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$50500.01
KEKER & VAN NEST LLP
JOHN W. KEKER - # 49092
jkeker@kvn.com
WARREN A. BRAUNIG - # 243884
whraunig@kvn.com
BENJAMIN BERKOWITZ - # 244441
bberkowitz@kvn.com
ABHISHEK BAJORIA - # 255294
abajoria@kvn.com
633 Battery Street
San Francisco, CA 94111-1809
Telephone: 415 391 5400
Facsimile: 415 397 7188
MYERS URBATSCH P.C,
PETER S. MYERS - # 115113
psmyers@myersurbatsch.com
MATTHEW R. MRAULE - # 263433
mmraule@myersurbatsch.com
625 Market Street, 4th Floor
San Francisco, California 94105
Phone: (415) 896-1500
Fax: (415) 979-0761
Attorneys for Petitioners and Respondents
BRUCE H. QVALE, FAMILY TRUSTEE AND
RESPONDENT LAURA HIURA
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
JUL 29 2014
Clerk of the Court
BY: SHIRLEY WU
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE 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
EXHIBITS 37-41 TO THE
DECLARATION OF JORDAN ROSE
Date: August 4, 2014
Time: 10:30 a.m.
Dept.: Probate, Room 204
EXHIBITS 37-41 TO THE DECLARATION OF JORDAN ROSE
Case No, PTR-13-297016EXHIBIT 37KEKER & VAN N ESTu con Fanecer ca 94111-1809
415 391 5400
kyn.com
Karen J. Bringola
(415) 676-2263
kbringola@kvn.com
June 24, 2014
VIA FEDERAL EXPRESS
Dominic J. Campisi Ronald Hayes Malone
Evans, Latham & Campisi 909 Mustang Court
One Post Street, 6th Floor Petaluma, CA 94954
San Francisco, CA 94104
Re: Jnre Qvale Estate, Case Nos. P'TR-13-297016, PTR-13-297017, PTR-13-297143
Dear Dominic and Ronald:
Enclosed please find a DVD containing copies of the Katherine C. Qvale Exempt Marital Trust
and Katherine C. Qvale NonExempt Martial Trust materials provided by the Manatt firm for
inspection on June 10, 2014. These documents have been marked Confidential and bates
stamped QTRUST00000001-QTRUST00037146. We are providing the documents to you in a
Concordance data base with tiff images and OCR text files.
Please let me know if you have any issues with the DVD.
Regards,
Karen J. Bringola
Senior Paralegal
Enclosure
83749501KEKER &. VAN NESTu>
June 24, 2014
VIA FEDERAL EXPRESS
Dominic J. Campisi
Evans, Latham & Campisi
One Post Street, 6th Floor
San Francisco, CA 94104
633 Battery Street
San Francisco, CA 94111-1809
415 391 5400
kya.com
Karen J. Bringola
(415) 676-2263
kbringola@kvn.com
Ronaid Hayes Malone
909 Mustang Court
Petaluma, CA 94954
Re: Inve Qvale Estate, Case Nos. PTR-13-297016, PTR-13-297017, PTR-13-297143
Dear Dominic and Ronald:
Enclosed please find a DVD containing copies of the Katherine C. Qvale Exempt Marital Trust
and Katherine C. Qvale NonExempt Martial Trust materials provided by the Manatt firm for
inspection on June 10, 2014. These documents have been marked Confidential and bates
stamped QTRUST00000001-QTRUST00037146. We are providing the documents to you ina
Concordance data base with tiff images and OCR text files.
Please let me know if you have any issues with the DVD.
Regards,
L4
Aivbaw
Karen J. Bringola
Senior Paralegal
Enclosure
837495.01EXHIBIT 38KEKER & VAN NESTur Sen Frncbc, CA 94111-1809
415 397 5400
kyn.com
Raina Magat
(415) 773-6692
mmagat@kva.com
June 30, 2014
VIA COURIER & FEDERAL EXPRESS
Dominic J. Campisi Ronald Hayes Malone
Evans, Latham & Campisi 909 Mustang Court
One Post Street, 6th Floor Petaluma, CA 94954
San Francisco, CA 94104
Re: Inre Qvale Estate, Case Nos, PTR-13-297016, PTR-13-297017, PTR-13-297143
Dear Counsel:
Enclosed please find a DVD containing copies of the Kjell H. Qvale Survivor’s Trust materials
provided by the Manatt firm for inspection on June 24, 2014. These documents have been
matked Confidential and bates stamped QTRUST00037147-QTRUST00065118. We are
providing the documents to you in a Concordance database with TIFF images and OCR text
files.
