On May 23, 2006 a
Party Statement
was filed
involving a dispute between
Baum Thornley Architects, Llp One Ferry Building, Suite,
Bibbs, Paula R. Unk San Francisco, Ca 94102,
Hart, Rosia Lee,
Williams, Rosalind Reed,
Thomas, Herb,
and
Wiggins, Gregory,
for TRUST (PETITION TO REVOKE POWERS OF TRUSTEES)
in the District Court of San Francisco County.
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Andrew K. Schultz (SBN 215917)
WITHERSPOON & SIRACUSA
1550 Bryant Street, Suite 875
San Francisco, CA 94103
Telephone (415) 552-1814
Fax (415) 552-2158
Attorneys for Herb Thomas,
Proposed Trustee
SUPERIOR COURT OF THE STATE OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO
THE ROSIA L. HART
REVOCABLE TRUST
dated May 19, 2004
a
NUMBER: PTR-06-288755
DECLARATION OF ANDREW K. SCHULTZ
RE: NOTICE OF HEARING ON PETITION
FOR APPOINTMENT OF TEMPORARY
TRUSTEE
Dept: Probate, Room 202
Date: May 24, 2006
Time: 11:00 a.m.
1, Andrew K. Schultz, whose office address is 1550 Bryant Stréet, Suite 875,
San Francisco, CA 94103, declare: |
/
1. | am an attorney at law in good standing, duly licensed to practice law in the
State of California, and | represent the Petitioner in these proceedings, Herb Thomas,
a private professional conservator.
2. The hearing on Mr. Thomas's Ex Parte Petition to Suspend Powers of
Trustees, Bring Trust under Continuing Court Supervision, Appoint Temporary
Successor Trustee, and Dispense with Notice to Parties is currently scheduled for
11:00 a.m. on May 24, 2006.
DECLARATION RE: NOTICE
PTR-06-288755om NIN DH FF WN
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3. Petitioner is requesting that notice to Rosia Lee Hart, the trustor and initial
trustee, and Gregory Wiggins, who is believed to be the successor trustee, be dis-
pensed with.
4. Ms. Hart's only relative within the second degree is her brother, Pastor Henry
Gaines. He may also be named as a successor trustee of Ms. Hart’s trust. On May
23, 2006 at approximately 9:45 a.m., | spoke with Pastor Gaines by phone. | informed
him of the date, time; and place of the ex parte hearing and the nature of the relief
sought. | explained particularly that he may be named as a successor trustee of the
trust, and that we would be asking to suspend any powers he might have. He ex-
pressed no objection to the relief requested. With respect to his sister, he said that it
seemed like Mr. Wiggins had “twisted her mind so that she doesn’t trust her own
people.” He does not plan to attend the hearing. ,
| certify under penalty of perjury under the laws of the State of California that the
foregoing is true and correct, and that this declaration was executed at San Francisco,
California, on the date indicated below.
Dated: Ven 2 , 2006 bwin . Sob hy
Andrew K. Schultz
Attorney for Herb Thomas
y
DECLARATION RE: NOTICE 2 PTR-06-288755,
Document Filed Date
May 24, 2006
Case Filing Date
May 23, 2006
Category
TRUST (PETITION TO REVOKE POWERS OF TRUSTEES)
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sg om IN DW Bw NY Nw NR YN YN NN NN YY Be Re Be Be Bee Be ee eI DA A BH NH F DFO we NIN DH BF WwW NH KF ST Andrew K. Schultz (SBN 215917) WITHERSPOON & SIRACUSA 1550 Bryant Street, Suite 875 San Francisco, CA 94103 Telephone (415) 552-1814 Fax (415) 552-2158 Attorneys for Herb Thomas, Proposed Trustee SUPERIOR COURT OF THE STATE OF CALIFORNIA CITY AND COUNTY OF SAN FRANCISCO THE ROSIA L. HART REVOCABLE TRUST dated May 19, 2004 a NUMBER: PTR-06-288755 DECLARATION OF ANDREW K. SCHULTZ RE: NOTICE OF HEARING ON PETITION FOR APPOINTMENT OF TEMPORARY TRUSTEE Dept: Probate, Room 202 Date: May 24, 2006 Time: 11:00 a.m. 1, Andrew K. Schultz, whose office address is 1550 Bryant Stréet, Suite 875, San Francisco, CA 94103, declare: | / 1. | am an attorney at law in good standing, duly licensed to practice law in the State of California, and | represent the Petitioner in these proceedings, Herb Thomas, a private professional conservator. 2. The hearing on Mr. Thomas's Ex Parte Petition to Suspend Powers of Trustees, Bring Trust under Continuing Court Supervision, Appoint Temporary Successor Trustee, and Dispense with Notice to Parties is currently scheduled for 11:00 a.m. on May 24, 2006. DECLARATION RE: NOTICE PTR-06-288755om NIN DH FF WN YN YN NY NR NN YN Be Se we we we we we Se Be oR A aA FY NH FF BOD eR DH BF Ww NH KF OD 3. Petitioner is requesting that notice to Rosia Lee Hart, the trustor and initial trustee, and Gregory Wiggins, who is believed to be the successor trustee, be dis- pensed with. 4. Ms. Hart's only relative within the second degree is her brother, Pastor Henry Gaines. He may also be named as a successor trustee of Ms. Hart’s trust. On May 23, 2006 at approximately 9:45 a.m., | spoke with Pastor Gaines by phone. | informed him of the date, time; and place of the ex parte hearing and the nature of the relief sought. | explained particularly that he may be named as a successor trustee of the trust, and that we would be asking to suspend any powers he might have. He ex- pressed no objection to the relief requested. With respect to his sister, he said that it seemed like Mr. Wiggins had “twisted her mind so that she doesn’t trust her own people.” He does not plan to attend the hearing. , | certify under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was executed at San Francisco, California, on the date indicated below. Dated: Ven 2 , 2006 bwin . Sob hy Andrew K. Schultz Attorney for Herb Thomas y DECLARATION RE: NOTICE 2 PTR-06-288755,