Preview
IOUT MOA
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Jan-17-2012 3:42 pm
Case Number: PES-10-293505
Filing Date: Jan-17-2012 3:42
Juke Box: 001 Image: 03455138
DECLARATION
IN RE: STAN KWONG IRREVOCABLE TRUST II
001P03455138
Instructions:
Please place this sheet on top of the document to be scanned.24
25
By FAX
Christine Tour-Sarkissian (SBN 118794)
Paut Tour-Sarkissian (SBN 123467) ER b & kb
Phil Foster (SBN 262120) ot Gert al Gl “ante
TOUR-SARKISSIAN LAW OFFICES eutity ofean Frantieht)
211 Gough Street, Third Floor JAN 4 7 2012
San Francisco, CA 94102 T
Telephone (415) 626-7744 cu AK OF THE COUR
Facsimile (415) 626-8189 BY: oes
Attomeys for Respondent
JEANNE KWONG as Trustee
of the Stan Kwong Trust
IN THE TRIAL COURTS FOR THE STATE OF CALIFORNIA
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION
Case No.: PES-09-293019
IN THE MATTER OF THE STAN KWONG _| Related Cases: PES-09-292733
TRUST FT 13
CGC-10-499028
DECLARATION OF NON-PARTY
WITNESS KAY TANG LEE IN SUPPORT
OF MOTION FOR RECONSIDERATION
I, Kay Tang Lee, declare:
1. I am not a party to any of the above-listed actions.
2. I submit this declaration in support of Respondent Jeanne Kwong’s Motion for
Reconsideration of Order Removing Jeanne Kwong as Trustee of the Stan Kwong Trust.
3. My husband Gary Lee and I were friends with Stan Kwong from 2002 or 2003 until the
1
DECLARATION OF NON-PARTY WITNESS KAY TANG LEE
IN SUPPORT OF MOTION FOR RECONSIDERATIONtime of Stan’s death in July 2009.
4. We first met Stan when seeking a refinance loan on our home in either 2002 or 2003.
After hiring Stan to obtain a refinance loan for us, we continued to consult with Stan for his advice in
the management of our property, including a rental property that my husband and I owned at the time.
Stan was well versed in the business world and had a lot of contacts that my husband and I came to rely
on.
5. Early on, our business relationship with Stan developed into a close friendship. Stan
was a great guy whose company we enjoyed. We frequently visited him at his office and spoke with
him on the phone. We considered Stan a good friend with whom we frequently went out for dinner.
6. Until the birth of Stan’s first child in 2007, Stan never told either of us that Stan was
married. During the first four or five years of our friendship with Stan, Stan never gave us any
indication that Stan was married. Stan’s wife never joined us for dinner or in the car when we drove
around the city. To the contrary, I recall that my husband and I used to ask Stan about his girlfriends.
We teased Stan about working so much and leading a single’s man life.
7. Stan never told us that Stan was married until after the birth of Stan’s child Justin in
2007. After the birth of Stan’s first child, we learned that Stan was married to Jennifer Kwok, whom
we had seen working in Stan’s office.
8. In the months of September 2008 through December 2008, Stan and I had a few
conversations during which Stan informed me that Stan had hired two attomeys to prepare his trusts.
During the period of time after Stan had learned of his diagnosis but prior to his chemotherapy in either
October or November 2008, I recall a specific conversation with Stan during which Stan stated that he
was very stressed. Not only was he faced with cancer and the need to prepare his estate plan, but also
Stan and his wife were in constant disagreement over Stan’s estate plan, which was impeding the
attomeys from writing the trusts. Stan stated to me “I gave her everything, but it’s never enough.”
During the same conversation, Stan stated “I gave her so much already. How many millions will be
2
DECLARATION OF NON-PARTY WITNESS KAY TANG LEE
IN SUPPORT OF MOTION FOR RECONSIDERATION24
25
enough?”
9. Stan told me that his constant arguing with his wife was a source of incredible stress for
him. Stan owned several buildings that he said belonged to his family. Whenever Stan used the word
“family” or “family’s buildings,” he always meant his mother, sister, and brother. Stan said he wanted
his “family’s buildings” to stay with his family. 1 remember asking how he could undergo
chemotherapy with so much on his mind. | told him that everything should be smooth so that he did
not have anything else on his mind except the chemotherapy.
