Motion-Secondary: CHARLES, RUDOLPH - DECEDENT

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                                Electronically FILED by Superior Court of California, County of Los Angeles 4/27/2021 5:43 PM Sherri R. Carter, Executive Officer/Clerk, By Herman Tam, Deputy Clerk




                   1    Robert T Downs (SBN 232173)
                        Rebecca L. T. Schroff, A Law Corporation
                  2     21515 Hawthorne Boulevard, Suite 490
                        Torrance, CA 90503-6511
                  3     Telephone: (310) 540-8855
                        Facsimile: (310) 316-1307
                  4     E-mail: robert@mbsllp.com
                  5     Attorneys for:         Farmers & Merchants Trust Company
                                               of Long Beach, as trustee
                  6
                  7
                  8
                  9                               SUPERIOR COURT OF THE STATE OF CALIFORNIA
                 10                                         FOR THE COUNTY OF LOS ANGELES
                 11
                 12     In re the matter of:                                                1   Case No.: 18STPB02362
                                                                                            1   Related to Case No.: 17STPB10990
                 13                                                                         I
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                 14       THE ESTATE OF RUDOLPH CHARLES                                     1   Hearing:
                                                                                                 Date: April 28, 2021
                 15                                                                              Time: 8:30 a.m.
                                                                                                 Dept.: 67
                                                                                        '
                 16
                                                                                          TRUSTEE FARMERS AND
                 17                                                                       MERCHANTS TRUST COMPANY OF
                                                                                        ' LONG BEACH'S OPPOSITION TO
                 18                                                                       SPECIAL ADMINISTRATORS' EX
                                                                                          PARTE PETITION FOR
                 19                                                                     ' WITHDRAW AL OF FUNDS FROM
                                                                                        ) BLOCKED ACCOUNT; DECLARATION
                 20                                                                       OF ROBERT T. DOWNS IN SUPPORT
                                                                                          THEREOF
                 21
                                                                                                Judge: Honorable Daniel Juarez
                 22
                 23               Farmers and Merchants Trust Company of Long Beach ("Trustee"), as trustee of the
                24      Rudolph Charles 2010 Trust dated April 22, 2010, as amended and restated on June 28, 2014
                 25     ("the Trust") hereby opposes the Ex Parte Petition to Withdraw Funds from Blocked Account,
                 26     which was filed by the Special Administrators of the Estate of Rudolph Charles, Katherine
                 27     Kirkman and Frederick Williams (collectively "Special Administrators") on or about April 27,
                 28     2021.

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                            TRUSTEE FARMERS AND MERCHANTS TRUST COMPANYOF LONG BEACH'S OPPOSITION TO
                          SPECIAL ADMINISTRATORS' EX PARTE PETITION FOR WITHDRAWAL OF FUNDS FROMBLOCKED
                                  ACCOUNT; DECLARATION OF ROBERT     T. DOWNS IN SUPPORT THEREOF