Please let me know if you have any issues with the DVD.
Regards,
ae
Raina Magat
Paralegal
Enclosure
ce: Peter Muhs
George Montgomery
838238EXHIBIT 39Karen Bringola
From: Lee, Barry
Sent: Wednesday, July 16, 2014 3:52 PM
To: Ron@circleoakequine.com
Ce: Lee, Barry; Cerruti, Veronica; Hofbauer, Claire Fox; Warren Braunig; Ben Berkowitz; Peter
S. Myers (psmyers@myersurbatsch.com) (psmyers@myersurbatsch.com);
pmuhs@cwclaw.com; Dominic J. Campisi (DCampisi@elc-law.com)
Subject: FW: Qvale - Original Client Billing Files
Ron--You were inadvertently not copied on email below. Not sure if you want to review hard cop. Regards, Barry
Barry Lee
Partner
Manatt, Phelps & Phillips, LLP
One Embarcadero Canter
30th Floor
San Francisco, CA 94114
D (415) 204-7450 F (415) 294-7519
BWLee@manatt.com
pinnati.cam
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous esnai messages attached fo it, may contain confidential information that is
jegally privileged. {f you are set the intended recipiant, or a person respansible for delivering it te th nded recipient, you are hereby notified thal any disclosure, copying,
distribution or use of any of the information contained in or aftached fo this massage is STRICTLY PROHIBITED. If you have received this transrnigsion in error, please
ely notily us by reply email and destroy the original transmission and ils attachments without reading them or saving thentto isk, Thank you,
From: Marquez, Demetrio
Sent: Wednesday, July 16, 2014 3:47 PM
To: jschneli@elc-law.com; DCampisi@elc-law.com
Cc: Lee, Barry; Warren Braunig (WBraunig@kvn.com); Hofbauer, Claire Fox; abajoria@kvn.com; Karen Bringola
(KBringola@KVN.com)
Subject: Qvale - Original Client Billing Files
Hi Jody and Mr. Campisi,
Please be advised that 8 boxes of original client billing files from Laura will be available for
your inspection starting this Monday, July 21 at 10:00 am in our office. Please confirm if
this date and time works for you.
These files have been scanned and Keker is producing them separately to you in electronic
format (QTRUST00065119 - QTRUST00093251) .
Thank you,
Demetrio
Demetrio MarquezParalegal
Manat, Phelps & Phillips, LLP
One Embarcadero Centar
30th Floor
San Francisco. CA 94411
D (415) 201-7557 F (415) 291-7659
DMarquez@manat.com
manaticon
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages aflached to it, may sontain confidential information tat is
legally privileged. if you are not the intended recipient, or a person responsilsie for delivering it to the intended recipient, you are hereby notified that sny disclosure, copying.
disinbutior of use of ary of the information contained in or attached to this message ig STRICTLY PROHIBITED. if you have received this tranemission in err, please
immediately nosfy us by reply eriall and destroy the original transmission arid tts atlachments without reading shen or saving them to disk. Thanks youEXHIBIT 40Karen Bringola
From: Lee, Barry [mailto:BWLee@manatt.com
Sent: Tuesday, July 01, 2014 11:03 AM
To: Ron@circleoakequine.com; Bruce Qvale (bqvale@qmmanagementine.com); lhiura@bmed.com;
4eff@qvalemanagement.com'
Cc: Lee, Barry; Cerruti, Veronica; Warren Braunig; Ben Berkowitz; Naznin Challa (NChalla@elc-law.com); Andrew
Zabronsky (AZabronsky@elc-law.com); George F. Montgomery (george@fomlaw.com); Dominic J. Campisi
(BCampisi@elc-law.com); pmuhs@cwclaw.com
Subject: FW: Qvale Marital and Survivor's Trust - Availability of Additional Records
Ali-We are in receipt of your various ernails requesting additional information beyond the 20 boxes of trust
administration documents we have already made available over the last few weeks. At the outset, neither of Mr.