10. Unfortunately, according to Stan, his stress derived from more than just being unable to
complete his trusts because of arguments with his wife. Stan told me that his stress derived from
concem for his children. Stan stated that he was concerned about where the children would go to
school and who would take care of the children if Stan was gone. According to Stan, his wife never
got out of bed in the morning and never cooked. He said that nobody was there to take care of the kids.
He was worried about who would take care of the kids while Stan was undergoing chemotherapy. It
was for this reason that Stan gave me a key to the gate to his house on Vallejo Street. At his request, I
started taking Stan’s children to the playground in the morning.
11. Out of all my times at Stan’s house on Vallejo Street to pick up Stan’s children, 1 never
saw Stan’s wife up in the morning.
12. Prior to undergoing chemotherapy, Stan also told me that Stan was planning on
divorcing his wife and had spoken to his divorce attomey several times. Stan told me that after his
transplant procedure, he had already decided to go live with his sister. He said he was never returning
to the house on Vallejo Street (where his wife Jennifer lived) because he needed “peace of mind.” Stan
also stated that Stan was leaving in one of his trusts money to his wife solely for Stan’s children in the
event that Stan did not survive his cancer. Stan made this statement a number of times to me and my
husband over the course of the next few months. He said that Stan was leaving his family’s buildings
to his sister for the family. Again, Stan used the word “family” to mean his mother, his sister, and his
3
DECLARATION OF NON-PARTY WITNESS KAY TANG LEE
IN SUPPORT OF MOTION FOR RECONSIDERATIONbrother.
13. After Stan’s chemotherapy in October/November 2008, Stan was having difficulty
finding a bone marrow donor for the transplant surgery that he needed. In approximately December
2008, Stan’s sister held a bone marrow donation drive at Stan’s office. Everyone arrived at Stan’s
office around 9 AM in the morning on a weekend to begin setting up. Stan’s sister, his co-workers, and
his sister’s friends were there. Stan’s wife Jennifer Kwok was not there. Stan’s wife did not arrive
until after 1:30 or 2 PM that afternoon and stayed only briefly.
14. Later on, although I do not recall the date, I remember that Stan, my husband, and I were
riding in the car when the subject of Stan’s trusts again came up. Stan said that he was giving all of his
“family buildings” to his sister. He said he wanted to keep the “family buildings” separate from
everything else. As Stan said this, we were driving on Walnut Street. Stan pointed at a building that
we were driving past. He said that the building he pointed at was being left to his sister because it was
his family’s building.
15. In the early months of 2009, I had another conversation with Stan about his trusts. To
the best of my recollection, this conversation was in the weeks leading up to Stan’s transplant surgery.
Stan and I went for lunch at one of Stan’s favorite restaurants, which is near the Jewish Community
Center. Stan stated to me that Stan and his wife were arguing all the time at this point. According to
Stan, his arguments with his wife concerned the same matters as before Stan underwent chemotherapy.
According to Stan, his wife wanted “more and more and more.”
16. | When we met for lunch, Stan told me that Stan had worked out the calculation of how
much was going to his wife. I do not recall Stan ever giving me the total amount of what he was
leaving to his wife. However, I remember that Stan had calculated how much his wife would receive
for each month for the rest of her life. According to his calculation, Stan’s wife was going to receive
$30,000 to $40,000 each month for the rest of her life. He said: “Thirty or forty-thousand dollars a
month is not enough for her?”
4
DECLARATION OF NON-PARTY WITNESS KAY TANG LEE
JN SUPPORT OF MOTION FOR RECONSIDERATION17. Over lunch, I told Stan about the disagreements about the trust that had arisen in my
family after my father-in-law died. | told Stan that he better write it clear to avoid any fights. Stan’s
response was to say that if anybody fought over the assets, then that person will get nothing. He said
he had two lawyers working on it but that his wife kept wanting his family’s buildings. As of the time
that Stan made this statement, Stan had been telling me and my husband about Stan and his wife’s
arguments about the trusts for more than six months.
48. 1 asked what Stan wanted. Stan said he wanted to keep things separate. He said he
wanted his family buildings separate from his wife. He said, “These are my family’s buildings. This is
not anything that Jennifer is going to get.” He said he wanted his sister to get everything that belonged
to the family in order to keep his family separate from his wife. Stan said that he trusted his sister and
that he was “very close” with his sister, which is why he wanted her to get everything that belonged to
the family. Stan said that he only had one sister and that they had always been close. He said that he
loved his sister and his sister’s daughters and that he had always taken care of them. He said he was
always to going to take care of them for the rest of their lives. He said he trusted his sister’s daughters
as much as he trusted his sister.
