On October 14, 2021 a
Complaint,Petition
was filed
involving a dispute between
Abujudeh, Hani,
and
for Trust
in the District Court of San Bernardino County.
Preview
\a
1 MATTHEW E. SHEASBY (SBN 197217) F LE
SHEASBY AND ASSOCIATES i
SUPERIOR COURT 0F
CALIFORNIA
9227 Haven Avenue, Suite 280 09mm 0F SAN BERNARDINO
VDAN RSPNARDINQ
Rancho Cucamonga, CA 91730 DISTRICT
Telephone: (909) 922-2543
Facsimile: (909) 922-2544 NOV 1 5 2022
Attorney for Petitioner, Hani Abujudeh mm 7%
NATHAN:
fit”..._...__
.JOHNSON,DEPLm
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
10
In the Matter of The Abujudeh Famil
y
Case No.2 TRUSB2100 1 50
11
Revocable Living Trust dated March 19, 2004 PETITION:
12 1. FOR REMOVAL OF
HANI ABUJUDEH, TRUSTEE, RIHAM HILO
13
PLAINTIFF,
AS TRUSTEE OF THE
14 TRUST;
V 2. APPOINTMENT OF
15 RIHAM HILO, an individual; RIHAM HILO PROFESSIONAL
AS TRUSTEE OF THE ABUIUDEH SUCCESSOR TRUSTEE
16
FAMILY REVOCABLE LIVING TRUST 3. RETURN 0F FUNDS
17 DATED MARCH 19, 2004 AND DERIVED FROM SALE OF
AMENDMENTS; RAJA KAKISH; an REAL PROPERTY;
18 individual; JACOB HILO (AKA JACO
UB ACCOUNTING;
HILO), an individual; TRUSTEES OF THE 99'?
CONSTRUCTIVE TRUST;
19
JACOB AND RIHAM HILO REVOCABLE BREACH OF FIDUCIARY
20 LIVING TRUST DATED JANUARY 29, DUTY;
2004; DOES 1-10. 7. PROABTE CODE 850
21 8. ELDER ABUSE
9. FRAUD
22
23 [PROBATE CODE 259, 850, 859,
15642; WELFARE AND
24 INSTITUTIONS CODE 15610]
25
Date: 01/26/23
Time: 9:00 am
26
Dept: S36
27
28
1
PETITION
V V
1
TO THE HONORABLE COURT, THE PARTIES, AND THEIR RESPECTIVE
ATTORNEYS OF RECORD:
Petitioner, Hani Abujudeh, by and through his attorney of record, Matthew E.
Sheasby,
hereby submits this Petition to for the following relief:
1. For Removal of Trustee, Riham Hilo as Trustee of the “Abujudeh
Family Revocable
Living Trust dated March 19, 2004” (the Trust);
For appointment of a successor professional trustee.
. Petition For Return of Funds Derived from the sale of the Real Property at O Cypress
10
Way, Redlands, California, as to Defendants Riham Hilo and Riham Hilo, Trustee;
11
12 Petition For Accounting of monies received from sale of the Real Property at 0 Cypress
13
Way, Redlands, California, as to Defendants Riham Hilo and Riham Hilo, Trustee;
l4
. Petition For Constructive Trust, as to Defendants,
Raja Kakish; Raja Kakish, Trustee;
15
Riham Hilo; Jacob Hilo; and Trustees of the Jacob and Riham Hilo
Revocable living
16
Trust dated January 29, 2004;
17
18 Petition for Breach of Fiduciary Duty as to Defendants, Riham Hilo and Riham Hilo,
19 Trustee;
20
Petition For Elder Abuse as to Defendants, Raja Kakish; Raja Kakish, Truste
e; Riham
21
Hilo; Jacob Hilo; and Trustees of the Jacob and Riham Hilo Revocable living Trust dated
22
January 29, 2004;
23
24 Petition for Fraud as t0 Defendants, Defendants,
Raja Kakish; Raja Kakish, Trustee;
25 Riham Hilo; Jacob Hilo; and Trustees of the Jacob and Riham Hilo Revocable living
26
Trust dated January 29, 2004;
27
