On August 02, 2023 a
Complaint,Petition
was filed
involving a dispute between
Acevado, Carol,
and
for Other Probate with at Least One Hearing
in the District Court of San Bernardino County.
Preview
ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
Marivel M. Zialcita, Esq. (SBN: 221827) COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
MMZ LAW, A Professional Corporation
341 W 1“ Street, Suite 100 8/2/2023 3:19 PM
Claremont, CA 91711 Munoz, DEPUTY
By: Sabrina
Phone (909) 256-6702
Fax (909) 256-6696
©®fl¢UIAOJNH
Email: marivel@mmzlawyer.com
Attorney for Carol Acevado, Petitioner
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO, PROBATE DIVISION
CORPORATION
100
91711
Carol Acevedo
SUITE
Case N0; PROSBZ300994
CA 256-6702
PROFESSIONAL
STREET,
Petitioner,
VERTIFIED PETITION FOR:
CLAREMONT, (909)
1ST
VS.
Aw 1. FINANCIAL ELDER ABUSE
LAW,
341 NNNNNNNNNHHh—tr—ah—tr—r—th—tr—th—t
Ashlee Acevedo Blais, Eric Maurice 2. UNJUST ENRICHMENT
Blais, and DOES 1-10 3. CONSTRUCTIVE FRAUD
MMZ
DATE;:£09713/2023
Respondents.
TIME; 9:00 am
OOQGNUIAUJNHOWQOQGUIAMNHG
DEPT: S36
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
Petitioner Carol Acevedo, by and through her attorney of record, Marivel Zialcita, alleges
the following:
///
///
///
VERTIFIED PETITION
I. PARTIES
1. Carol Acevedo ("Mrs. Acevedo" and/or "Petitioner" ) was at all times relevant to
this action, over the age of 65, making her an elder pursuant to )5610.27, and for purposes of
$ 15610.30, of the Welfare and Institutions Code.
2. Respondents, Ashlee Acevedo Blais ("Ashlee"), is an individual who resides in the
State of Texas and is the daughter of Carol Acevedo.
3. Respondent, Eric Maurice Blais (" Eric" ), is an individual, who resides in the State
of Texas. and is the son-in-law of Carol Acevedo
4. Larry Acevedo, Deceased, was the husband of Carol Acevedo and Father of Ashlee
opia-
10 Acevedo Blais.
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I
5. Petitioner is informed and believes, and on that basis alleges, that with reasonable
z0
oQ
CL
IL' 12 opportunity for future discovery, the evidence will show that Respondents Ashlee and Eric added
0
eN 13 themselves to the Grant Deed through undue influence.
zo w"o&
~ The true names and capacities of the respondents named herein as DOES through
2e
u&
(n +z w"
14 6. 1
g N
O
Q 15 10, inclusive, whether individual, corporate, or otherwise, are currently unknown to Petitioner.
o.~z~
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o 16 Petitioner therefore sues such respondents by fictitious names pursuant to I'1474 of the Code of
17 Civil Procedure. Petitioner is informed and believes, and on that basis alleges, each of the
N
K 18 fictitiously named respondents is responsible in some manner for the occurrences alleged herein,
19 and that the fictitiously named respondents'onduct proximately caused the damages alleged
20 herein. Petitioner will amend this Complaint to identify the true names and capacities of each of
21 the fictitiously named respondents when such names and capacities have been determined.
22
23 II. VENUE, JURISDICTION & STANDING
24 7. Pursuant to Probate Code )17005, subdivision (a)(1), the proper county for
25 commencement of a proceeding of this nature
26 8. Petitioner resides in San Bernardino, making this county the principal place of
27 administration and the proper place to commence this action.
28 III. FACTUAL BACKGROUND
2
VERTIFIED PETITION
Document Filed Date
August 02, 2023
Case Filing Date
August 02, 2023
Category
Other Probate with at Least One Hearing
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ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA Marivel M. Zialcita, Esq. (SBN: 221827) COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT MMZ LAW, A Professional Corporation 341 W 1“ Street, Suite 100 8/2/2023 3:19 PM Claremont, CA 91711 Munoz, DEPUTY By: Sabrina Phone (909) 256-6702 Fax (909) 256-6696 ©®fl¢UIAOJNH Email: marivel@mmzlawyer.com Attorney for Carol Acevado, Petitioner SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO, PROBATE DIVISION CORPORATION 100 91711 Carol Acevedo SUITE Case N0; PROSBZ300994 CA 256-6702 PROFESSIONAL STREET, Petitioner, VERTIFIED PETITION FOR: CLAREMONT, (909) 1ST VS. Aw 1. FINANCIAL ELDER ABUSE LAW, 341 NNNNNNNNNHHh—tr—ah—tr—r—th—tr—th—t Ashlee Acevedo Blais, Eric Maurice 2. UNJUST ENRICHMENT Blais, and DOES 1-10 3. CONSTRUCTIVE FRAUD MMZ DATE;:£09713/2023 Respondents. TIME; 9:00 am OOQGNUIAUJNHOWQOQGUIAMNHG DEPT: S36 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: Petitioner Carol Acevedo, by and through her attorney of record, Marivel Zialcita, alleges the following: /// /// /// VERTIFIED PETITION I. PARTIES 1. Carol Acevedo ("Mrs. Acevedo" and/or "Petitioner" ) was at all times relevant to this action, over the age of 65, making her an elder pursuant to )5610.27, and for purposes of $ 15610.30, of the Welfare and Institutions Code. 2. Respondents, Ashlee Acevedo Blais ("Ashlee"), is an individual who resides in the State of Texas and is the daughter of Carol Acevedo. 3. Respondent, Eric Maurice Blais (" Eric" ), is an individual, who resides in the State of Texas. and is the son-in-law of Carol Acevedo 4. Larry Acevedo, Deceased, was the husband of Carol Acevedo and Father of Ashlee opia- 10 Acevedo Blais. z 0 I 5. Petitioner is informed and believes, and on that basis alleges, that with reasonable z0 oQ CL IL' 12 opportunity for future discovery, the evidence will show that Respondents Ashlee and Eric added 0 eN 13 themselves to the Grant Deed through undue influence. zo w"o& ~ The true names and capacities of the respondents named herein as DOES through 2e u& (n +z w" 14 6. 1 g N O Q 15 10, inclusive, whether individual, corporate, or otherwise, are currently unknown to Petitioner. o.~z~ j~ Q à o 16 Petitioner therefore sues such respondents by fictitious names pursuant to I'1474 of the Code of 17 Civil Procedure. Petitioner is informed and believes, and on that basis alleges, each of the N K 18 fictitiously named respondents is responsible in some manner for the occurrences alleged herein, 19 and that the fictitiously named respondents'onduct proximately caused the damages alleged 20 herein. Petitioner will amend this Complaint to identify the true names and capacities of each of 21 the fictitiously named respondents when such names and capacities have been determined. 22 23 II. VENUE, JURISDICTION & STANDING 24 7. Pursuant to Probate Code )17005, subdivision (a)(1), the proper county for 25 commencement of a proceeding of this nature 26 8. Petitioner resides in San Bernardino, making this county the principal place of 27 administration and the proper place to commence this action. 28 III. FACTUAL BACKGROUND 2 VERTIFIED PETITION