19. T recall that Stan went into the hospital several weeks later in the middle of April 2009.
My husband and I visited Stan in the hospital on at least two occasions. On each of these occasions,
Stan’s sister asked me to stay with Stan because Stan’s friend/companion Hee Joo Lee had been
staying overnight and was tired and needed someone to relieve her.
20. IL only ever saw Stan’s wife Jennifer visit Stan one time in the hospital. Stan’s wife
arrived at the hospital in the afternoon. Stan had been temporarily taken out of the room for X-rays. I
was the only person in Stan’s room. His wife did not wait around for Stan to return. She asked me
who was taking care of Stan and then left. I did not see her speak with anyone about Stan’s condition.
She did not wait around to ask Stan about his condition.
21. Aside from that one visit, I never saw Stan’s wife return to see Stan in the hospital on
5
DECLARATION OF NON-PARTY WITNESS KAY TANG LEE
JN SUPPORT OF MOTION FOR RECONSIDERATIONany of Stan’s hospital stays. I also never saw her at Stan’s sister’s house during Stan’s recovery phase.
22. To the best of my knowledge, it was Stan’s sister and nieces and Stan’s
friend/companion Hee Joo Lee who attended to Stan and remain at his side constantly while he was in
the hospital. 1 personally observed Stan’s friend/companion Hee Joo Lee taking notes when hospital
staff entered Stan’s room and talked to him. I saw Hee Joo Lee attending to Stan’s medications, the
medication schedule, Stan’s meal schedule, and Stan’s general well being. So far as I ever saw or
heard from anyone, Stan’s wife was never involved in any of this.
23. Ineither April or May 2009, I again visited Stan in the hospital. Although Stan did not
say it explicitly, | understood from him that Stan and his wife were stil! arguing about money and
property. I remember that Stan had turned off his cell phone to avoid his wife. Stan stated, as he often
did, that he just wanted peace of mind.
24. Unfortunately, the care of Stan’s children was a stress for Stan on that day. As Stan had
feared months earlier, Stan did not know who was taking care of Stan’s two children while Stan was
hospitalized. Stan told me that Stan had just learned that Stan’s mother had gone to Stan’s house on
Vallejo Street to make breakfast and tend to the children. I was aware from Stan that Stan’s mother
had been going to the Vallejo Street house for several months to wake and feed the children. On this
day in the hospital, Stan told me that Stan’s wife had suddenly changed the lock to the front gate. Stan
stated unequivocally that his wife had changed the lock to the gate and that his mother was no longer
being allowed inside the house. Stan was unspeakably disturbed.
25. After his surgery, Stan did not want to return to the Vallejo Street house. According to
Stan, he had planned since at least the time of his chemotherapy that he would not go back to the
Vallejo Street house except to pick up his kids after his recovery. Stan told me that he had never
changed his mind about moving into his sister’s house. When Stan was discharged from the hospital,
Stan went to live at his sister’s house. I visited Stan at his sister’s house several times.
26. On my first visit to see Stan at his sister’s house, { brought Stan several containers of
6
DECLARATION OF NON-PARTY WITNESS KAY TANG LEE
EN SUPPORT OF MOTION FOR RECONSIDERATIONEnsure for his recovery. Stan was physically weak, but his mind was clear. His friend/companion Hee
Joo Lee was at the house, cooking for Stan in the downstairs kitchen. Stan and I had a chance to talk.
He told me about looking up and calling an old high school or college girlfriend a while back. He
made the comment that he should have stuck with her. I understood Stan to be saying that he regretted
his marriage. | remember saying something to the effect of it’s not too late or how could it be too late
but that he needed to fight his cancer first.
27. In response, Stan stated that he did not know why his wife was still fighting with him
even during his recovery. Stan said he had left all of the family’s buildings to his sister and that there
nothing more to argue about. He was never returning to the house on Vallejo Street. After he
recovered, he wanted to take care of his two kids. If he did not recover, he said his sister was going to
take care of the family. He mentioned that he had not named his mother in his trust because his mother
was old but that he knew his sister would take care of ber without Stan having to tell her to.
28. He said that he had not ever trusted his wife when it came to his “family’s buildings.”
He said it was important to him to keep the family’s buildings separate from his wife because he could
not trust his wife to work with his sister when it came to the family’s buildings.
29, Inmall the time that I knew him, Stan never said be could rely on his wife to look out for
Stan’s mother or family.
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct. Executed on January Lb, 2012 at San Francisco, California.
