On September 26, 2011 a
Motion-Secondary
was filed
involving a dispute between
Corrales, Gilbert,
Corrales, Lorraine,
and
for Trust
in the District Court of San Bernardino County.
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1 Steven Urenda SBN 310849
Uf E z R C U
GAUDY LAW INC cou r r t
i OF C iti a
2 s
r
tv R yrr
267 D Street a
r
Upland California 91786
3 P 2 h 201
P 909 982 3199 F 909 946 9449
4 steven@gaudylaw com Y ry
1
i tifVil
5 Fr 1 t
Attomeys for Respondent
6 Lorraine Corrales
8
SUPERIOR COURT OF CALIFORNIA
9
COUNTY OF SAN BERNARDINO
10
1
IN THE MAT TER OF CASE NO PROPS 1100680
t2
OBJECTIONS TO PETITION TO FOR
13
Pete G Corrales and Carmen C Corrales 1 AN IMMEDIATE ORDER THAT
t4
Revocable Trust LORRAINE CORRALES NOT USE TRUST
15
FUNDS TO PAY FOR THE DEFENSE OF
THIS ACTION
16 2 AN IMMEDIATE ORDER THAT
LORRAINE CORRALES PREPARE A
i
FORMAL ACCOUNTING
3 AN ORDER THAT LORRAINE
lg
CORRALES DISTRIBUTE TRUST ASSETS
19 TO GILBERT CORRALES
4 DAMAGES DUE TO LORRAINE
20
CORRALES BREACH OF TRUST AND
FAILURE TO DISTRIBUTE ASSETS
21
22
Respondent Lorraine Corrales objects to Petitioner s Petition as follows
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1 Respondent admits the allegations contained in Paragraph 1 of the Petition
24
2 Respondent adrnits the allegations contained in Paragraph 2 ofthe Petition
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3 Respondent objects to all allegations or assertions contained in paragraph 3 of the Petition T6e
26
27 Trust was extinguished pursuant to an intrafamily agreement between Petitioner and Respondent
28 Pursuant to that agreement Respondent was to manage Petitioner s share of the Trust procezds in
1 E Y FAX
OBJECTIONS TO PETITION TO FOR 1 AN IMMEDIATE ORDER THAT LORRAINE CORALES NOT USE
TRUST FUNDS TO PAY FOR THE DEFENSE OF THIS ACTION ET AL
1
a mutual fund with Petitioner receiving monthly distributions The purpose of that agreement
2
was for Respondent to manage Petitioner s finances due to Petitioner s inability stemming from
3
his long history of substance abuse and the substantial child support and tax liabilities Petitioner
4
owed and presumably still owes
5
4 Respondent admits atl allegations contained in Paragraph 4 of the Petition
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5 Respondent admits all allegations contained in Paragraph 5 ofthe Petition
7
6 Respondent objects to all allegations or assertions contained in Paragraph 6 ofthe Petition
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7 Respondent objects to all allegations or assertions contained in Paragraph 7 of the Petition
9
g Respondent objects to all allegations or assertions contained in Paragraph 8 of the Petition
10
11 9 Respondent objects to all allegations or assertions contained in Paragraph 9 of the Petition
12 Petitioner s puerile insistence that he is a financial prisoner of Respondent ignores that he
13
agreed to have Respondent manage his assets to receive monthly distributions at a set amount
14
d that he has not made any request for sums above the agreed upon monthly distribution If
15
client desired additional funds atl he had to do was simply ask Respondent
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10 Respondent objects to all allegations or assertions contained in Paragraph 10 ofthe Petition
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11 Respondent objects to all allegations or assertions contained in Paragraph 12 ofthe Petition
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WHEREFORE Petitioner prays the court make an order
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1 Denying Petitioner s request that Lorraine Corrales be prohibited from using Trust assets to pay
21
22 for her defense in this action
23 2 Denying Petitioner s request for an accounting
24 3 In the alternative the court limit the accounting period to the period beginning on the death of the
25
second settlor to the date of the parties execution of the intrafamily agreement
26
4 Denying Petitioner s request for ordering distributing assets or the equivalent damages to
