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©WN®G$WNA
Marc E. Grossman (SBN 197627)
James T. Lee (SBN 110838)
100 North Euclid Ave, 2nd Floor
Upland, CA 91786
Phone: (909) 608-7426
Fax: (909) 949-0119
Email: marc@wefiqht4vou.com
iim@wefight4you.com
Attorney for Kendall F. Turner, Kelly James Turner
BY
W A ”WA
F
SUPERIOR COURT 0F
A
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gquORNIA
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APR 2 2
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ELI ,DEpuyy
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
A
A
.a.
GROSSMAN
949-0119
In re the:
FLOOR
A OW§OQNAO
Case No. PROSBZZOO416
OF
2ND (909)
....\
Estate of Betty J. Turner. OBJECTION TO PETITION FOR 0F
AVE., FX
WILL ANDIOR AUTHORIZATION T0
ELLIOT
91786 .A
Decadent ADMINISTER UNDER THE
OFFICES
INDEPENDENT ADMINISTRATION OF
EUCLID
CA
60&7426
.4
ESTATES ACT
N. UPLAND,
(909)
A N Date: April 25-, 2022
NLARC
Eimg: a.m. $1.; $29.”
LAW
100 $3060 “i £5
PH
.4 m ep ‘
5145;: t:;=4:i:
£33223
6:3
COMES NOW, Kendall F. Turner, administrator of the Conservatorship Estate
of Betty J. Turner, and Kelly James Turner, both sons of Betty J. Turner, and heirs of
Betty J. Turner, and object to the Petition for Probate. filed on March 24, 2022, by
Victor R. Tzankov.
NNNNNNNN QNODOILOONA
FACTUAL BACKGROUND
1. Decedent Betty J. Turner, Objectors’ mother, died on May 31, 2021.
2. At the time of her death, she was the Temporary Conservatee in the Temporary
Conservatorship of Betty Joan Turner, Case No. CONSPS 2000054, pending before
1
OBJECTION TO PETITION FOR PROBATE OF BETTY J. TURNER
Judge Tara Reilly. Objector Kendall F. Turner was the duly appointed Temporary
Conservator of the Estate having been appointed by Judge Reilly on March 4, 2020,
with Letters of Temporary Conservatorship of the Person and Estate issued on March
13, 2020 and were extended numerous times with General Letters not being issued
(Dm‘dODO‘IAODN—t
due to Betty J. Tumer’s death.
3. A hearing on the First and Final Account and Report of Temporary Conservator
and for Setttement Thereof; Petition for Delivery of Assets, is scheduled for hearing
before Judge Reilly on May 5, 2022, 10:30 a.m. Department S 37. A true and correct
copy of the First and Final Account and Report Of Temporary Conservator and For
.A O Settlement Thereof; Petition For Delivery Of Assets (“First and Final Account") with
.3
A attachments is attached to this Objection as Exhibit 1.
SSBlAN
—0119
.4 N 4. Attached as Exhibit1 to the First and Final Account the Betty J. Turner‘s Law
FLOOR
GRO
949 .4.
OD
VWI and Testament. This Will is dated March 7, 2002. This document lists the heirs to
2ND (9(8)
0F -B be Kelly J. Turner, Kendall F. Turner, and Kirk A. Turner. These are the three sons of
AVE.. FX
U1
decedent Betty
4AA...‘
ELLIOT
91786
J. Turner.
OFFICES
808-7426
CA
EUCLID
O)
5. By contrast Petitioner Tzankov’s Petition, attaches a purported Last VWI And
RIARC
N. UPLAND,
(909)
V Testament purportedly dated April 1, 2017, which disinherited Objectors and names
LAW
100 PH
A m Tzankov executor.
.4 CO 6. Objectors will file a Petition to Probate the aforementioned March 7, 2002 Will,
THC
a true and correct copy of which is attached to this Objection as Exhibit 2.
7. Paragraph d(1) of Tzankov’s Petition lists Personal PrOperty in the amount of
$300,000.00. By contrast, the First and Final Account represents that “[t]he assets on
hand do not exceed $166,250.00. (Exhibit 1, page 3, line 16).
8. Exhibit 1’s statement also necessarily excludes any real property owned by
NNNNNNNN
m‘dwm-FWNA
decedent at the time of her death. Again, by contrast, Tzankov’s Petition lists Real
Property worth $450,000.00.
