Motion-Secondary: CAROLE M. LAFFEY TRUST

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                                Electronically FILED by Superior Court of California, County of Los Angeles 1/12/2023 1:16 PM David W. Slayton, Executive Officer/Clerk, By S. Katourjian, Deputy Clerk




                    Donald G. Walker (SBif135758)
                    99 Elm Ave.
                    Larkspur, Ca 94939
                3   Telephone: 415 924 9164
                    Fax: 415 924 9165
                    legalfirm@pacbell.net
                    Attorney for Respondent
                    Karen Laffey
                                    IN THE      SUPERIOR COURT OF THE STATE OF CALIFORNIA
               7
                                                             COUNTY OF LOS ANGELES
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                                                                           PROBATE
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                                                               Stanley Mosk Courthouse
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                    In   the Matter of the

                     CAROLE M. LAFFEY TRUST                                               CASE NO 22STPB03006
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                           JOHN KEVIN LAFFEY, BRUCE
           14                         ALAN LAFFEY, and                                   RESPONSE TO PETITION FOR
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                                                                                         BREACH OF FIDUCIARY DUTY BY
                                                Petitioner                               TRUSTEE AND SURCHARGE AGAINST
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                                                                                         KAREN IIARIE LAFFEY

          17                                                                         Hearing: January 20,2023
                                                KAREN MARIE                          Time: 9;30 a.m.
          18                                    LAFFEY                               Dept 44
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                                                   Respondents
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                             In   response to the petition for breach of fiduciary duty and for a
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          23        surcharge filed by John Kevin Laffey and Bruce Alan Laffey,                                          in   the above
                    captioned matter and to the notice issued thereon, the respondent Karen
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                    Marie Laffey,       as trustee of the Carole M. Laffey Trust dated October 2,
                    2015, admits, denies, and alleges:
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                            (1)With respect to paragraph                      1   of the Petition, Respondent denies
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                     RESPONSE TO PETITION          by   KAREN MARIE LAFFEY


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