27
Petitioner
28
5
Denying Petitioner s request for double damages under Probate Code section 859
2
OBJECTIONS TO PETITION TO FOR 1 AN IMMEDIATE ORDER THAT LORRAINE CORALES NOT USE
TRUST FUNDS TO PAY FOR THE DEFENSE OF THIS ACTION ET AL
Document Filed Date
September 25, 2019
Case Filing Date
September 26, 2011
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1 Steven Urenda SBN 310849 Uf E z R C U GAUDY LAW INC cou r r t i OF C iti a 2 s r tv R yrr 267 D Street a r Upland California 91786 3 P 2 h 201 P 909 982 3199 F 909 946 9449 4 steven@gaudylaw com Y ry 1 i tifVil 5 Fr 1 t Attomeys for Respondent 6 Lorraine Corrales 8 SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF SAN BERNARDINO 10 1 IN THE MAT TER OF CASE NO PROPS 1100680 t2 OBJECTIONS TO PETITION TO FOR 13 Pete G Corrales and Carmen C Corrales 1 AN IMMEDIATE ORDER THAT t4 Revocable Trust LORRAINE CORRALES NOT USE TRUST 15 FUNDS TO PAY FOR THE DEFENSE OF THIS ACTION 16 2 AN IMMEDIATE ORDER THAT LORRAINE CORRALES PREPARE A i FORMAL ACCOUNTING 3 AN ORDER THAT LORRAINE lg CORRALES DISTRIBUTE TRUST ASSETS 19 TO GILBERT CORRALES 4 DAMAGES DUE TO LORRAINE 20 CORRALES BREACH OF TRUST AND FAILURE TO DISTRIBUTE ASSETS 21 22 Respondent Lorraine Corrales objects to Petitioner s Petition as follows 23 1 Respondent admits the allegations contained in Paragraph 1 of the Petition 24 2 Respondent adrnits the allegations contained in Paragraph 2 ofthe Petition 25 3 Respondent objects to all allegations or assertions contained in paragraph 3 of the Petition T6e 26 27 Trust was extinguished pursuant to an intrafamily agreement between Petitioner and Respondent 28 Pursuant to that agreement Respondent was to manage Petitioner s share of the Trust procezds in 1 E Y FAX OBJECTIONS TO PETITION TO FOR 1 AN IMMEDIATE ORDER THAT LORRAINE CORALES NOT USE TRUST FUNDS TO PAY FOR THE DEFENSE OF THIS ACTION ET AL 1 a mutual fund with Petitioner receiving monthly distributions The purpose of that agreement 2 was for Respondent to manage Petitioner s finances due to Petitioner s inability stemming from 3 his long history of substance abuse and the substantial child support and tax liabilities Petitioner 4 owed and presumably still owes 5 4 Respondent admits atl allegations contained in Paragraph 4 of the Petition 6 5 Respondent admits all allegations contained in Paragraph 5 ofthe Petition 7 6 Respondent objects to all allegations or assertions contained in Paragraph 6 ofthe Petition 8 7 Respondent objects to all allegations or assertions contained in Paragraph 7 of the Petition 9 g Respondent objects to all allegations or assertions contained in Paragraph 8 of the Petition 10 11 9 Respondent objects to all allegations or assertions contained in Paragraph 9 of the Petition 12 Petitioner s puerile insistence that he is a financial prisoner of Respondent ignores that he 13 agreed to have Respondent manage his assets to receive monthly distributions at a set amount 14 d that he has not made any request for sums above the agreed upon monthly distribution If 15 client desired additional funds atl he had to do was simply ask Respondent 16 10 Respondent objects to all allegations or assertions contained in Paragraph 10 ofthe Petition 17 11 Respondent objects to all allegations or assertions contained in Paragraph 12 ofthe Petition 18 19 WHEREFORE Petitioner prays the court make an order 20 1 Denying Petitioner s request that Lorraine Corrales be prohibited from using Trust assets to pay 21 22 for her defense in this action 23 2 Denying Petitioner s request for an accounting 24 3 In the alternative the court limit the accounting period to the period beginning on the death of the 25 second settlor to the date of the parties execution of the intrafamily agreement 26 4 Denying Petitioner s request for ordering distributing assets or the equivalent damages to 27 Petitioner 28 5 Denying Petitioner s request for double damages under Probate Code section 859 2 OBJECTIONS TO PETITION TO FOR 1 AN IMMEDIATE ORDER THAT LORRAINE CORALES NOT USE TRUST FUNDS TO PAY FOR THE DEFENSE OF THIS ACTION ET AL