///
28
2
PETITION
Document Filed Date
November 15, 2022
Case Filing Date
October 14, 2021
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
\a 1 MATTHEW E. SHEASBY (SBN 197217) F LE SHEASBY AND ASSOCIATES i SUPERIOR COURT 0F CALIFORNIA 9227 Haven Avenue, Suite 280 09mm 0F SAN BERNARDINO VDAN RSPNARDINQ Rancho Cucamonga, CA 91730 DISTRICT Telephone: (909) 922-2543 Facsimile: (909) 922-2544 NOV 1 5 2022 Attorney for Petitioner, Hani Abujudeh mm 7% NATHAN: fit”..._...__ .JOHNSON,DEPLm IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO 10 In the Matter of The Abujudeh Famil y Case No.2 TRUSB2100 1 50 11 Revocable Living Trust dated March 19, 2004 PETITION: 12 1. FOR REMOVAL OF HANI ABUJUDEH, TRUSTEE, RIHAM HILO 13 PLAINTIFF, AS TRUSTEE OF THE 14 TRUST; V 2. APPOINTMENT OF 15 RIHAM HILO, an individual; RIHAM HILO PROFESSIONAL AS TRUSTEE OF THE ABUIUDEH SUCCESSOR TRUSTEE 16 FAMILY REVOCABLE LIVING TRUST 3. RETURN 0F FUNDS 17 DATED MARCH 19, 2004 AND DERIVED FROM SALE OF AMENDMENTS; RAJA KAKISH; an REAL PROPERTY; 18 individual; JACOB HILO (AKA JACO UB ACCOUNTING; HILO), an individual; TRUSTEES OF THE 99'? CONSTRUCTIVE TRUST; 19 JACOB AND RIHAM HILO REVOCABLE BREACH OF FIDUCIARY 20 LIVING TRUST DATED JANUARY 29, DUTY; 2004; DOES 1-10. 7. PROABTE CODE 850 21 8. ELDER ABUSE 9. FRAUD 22 23 [PROBATE CODE 259, 850, 859, 15642; WELFARE AND 24 INSTITUTIONS CODE 15610] 25 Date: 01/26/23 Time: 9:00 am 26 Dept: S36 27 28 1 PETITION V V 1 TO THE HONORABLE COURT, THE PARTIES, AND THEIR RESPECTIVE ATTORNEYS OF RECORD: Petitioner, Hani Abujudeh, by and through his attorney of record, Matthew E. Sheasby, hereby submits this Petition to for the following relief: 1. For Removal of Trustee, Riham Hilo as Trustee of the “Abujudeh Family Revocable Living Trust dated March 19, 2004” (the Trust); For appointment of a successor professional trustee. . Petition For Return of Funds Derived from the sale of the Real Property at O Cypress 10 Way, Redlands, California, as to Defendants Riham Hilo and Riham Hilo, Trustee; 11 12 Petition For Accounting of monies received from sale of the Real Property at 0 Cypress 13 Way, Redlands, California, as to Defendants Riham Hilo and Riham Hilo, Trustee; l4 . Petition For Constructive Trust, as to Defendants, Raja Kakish; Raja Kakish, Trustee; 15 Riham Hilo; Jacob Hilo; and Trustees of the Jacob and Riham Hilo Revocable living 16 Trust dated January 29, 2004; 17 18 Petition for Breach of Fiduciary Duty as to Defendants, Riham Hilo and Riham Hilo, 19 Trustee; 20 Petition For Elder Abuse as to Defendants, Raja Kakish; Raja Kakish, Truste e; Riham 21 Hilo; Jacob Hilo; and Trustees of the Jacob and Riham Hilo Revocable living Trust dated 22 January 29, 2004; 23 24 Petition for Fraud as t0 Defendants, Defendants, Raja Kakish; Raja Kakish, Trustee; 25 Riham Hilo; Jacob Hilo; and Trustees of the Jacob and Riham Hilo Revocable living 26 Trust dated January 29, 2004; 27 /// 28 2 PETITION