KAY JANG L Ade
7
DECLARATION OF NON-PARTY WITNESS KAY TANG LEE
IN SUPPORT OF MOTION FOR RECONSIDERATION
Preview
IOUT MOA SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Jan-17-2012 3:42 pm Case Number: PES-10-293505 Filing Date: Jan-17-2012 3:42 Juke Box: 001 Image: 03455138 DECLARATION IN RE: STAN KWONG IRREVOCABLE TRUST II 001P03455138 Instructions: Please place this sheet on top of the document to be scanned.24 25 By FAX Christine Tour-Sarkissian (SBN 118794) Paut Tour-Sarkissian (SBN 123467) ER b & kb Phil Foster (SBN 262120) ot Gert al Gl “ante TOUR-SARKISSIAN LAW OFFICES eutity ofean Frantieht) 211 Gough Street, Third Floor JAN 4 7 2012 San Francisco, CA 94102 T Telephone (415) 626-7744 cu AK OF THE COUR Facsimile (415) 626-8189 BY: oes Attomeys for Respondent JEANNE KWONG as Trustee of the Stan Kwong Trust IN THE TRIAL COURTS FOR THE STATE OF CALIFORNIA IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION Case No.: PES-09-293019 IN THE MATTER OF THE STAN KWONG _| Related Cases: PES-09-292733 TRUST FT 13 CGC-10-499028 DECLARATION OF NON-PARTY WITNESS KAY TANG LEE IN SUPPORT OF MOTION FOR RECONSIDERATION I, Kay Tang Lee, declare: 1. I am not a party to any of the above-listed actions. 2. I submit this declaration in support of Respondent Jeanne Kwong’s Motion for Reconsideration of Order Removing Jeanne Kwong as Trustee of the Stan Kwong Trust. 3. My husband Gary Lee and I were friends with Stan Kwong from 2002 or 2003 until the 1 DECLARATION OF NON-PARTY WITNESS KAY TANG LEE IN SUPPORT OF MOTION FOR RECONSIDERATIONtime of Stan’s death in July 2009. 4. We first met Stan when seeking a refinance loan on our home in either 2002 or 2003. After hiring Stan to obtain a refinance loan for us, we continued to consult with Stan for his advice in the management of our property, including a rental property that my husband and I owned at the time. Stan was well versed in the business world and had a lot of contacts that my husband and I came to rely on. 5. Early on, our business relationship with Stan developed into a close friendship. Stan was a great guy whose company we enjoyed. We frequently visited him at his office and spoke with him on the phone. We considered Stan a good friend with whom we frequently went out for dinner. 6. Until the birth of Stan’s first child in 2007, Stan never told either of us that Stan was married. During the first four or five years of our friendship with Stan, Stan never gave us any indication that Stan was married. Stan’s wife never joined us for dinner or in the car when we drove around the city. To the contrary, I recall that my husband and I used to ask Stan about his girlfriends. We teased Stan about working so much and leading a single’s man life. 7. Stan never told us that Stan was married until after the birth of Stan’s child Justin in 2007. After the birth of Stan’s first child, we learned that Stan was married to Jennifer Kwok, whom we had seen working in Stan’s office. 8. In the months of September 2008 through December 2008, Stan and I had a few conversations during which Stan informed me that Stan had hired two attomeys to prepare his trusts. During the period of time after Stan had learned of his diagnosis but prior to his chemotherapy in either October or November 2008, I recall a specific conversation with Stan during which Stan stated that he was very stressed. Not only was he faced with cancer and the need to prepare his estate plan, but also Stan and his wife were in constant disagreement over Stan’s estate plan, which was impeding the attomeys from writing the trusts. Stan stated to me “I gave her everything, but it’s never enough.” During the same conversation, Stan stated “I gave her so much already. How many millions will be 2 DECLARATION OF NON-PARTY WITNESS KAY TANG LEE IN SUPPORT OF MOTION FOR RECONSIDERATION24 25 enough?” 9. Stan told me that his constant arguing with his wife was a source of incredible stress for him. Stan owned several buildings that he said belonged to his family. Whenever Stan used the word “family” or “family’s buildings,” he always meant his mother, sister, and brother. Stan said he wanted his “family’s buildings” to stay with his family. 1 remember asking how he could undergo chemotherapy with so much on his mind. | told him that everything should be smooth so that he did not have anything else on his mind except the chemotherapy. 10. Unfortunately, according to Stan, his stress derived from more than just being unable to complete his trusts because of arguments with his wife. Stan told me that his stress derived from concem for his children. Stan stated that he was concerned about where the children would go to school and who would take care of the children if Stan was gone. According to Stan, his wife never got out of bed in the morning and never cooked. He said that nobody was there to take care of the kids. He was worried about who would take care of the kids while Stan was undergoing chemotherapy. It was for this reason that Stan gave me a key to the gate to his house on Vallejo Street. At his request, I started taking Stan’s children to the playground in the morning. 