Campisi nor Mr. Muhs included me on the last few emails; to expedite matters please include me on all communications
going forward.
We are diligently working to identify, callect and produce additional materials to you. However, we need to go about
this in a more organized way, and with agreement on what exactly it is you are seeking, so that we are not constantly
chasing the next request. | propose that each trustee (Jeff and Ron) provide to us, in writing, in a numbered list, the
items you believe we have not produced and to which you helleve you are entitled. State them as simply and clearly as
possible, without leveling incorrect accusations of malfeasance in every request. Such a list will give us the opportunity
to review each specific request, seek clarification, determine whether we agree that the request is proper, and, if so,
collect them and make them available to you. {f you want to prioritize them, please do so. Within a couple of days of
receiving these requests, we should have a telephone conference that will allow us to discuss any disagreements or
confusion we might have. We will then make the documents available on a rolling basis, as we have been doing so
far. And we will be able to tell you specifically “Requests No. 1-17 are provided. Nos. 18-25 are still in
progress. Etc.” Receiving daily, overlapping requests (sometimes from multiple lawyers on behalf of the sare trustee)
is distracting us from actually getting you documents in a timely manner. To get this approach started, immediately
below is the status of certain of the materials that some or all of you have requested. We have taken the liberty of
numbering these as Request Nos. 1-9, which is how they should be referenced in future emalis/correspondence. Thus:
1. Regarding your question whether any additional income statements or balance sheets exist for 2013/2014, the
available records far the 2013/2014 transactions were provided in the prior document productions and/or such
records are with BPM to assist them in the preparation of the incorne tax returns. No additional income
statements or balance sheets were prepared for this period of time.
2. The source information used in preparing the draft estate tax return will be made available to all parties for their
review with the draft return. We expect to circulate the draft return today or tomorrow.
3. Written communications between Steefel/Manatt and Kathryn and Kjell Qvale regarding estate planning
are being gathered, reviewed, and duplicated. if we are to produce these materials without a Petition for
Instructions, we will need each of the Trustees and their counsel to agree in writing that this production dees
not constitute a waiver of any applicable privileges or protections, including but not limited ta the
attorney/client privilege and the attorney work product protection. These communications are being turned
over to the co-trustees at their request as trust administration materials. We are also aware of the limitations
imposed by Section 19.11 of the 2002 Trust Agreement and want to ensure that all Trustees (and their counsel}
agree that turning over these communications is not a violation of Section 19.11 and will not constitute any sort
of waiver of the protections codified by Kjell & Kathryn in Section 19.11, including the absolute protection for
attorney work product. An email to everyone on this email confirming agreement will be sufficient.
14, Additional materials relating to the funding of the sub-trusts were located late last week and will be made
available for review.
5. We will search our files for information on the split dollar insurance trust.
6. Arun of the receipts and disbursements for the various sub-trusts for the period Nov. 2013-May 2014 will be
forwarded today. The materials for the pre-Nov. 2013 period were previously made available (as was the Nov. &
Dec. 2013 information}.
7. Additional correspondence between Manatt and Dr. Smith was located late last week and will be made available
for review.
8. Conflict waivers have already been produced. Some conflict waivers are contained in the redemption
agreements, which were produced some time aga.
9. Steefel/Manatt billing statements are being reviewed for relevance and will be praduced to the extent they
address estate planning work done for either Kathryn or Kjell.
We appreciate your willingness to work with us, so that we can get you what you need as co-trustees more quickly and
smoothly. And, Dominic, for everyone's sake, please turn down the rhetoric. We are trying to work with you; this is an
administrative process of gathering and reviewing volurninous materials and then distributing them in searchable format
for all interested parties, while protecting any applicable privileges. Rhetorical accusations of malfeasance serve only ta
create hostility among the co-trustees and their counsel, resulting in a more difficult and costly administration. Thanks.