9. The only real property previously owned by the decedent. Betty J. Turner was
the property located at 10232 Lilac Rd, Oak Hills, CA 92344 (the address listed in
2
OBJECTION TO PETITION FOR PROBATE 0F BETTY J. TURNER
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©WN®G$WNA Marc E. Grossman (SBN 197627) James T. Lee (SBN 110838) 100 North Euclid Ave, 2nd Floor Upland, CA 91786 Phone: (909) 608-7426 Fax: (909) 949-0119 Email: marc@wefiqht4vou.com iim@wefight4you.com Attorney for Kendall F. Turner, Kelly James Turner BY W A ”WA F SUPERIOR COURT 0F A l L gquORNIA Cgk’hfgggjflggqgosggggggo APR 2 2 . E 2 0 22 ELI ,DEpuyy SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO A A .a. GROSSMAN 949-0119 In re the: FLOOR A OW§OQNAO Case No. PROSBZZOO416 OF 2ND (909) ....\ Estate of Betty J. Turner. OBJECTION TO PETITION FOR 0F AVE., FX WILL ANDIOR AUTHORIZATION T0 ELLIOT 91786 .A Decadent ADMINISTER UNDER THE OFFICES INDEPENDENT ADMINISTRATION OF EUCLID CA 60&7426 .4 ESTATES ACT N. UPLAND, (909) A N Date: April 25-, 2022 NLARC Eimg: a.m. $1.; $29.” LAW 100 $3060 “i £5 PH .4 m ep ‘ 5145;: t:;=4:i: £33223 6:3 COMES NOW, Kendall F. Turner, administrator of the Conservatorship Estate of Betty J. Turner, and Kelly James Turner, both sons of Betty J. Turner, and heirs of Betty J. Turner, and object to the Petition for Probate. filed on March 24, 2022, by Victor R. Tzankov. NNNNNNNN QNODOILOONA FACTUAL BACKGROUND 1. Decedent Betty J. Turner, Objectors’ mother, died on May 31, 2021. 2. At the time of her death, she was the Temporary Conservatee in the Temporary Conservatorship of Betty Joan Turner, Case No. CONSPS 2000054, pending before 1 OBJECTION TO PETITION FOR PROBATE OF BETTY J. TURNER Judge Tara Reilly. Objector Kendall F. Turner was the duly appointed Temporary Conservator of the Estate having been appointed by Judge Reilly on March 4, 2020, with Letters of Temporary Conservatorship of the Person and Estate issued on March 13, 2020 and were extended numerous times with General Letters not being issued (Dm‘dODO‘IAODN—t due to Betty J. Tumer’s death. 3. A hearing on the First and Final Account and Report of Temporary Conservator and for Setttement Thereof; Petition for Delivery of Assets, is scheduled for hearing before Judge Reilly on May 5, 2022, 10:30 a.m. Department S 37. A true and correct copy of the First and Final Account and Report Of Temporary Conservator and For .A O Settlement Thereof; Petition For Delivery Of Assets (“First and Final Account") with .3 A attachments is attached to this Objection as Exhibit 1. SSBlAN —0119 .4 N 4. Attached as Exhibit1 to the First and Final Account the Betty J. Turner‘s Law FLOOR GRO 949 .4. OD VWI and Testament. This Will is dated March 7, 2002. This document lists the heirs to 2ND (9(8) 0F -B be Kelly J. Turner, Kendall F. Turner, and Kirk A. Turner. These are the three sons of AVE.. FX U1 decedent Betty 4AA...‘ ELLIOT 91786 J. Turner. OFFICES 808-7426 CA EUCLID O) 5. By contrast Petitioner Tzankov’s Petition, attaches a purported Last VWI And RIARC N. UPLAND, (909) V Testament purportedly dated April 1, 2017, which disinherited Objectors and names LAW 100 PH A m Tzankov executor. .4 CO 6. Objectors will file a Petition to Probate the aforementioned March 7, 2002 Will, THC a true and correct copy of which is attached to this Objection as Exhibit 2. 7. Paragraph d(1) of Tzankov’s Petition lists Personal PrOperty in the amount of $300,000.00. By contrast, the First and Final Account represents that “[t]he assets on hand do not exceed $166,250.00. (Exhibit 1, page 3, line 16). 8. Exhibit 1’s statement also necessarily excludes any real property owned by NNNNNNNN m‘dwm-FWNA decedent at the time of her death. Again, by contrast, Tzankov’s Petition lists Real Property worth $450,000.00. 9. The only real property previously owned by the decedent. Betty J. Turner was the property located at 10232 Lilac Rd, Oak Hills, CA 92344 (the address listed in 2 OBJECTION TO PETITION FOR PROBATE 0F BETTY J. TURNER