamin Berkowitz
Abhishek Bajoria

Keker & Van Nest LLP
633 Battery Street

San Francisco, CA 94111

Peter S. Myers

Matthew R. Mraule

Myers Urbatsch P.C.

625 Market Street, 4th Floor
San Francisco, CA 94105

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