11. Out of all my times at Stan’s house on Vallejo Street to pick up Stan’s children, 1 never saw Stan’s wife up in the morning. 12. Prior to undergoing chemotherapy, Stan also told me that Stan was planning on divorcing his wife and had spoken to his divorce attomey several times. Stan told me that after his transplant procedure, he had already decided to go live with his sister. He said he was never returning to the house on Vallejo Street (where his wife Jennifer lived) because he needed “peace of mind.” Stan also stated that Stan was leaving in one of his trusts money to his wife solely for Stan’s children in the event that Stan did not survive his cancer. Stan made this statement a number of times to me and my husband over the course of the next few months. He said that Stan was leaving his family’s buildings to his sister for the family. Again, Stan used the word “family” to mean his mother, his sister, and his 3 DECLARATION OF NON-PARTY WITNESS KAY TANG LEE IN SUPPORT OF MOTION FOR RECONSIDERATIONbrother. 13. After Stan’s chemotherapy in October/November 2008, Stan was having difficulty finding a bone marrow donor for the transplant surgery that he needed. In approximately December 2008, Stan’s sister held a bone marrow donation drive at Stan’s office. Everyone arrived at Stan’s office around 9 AM in the morning on a weekend to begin setting up. Stan’s sister, his co-workers, and his sister’s friends were there. Stan’s wife Jennifer Kwok was not there. Stan’s wife did not arrive until after 1:30 or 2 PM that afternoon and stayed only briefly. 14. Later on, although I do not recall the date, I remember that Stan, my husband, and I were riding in the car when the subject of Stan’s trusts again came up. Stan said that he was giving all of his “family buildings” to his sister. He said he wanted to keep the “family buildings” separate from everything else. As Stan said this, we were driving on Walnut Street. Stan pointed at a building that we were driving past. He said that the building he pointed at was being left to his sister because it was his family’s building. 15. In the early months of 2009, I had another conversation with Stan about his trusts. To the best of my recollection, this conversation was in the weeks leading up to Stan’s transplant surgery. Stan and I went for lunch at one of Stan’s favorite restaurants, which is near the Jewish Community Center. Stan stated to me that Stan and his wife were arguing all the time at this point. According to Stan, his arguments with his wife concerned the same matters as before Stan underwent chemotherapy. According to Stan, his wife wanted “more and more and more.” 16. | When we met for lunch, Stan told me that Stan had worked out the calculation of how much was going to his wife. I do not recall Stan ever giving me the total amount of what he was leaving to his wife. However, I remember that Stan had calculated how much his wife would receive for each month for the rest of her life. According to his calculation, Stan’s wife was going to receive $30,000 to $40,000 each month for the rest of her life. He said: “Thirty or forty-thousand dollars a month is not enough for her?” 4 DECLARATION OF NON-PARTY WITNESS KAY TANG LEE JN SUPPORT OF MOTION FOR RECONSIDERATION17. Over lunch, I told Stan about the disagreements about the trust that had arisen in my family after my father-in-law died. | told Stan that he better write it clear to avoid any fights. Stan’s response was to say that if anybody fought over the assets, then that person will get nothing. He said he had two lawyers working on it but that his wife kept wanting his family’s buildings. As of the time that Stan made this statement, Stan had been telling me and my husband about Stan and his wife’s arguments about the trusts for more than six months. 48. 1 asked what Stan wanted. Stan said he wanted to keep things separate. He said he wanted his family buildings separate from his wife. He said, “These are my family’s buildings. This is not anything that Jennifer is going to get.” He said he wanted his sister to get everything that belonged to the family in order to keep his family separate from his wife. Stan said that he trusted his sister and that he was “very close” with his sister, which is why he wanted her to get everything that belonged to the family. Stan said that he only had one sister and that they had always been close. He said that he loved his sister and his sister’s daughters and that he had always taken care of them. He said he was always to going to take care of them for the rest of their lives. He said he trusted his sister’s daughters as much as he trusted his sister. 