Barty Lee
Partner
Manat, Phelps & Phillips, IAP
One Embarcadero Center
30th Floor
San Francisco, CA 94111
D (415) 201-7450 F (415) 297-7518
BWLee@manatt.com
manati.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages atlached fo it, may contain confidential information that is
iegally privileged. ff you are not the intended recipient, or a person responsible for delivering it te the intended recipient, you ere hereby notified that any disclosure, capying,
Preview
$50500.01 KEKER & VAN NEST LLP JOHN W. KEKER - # 49092 jkeker@kvn.com WARREN A. BRAUNIG - # 243884 whraunig@kvn.com BENJAMIN BERKOWITZ - # 244441 bberkowitz@kvn.com ABHISHEK BAJORIA - # 255294 abajoria@kvn.com 633 Battery Street San Francisco, CA 94111-1809 Telephone: 415 391 5400 Facsimile: 415 397 7188 MYERS URBATSCH P.C, PETER S. MYERS - # 115113 psmyers@myersurbatsch.com MATTHEW R. MRAULE - # 263433 mmraule@myersurbatsch.com 625 Market Street, 4th Floor San Francisco, California 94105 Phone: (415) 896-1500 Fax: (415) 979-0761 Attorneys for Petitioners and Respondents BRUCE H. QVALE, FAMILY TRUSTEE AND RESPONDENT LAURA HIURA ELECTRONICALLY FILED Superior Court of California, County of San Francisco JUL 29 2014 Clerk of the Court BY: SHIRLEY WU Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE 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 EXHIBITS 37-41 TO THE DECLARATION OF JORDAN ROSE Date: August 4, 2014 Time: 10:30 a.m. Dept.: Probate, Room 204 EXHIBITS 37-41 TO THE DECLARATION OF JORDAN ROSE Case No, PTR-13-297016EXHIBIT 37KEKER & VAN N ESTu con Fanecer ca 94111-1809 415 391 5400 kyn.com Karen J. Bringola (415) 676-2263 kbringola@kvn.com June 24, 2014 VIA FEDERAL EXPRESS Dominic J. Campisi Ronald Hayes Malone Evans, Latham & Campisi 909 Mustang Court One Post Street, 6th Floor Petaluma, CA 94954 San Francisco, CA 94104 Re: Jnre Qvale Estate, Case Nos. P'TR-13-297016, PTR-13-297017, PTR-13-297143 Dear Dominic and Ronald: Enclosed please find a DVD containing copies of the Katherine C. Qvale Exempt Marital Trust and Katherine C. Qvale NonExempt Martial Trust materials provided by the Manatt firm for inspection on June 10, 2014. These documents have been marked Confidential and bates stamped QTRUST00000001-QTRUST00037146. We are providing the documents to you in a Concordance data base with tiff images and OCR text files. Please let me know if you have any issues with the DVD. Regards, Karen J. Bringola Senior Paralegal Enclosure 83749501KEKER &. VAN NESTu> June 24, 2014 VIA FEDERAL EXPRESS Dominic J. Campisi Evans, Latham & Campisi One Post Street, 6th Floor San Francisco, CA 94104 633 Battery Street San Francisco, CA 94111-1809 415 391 5400 kya.com Karen J. Bringola (415) 676-2263 kbringola@kvn.com Ronaid Hayes Malone 909 Mustang Court Petaluma, CA 94954 Re: Inve Qvale Estate, Case Nos. PTR-13-297016, PTR-13-297017, PTR-13-297143 Dear Dominic and Ronald: Enclosed please find a DVD containing copies of the Katherine C. Qvale Exempt Marital Trust and Katherine C. Qvale NonExempt Martial Trust materials provided by the Manatt firm for inspection on June 10, 2014. These documents have been marked Confidential and bates stamped QTRUST00000001-QTRUST00037146. We are providing the documents to you ina Concordance data base with tiff images and OCR text files. Please let me know if you have any issues with the DVD. Regards, L4 Aivbaw Karen J. Bringola Senior Paralegal Enclosure 837495.01EXHIBIT 38KEKER & VAN NESTur Sen Frncbc, CA 94111-1809 415 397 5400 kyn.com Raina Magat (415) 773-6692 mmagat@kva.com June 30, 2014 VIA COURIER & FEDERAL EXPRESS Dominic J. Campisi Ronald Hayes Malone Evans, Latham & Campisi 909 Mustang Court One Post Street, 6th Floor Petaluma, CA 94954 San Francisco, CA 94104 Re: Inre Qvale Estate, Case Nos, PTR-13-297016, PTR-13-297017, PTR-13-297143 Dear Counsel: Enclosed please find a DVD containing copies of the Kjell H. Qvale Survivor’s Trust materials provided by the Manatt firm for inspection on June 24, 2014. These documents have been matked Confidential and bates stamped QTRUST00037147-QTRUST00065118. We are providing the documents to you in a Concordance database with TIFF images and OCR text files. Please let me know if you have any issues with the DVD. Regards, ae Raina Magat Paralegal Enclosure ce: Peter Muhs George Montgomery 838238EXHIBIT 39Karen Bringola From: Lee, Barry Sent: Wednesday, July 16, 2014 3:52 PM To: Ron@circleoakequine.com