On November 24, 2020 a
Complaint,Petition
was filed
involving a dispute between
Harris, Ray,
Harris, Roderick,
and
for Trust
in the District Court of San Bernardino County.
Preview
r
Scott J Sheldon SBN 290258
SUPERIOR COURT OF CALIFORNIA
1
Law Office of Scott J Sheldon
GpN NARDIN ID STR ICT
2 10788 Civic Center Drive
Rancho Cucamonga CA 91730
NOV 2 4 ZOZo
3 Telephone 909 660 3062
Email scottsheldon@sheldonlawgroup com gy
4
y
A RAZO DEPUTY
5 Attorney for Petitioners
RODERICK HARRIS and RAY HARRIS
6
7
ci g
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
COUNTY OF SAN BERNARDINO
10
In re Case No
11
THE ALFRED D HARRIS REVOCABLE
12
TRUST est February 2 2016 PETITION FOR
13 1 FINANCIAL ELDER ABUSE
Welf Inst Code 15610 30
14 2 INVALIDATE TRUST
RODERICK HARRIS and individual and RAY Prob Code 17200 850
15
HARRIS an individual 3 ACCOUNTING
16
Petitioners
1
1g S
Hearing Date i I l r I2
19 NORMAN HARRIS CARDELL Time a
aJk a Gi
HARRIS an individual and DOES 1 to 20 Department
20 S
t f S
n
Respondents
ase is assigned to Dept S
21 N J E fiis 7
22 for all purposes and is subject to CP 170 6 2
23
COMES NOW Petitioners RODERICK HARRIS and RAY HARRIS and allege the following
24 1 Decedent Alfred D Harris died on or about August 15 2020
25 hereinafter RODERICK
2 Petitioner RODERICK HARRIS and collectively with RAY
26 HARRIS referred to as Petitioner ar Petitioners is the son of Decedent
27 hereinafter RAY
3 Petitioner RAY HARRIS and collectively with RODERICK HARRIS
28 referred to as Petitioner or Petitioners is the son of Decedent
1
PETITION TO INVALIDATE TRUST AND FOR FINANCIAL ELDER ABUSE
1 4 Respondent NORMAN HARRIS aJk a CARDELL HARRIS hereinafter NORMAN or
2 Respondent is the son of Decedent
3 5 The true names and capacities of Respondents DOES 1 to 10 are unknown to Petitioners and
4 Petitioners will seek leave of the court to amend this complaint to allege such names and capacities as
5 soon as they are ascertained
6 6 On or about October 4 2020 Petitioners received a two 2 page letter from Tanya L Willis Esq
7 titled Notification of Trustee Under Probate Code Section 16061 7 A true and correct copy of this
8 letter is attached hereto as Exhibit A
9 7 Along with this letter Petitioners received a copy of THE ALFRED D HARRIS REVOCABLE
10 TRUST est
February 2 2016 hereinafter the Trust A true and correct copy of this Trust is attached
11 hereto as E ibit B
12 8 Petitioners are informed and believe and thereupon allege that the Trust does not reflect the true
13 and accurate wishes of Decedent
14
15 ELDER FINANCIAL ABUSE
16 RODERICK HARRIS and RAY HARRIS v NORMAN HARRIS and DOES 1 to 20
17 Welf Inst Code 15610 30
18 9 Petitioners restate and incorporate each of the faregoing allegations of this Petition as if set forth
19 herein
20 10 Petitioners are informed and believe and thereupon allege NORMAN took hid or retained the
21 assets and property of Decedent and attempted to take hide appropriate and retain the real property
22 commonly known as 21085 Hicks Street Perris CA 92570 by causing Decedent to execute the THE
23 ALFRED D HARRIS REVOCABLE TRUST hereinafter the Trust on or about February 2 2016
24 depriving Descendent of the ability to dispose of his assets and the title to his real property in accordance
25 with Decedent s wishes
26 11 At all relevant times Decedent was 65 years of age or older and an Elder as defined by Welfare
27 and Institutions Code section 15610 27
28 12 Decedent was harmed in that he was deprived of making disposition of his assets in accordance
2