19. T recall that Stan went into the hospital several weeks later in the middle of April 2009. My husband and I visited Stan in the hospital on at least two occasions. On each of these occasions, Stan’s sister asked me to stay with Stan because Stan’s friend/companion Hee Joo Lee had been staying overnight and was tired and needed someone to relieve her. 20. IL only ever saw Stan’s wife Jennifer visit Stan one time in the hospital. Stan’s wife arrived at the hospital in the afternoon. Stan had been temporarily taken out of the room for X-rays. I was the only person in Stan’s room. His wife did not wait around for Stan to return. She asked me who was taking care of Stan and then left. I did not see her speak with anyone about Stan’s condition. She did not wait around to ask Stan about his condition. 21. Aside from that one visit, I never saw Stan’s wife return to see Stan in the hospital on 5 DECLARATION OF NON-PARTY WITNESS KAY TANG LEE JN SUPPORT OF MOTION FOR RECONSIDERATIONany of Stan’s hospital stays. I also never saw her at Stan’s sister’s house during Stan’s recovery phase. 22. To the best of my knowledge, it was Stan’s sister and nieces and Stan’s friend/companion Hee Joo Lee who attended to Stan and remain at his side constantly while he was in the hospital. 1 personally observed Stan’s friend/companion Hee Joo Lee taking notes when hospital staff entered Stan’s room and talked to him. I saw Hee Joo Lee attending to Stan’s medications, the medication schedule, Stan’s meal schedule, and Stan’s general well being. So far as I ever saw or heard from anyone, Stan’s wife was never involved in any of this. 23. Ineither April or May 2009, I again visited Stan in the hospital. Although Stan did not say it explicitly, | understood from him that Stan and his wife were stil! arguing about money and property. I remember that Stan had turned off his cell phone to avoid his wife. Stan stated, as he often did, that he just wanted peace of mind. 24. Unfortunately, the care of Stan’s children was a stress for Stan on that day. As Stan had feared months earlier, Stan did not know who was taking care of Stan’s two children while Stan was hospitalized. Stan told me that Stan had just learned that Stan’s mother had gone to Stan’s house on Vallejo Street to make breakfast and tend to the children. I was aware from Stan that Stan’s mother had been going to the Vallejo Street house for several months to wake and feed the children. On this day in the hospital, Stan told me that Stan’s wife had suddenly changed the lock to the front gate. Stan stated unequivocally that his wife had changed the lock to the gate and that his mother was no longer being allowed inside the house. Stan was unspeakably disturbed. 25. After his surgery, Stan did not want to return to the Vallejo Street house. According to Stan, he had planned since at least the time of his chemotherapy that he would not go back to the Vallejo Street house except to pick up his kids after his recovery. Stan told me that he had never changed his mind about moving into his sister’s house. When Stan was discharged from the hospital, Stan went to live at his sister’s house. I visited Stan at his sister’s house several times. 26. On my first visit to see Stan at his sister’s house, { brought Stan several containers of 6 DECLARATION OF NON-PARTY WITNESS KAY TANG LEE EN SUPPORT OF MOTION FOR RECONSIDERATIONEnsure for his recovery. Stan was physically weak, but his mind was clear. His friend/companion Hee Joo Lee was at the house, cooking for Stan in the downstairs kitchen. Stan and I had a chance to talk. He told me about looking up and calling an old high school or college girlfriend a while back. He made the comment that he should have stuck with her. I understood Stan to be saying that he regretted his marriage. | remember saying something to the effect of it’s not too late or how could it be too late but that he needed to fight his cancer first. 27. In response, Stan stated that he did not know why his wife was still fighting with him even during his recovery. Stan said he had left all of the family’s buildings to his sister and that there nothing more to argue about. He was never returning to the house on Vallejo Street. After he recovered, he wanted to take care of his two kids. If he did not recover, he said his sister was going to take care of the family. He mentioned that he had not named his mother in his trust because his mother was old but that he knew his sister would take care of ber without Stan having to tell her to. 28. He said that he had not ever trusted his wife when it came to his “family’s buildings.” He said it was important to him to keep the family’s buildings separate from his wife because he could not trust his wife to work with his sister when it came to the family’s buildings. 29, Inmall the time that I knew him, Stan never said be could rely on his wife to look out for Stan’s mother or family. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on January Lb, 2012 at San Francisco, California. KAY JANG L Ade 7 DECLARATION OF NON-PARTY WITNESS KAY TANG LEE IN SUPPORT OF MOTION FOR RECONSIDERATION