Ce: Lee, Barry; Cerruti, Veronica; Hofbauer, Claire Fox; Warren Braunig; Ben Berkowitz; Peter S. Myers (psmyers@myersurbatsch.com) (psmyers@myersurbatsch.com); pmuhs@cwclaw.com; Dominic J. Campisi (DCampisi@elc-law.com) Subject: FW: Qvale - Original Client Billing Files Ron--You were inadvertently not copied on email below. Not sure if you want to review hard cop. Regards, Barry Barry Lee Partner Manatt, Phelps & Phillips, LLP One Embarcadero Canter 30th Floor San Francisco, CA 94114 D (415) 204-7450 F (415) 294-7519 BWLee@manatt.com pinnati.cam CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous esnai messages attached fo it, may contain confidential information that is jegally privileged. {f you are set the intended recipiant, or a person respansible for delivering it te th nded recipient, you are hereby notified thal any disclosure, copying, distribution or use of any of the information contained in or aftached fo this massage is STRICTLY PROHIBITED. If you have received this transrnigsion in error, please ely notily us by reply email and destroy the original transmission and ils attachments without reading them or saving thentto isk, Thank you, From: Marquez, Demetrio Sent: Wednesday, July 16, 2014 3:47 PM To: jschneli@elc-law.com; DCampisi@elc-law.com Cc: Lee, Barry; Warren Braunig (WBraunig@kvn.com); Hofbauer, Claire Fox; abajoria@kvn.com; Karen Bringola (KBringola@KVN.com) Subject: Qvale - Original Client Billing Files Hi Jody and Mr. Campisi, Please be advised that 8 boxes of original client billing files from Laura will be available for your inspection starting this Monday, July 21 at 10:00 am in our office. Please confirm if this date and time works for you. These files have been scanned and Keker is producing them separately to you in electronic format (QTRUST00065119 - QTRUST00093251) . Thank you, Demetrio Demetrio MarquezParalegal Manat, Phelps & Phillips, LLP One Embarcadero Centar 30th Floor San Francisco. CA 94411 D (415) 201-7557 F (415) 291-7659 DMarquez@manat.com manaticon CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages aflached to it, may sontain confidential information tat is legally privileged. if you are not the intended recipient, or a person responsilsie for delivering it to the intended recipient, you are hereby notified that sny disclosure, copying. disinbutior of use of ary of the information contained in or attached to this message ig STRICTLY PROHIBITED. if you have received this tranemission in err, please immediately nosfy us by reply eriall and destroy the original transmission arid tts atlachments without reading shen or saving them to disk. Thanks youEXHIBIT 40Karen Bringola From: Lee, Barry [mailto:BWLee@manatt.com Sent: Tuesday, July 01, 2014 11:03 AM To: Ron@circleoakequine.com; Bruce Qvale (bqvale@qmmanagementine.com); lhiura@bmed.com; 4eff@qvalemanagement.com' Cc: Lee, Barry; Cerruti, Veronica; Warren Braunig; Ben Berkowitz; Naznin Challa (NChalla@elc-law.com); Andrew Zabronsky (AZabronsky@elc-law.com); George F. Montgomery (george@fomlaw.com); Dominic J. Campisi (BCampisi@elc-law.com); pmuhs@cwclaw.com Subject: FW: Qvale Marital and Survivor's Trust - Availability of Additional Records Ali-We are in receipt of your various ernails requesting additional information beyond the 20 boxes of trust administration documents we have already made available over the last few weeks. At the outset, neither of Mr. Campisi nor Mr. Muhs included me on the last few emails; to expedite matters please include me on all communications going forward. We are diligently working to identify, callect and produce additional materials to you. However, we need to go about this in a more organized way, and with agreement on what exactly it is you are seeking, so that we are not constantly chasing the next request. | propose that each trustee (Jeff and Ron) provide to us, in writing, in a numbered list, the items you believe we have not produced and to which you helleve you are entitled. State them as simply and clearly as possible, without leveling incorrect accusations of malfeasance in every request. Such a list will give us the opportunity to review each specific request, seek clarification, determine whether we agree that the request is proper, and, if so, collect them and make them available to you. {f you want to prioritize them, please do so. Within a couple of days of receiving these requests, we