PETITION TO INVALIDATE TRUST AND FOR FINANCIAL ELDER ABUSE
Document Filed Date
November 24, 2020
Case Filing Date
November 24, 2020
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r Scott J Sheldon SBN 290258 SUPERIOR COURT OF CALIFORNIA 1 Law Office of Scott J Sheldon GpN NARDIN ID STR ICT 2 10788 Civic Center Drive Rancho Cucamonga CA 91730 NOV 2 4 ZOZo 3 Telephone 909 660 3062 Email scottsheldon@sheldonlawgroup com gy 4 y A RAZO DEPUTY 5 Attorney for Petitioners RODERICK HARRIS and RAY HARRIS 6 7 ci g SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SAN BERNARDINO 10 In re Case No 11 THE ALFRED D HARRIS REVOCABLE 12 TRUST est February 2 2016 PETITION FOR 13 1 FINANCIAL ELDER ABUSE Welf Inst Code 15610 30 14 2 INVALIDATE TRUST RODERICK HARRIS and individual and RAY Prob Code 17200 850 15 HARRIS an individual 3 ACCOUNTING 16 Petitioners 1 1g S Hearing Date i I l r I2 19 NORMAN HARRIS CARDELL Time a aJk a Gi HARRIS an individual and DOES 1 to 20 Department 20 S t f S n Respondents ase is assigned to Dept S 21 N J E fiis 7 22 for all purposes and is subject to CP 170 6 2 23 COMES NOW Petitioners RODERICK HARRIS and RAY HARRIS and allege the following 24 1 Decedent Alfred D Harris died on or about August 15 2020 25 hereinafter RODERICK 2 Petitioner RODERICK HARRIS and collectively with RAY 26 HARRIS referred to as Petitioner ar Petitioners is the son of Decedent 27 hereinafter RAY 3 Petitioner RAY HARRIS and collectively with RODERICK HARRIS 28 referred to as Petitioner or Petitioners is the son of Decedent 1 PETITION TO INVALIDATE TRUST AND FOR FINANCIAL ELDER ABUSE 1 4 Respondent NORMAN HARRIS aJk a CARDELL HARRIS hereinafter NORMAN or 2 Respondent is the son of Decedent 3 5 The true names and capacities of Respondents DOES 1 to 10 are unknown to Petitioners and 4 Petitioners will seek leave of the court to amend this complaint to allege such names and capacities as 5 soon as they are ascertained 6 6 On or about October 4 2020 Petitioners received a two 2 page letter from Tanya L Willis Esq 7 titled Notification of Trustee Under Probate Code Section 16061 7 A true and correct copy of this 8 letter is attached hereto as Exhibit A 9 7 Along with this letter Petitioners received a copy of THE ALFRED D HARRIS REVOCABLE 10 TRUST est February 2 2016 hereinafter the Trust A true and correct copy of this Trust is attached 11 hereto as E ibit B 12 8 Petitioners are informed and believe and thereupon allege that the Trust does not reflect the true 13 and accurate wishes of Decedent 14 15 ELDER FINANCIAL ABUSE 16 RODERICK HARRIS and RAY HARRIS v NORMAN HARRIS and DOES 1 to 20 17 Welf Inst Code 15610 30 18 9 Petitioners restate and incorporate each of the faregoing allegations of this Petition as if set forth 19 herein 20 10 Petitioners are informed and believe and thereupon allege NORMAN took hid or retained the 21 assets and property of Decedent and attempted to take hide appropriate and retain the real property 22 commonly known as 21085 Hicks Street Perris CA 92570 by causing Decedent to execute the THE 23 ALFRED D HARRIS REVOCABLE TRUST hereinafter the Trust on or about February 2 2016 24 depriving Descendent of the ability to dispose of his assets and the title to his real property in accordance 25 with Decedent s wishes 26 11 At all relevant times Decedent was 65 years of age or older and an Elder as defined by Welfare 27 and Institutions Code section 15610 27 28 12 Decedent was harmed in that he was deprived of making disposition of his assets in accordance 2 PETITION TO INVALIDATE TRUST AND FOR FINANCIAL ELDER ABUSE