should have a telephone conference that will allow us to discuss any disagreements or confusion we might have. We will then make the documents available on a rolling basis, as we have been doing so far. And we will be able to tell you specifically “Requests No. 1-17 are provided. Nos. 18-25 are still in progress. Etc.” Receiving daily, overlapping requests (sometimes from multiple lawyers on behalf of the sare trustee) is distracting us from actually getting you documents in a timely manner. To get this approach started, immediately below is the status of certain of the materials that some or all of you have requested. We have taken the liberty of numbering these as Request Nos. 1-9, which is how they should be referenced in future emalis/correspondence. Thus: 1. Regarding your question whether any additional income statements or balance sheets exist for 2013/2014, the available records far the 2013/2014 transactions were provided in the prior document productions and/or such records are with BPM to assist them in the preparation of the incorne tax returns. No additional income statements or balance sheets were prepared for this period of time. 2. The source information used in preparing the draft estate tax return will be made available to all parties for their review with the draft return. We expect to circulate the draft return today or tomorrow. 3. Written communications between Steefel/Manatt and Kathryn and Kjell Qvale regarding estate planning are being gathered, reviewed, and duplicated. if we are to produce these materials without a Petition for Instructions, we will need each of the Trustees and their counsel to agree in writing that this production dees not constitute a waiver of any applicable privileges or protections, including but not limited ta the attorney/client privilege and the attorney work product protection. These communications are being turned over to the co-trustees at their request as trust administration materials. We are also aware of the limitations imposed by Section 19.11 of the 2002 Trust Agreement and want to ensure that all Trustees (and their counsel} agree that turning over these communications is not a violation of Section 19.11 and will not constitute any sort of waiver of the protections codified by Kjell & Kathryn in Section 19.11, including the absolute protection for attorney work product. An email to everyone on this email confirming agreement will be sufficient. 14, Additional materials relating to the funding of the sub-trusts were located late last week and will be made available for review. 5. We will search our files for information on the split dollar insurance trust. 6. Arun of the receipts and disbursements for the various sub-trusts for the period Nov. 2013-May 2014 will be forwarded today. The materials for the pre-Nov. 2013 period were previously made available (as was the Nov. & Dec. 2013 information}. 7. Additional correspondence between Manatt and Dr. Smith was located late last week and will be made available for review. 8. Conflict waivers have already been produced. Some conflict waivers are contained in the redemption agreements, which were produced some time aga. 9. Steefel/Manatt billing statements are being reviewed for relevance and will be praduced to the extent they address estate planning work done for either Kathryn or Kjell. We appreciate your willingness to work with us, so that we can get you what you need as co-trustees more quickly and smoothly. And, Dominic, for everyone's sake, please turn down the rhetoric. We are trying to work with you; this is an administrative process of gathering and reviewing volurninous materials and then distributing them in searchable format for all interested parties, while protecting any applicable privileges. Rhetorical accusations of malfeasance serve only ta create hostility among the co-trustees and their counsel, resulting in a more difficult and costly administration. Thanks. Barty Lee Partner Manat, Phelps & Phillips, IAP One Embarcadero Center 30th Floor San Francisco, CA 94111 D (415) 201-7450 F (415) 297-7518 BWLee@manatt.com manati.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages atlached fo it, may contain confidential information that is iegally privileged. ff you are not the intended recipient, or a person responsible for delivering it te the intended recipient, you ere hereby notified that any disclosure, capying,