On March 24, 2023 a
Complaint,Petition
was filed
involving a dispute between
Morris, Christopher,
and
for Trust
in the District Court of San Bernardino County.
Preview
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F L
Priscilla C. Solario, Esq. (State Bar No.1 259607)
l
SUPERIOR Court gg
county 0F SAN seam Dmo
ORMA
9431 Haven Avenue moans DEPT.
Suite 108
Rancho Cucamonga, CA 91730 MAY 08 2023
Telephone: (909) 529-1011
Facsimile: (866)442-6404
BY: VALERIE GOLDSTEIN, Deputy
Attorney for Lisa Bonnell
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN BERNARDINO
Case No.: TRUSBZBOOO64
IN RE:
IN OPPOSITION TO CHRISTOPHER
10
THE FIRST AMENDMENT TO AND MORRIS’ PETITION FOR 1)
REMOVAL OF TRUSTEE; 2)
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THE MORRIS TRUST AS AMENDED APPOINTMENT OF SUCCESSOR
TRUSTEE; 3) INSTRUCTION FOR
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DISTRIBUTION; 4) DIVISION OF
AND RESTATED TRUST; 5) ACCOUNTING AND 6)
13
CONVERSION
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DATE: May 5, 2023
TIME: 9:00 a.m.
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DEPT: S36
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COMES NOW, Objector Lisa Bonnell and and submits the following
Opposition to Christopher Morris’ Petition For 1) Removal of Trustee; 2)
18
Appointment of Successor Trustee; 3) Instruction for Distribution; 4) Division of
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Trust; 5) Accounting and 6) Conversion as follows:
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GENERAL ALLEGATIONS
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1. In response to Paragraph 1 of the Petition, Respondent admits the
24
allegations contained therein.
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2. In response to Paragraph 2 of the Petition, Respondent admits the
allegations contained therein.
3. In response to Paragraph 3 of the Petition, Respondent admits the
allegations contained therein.
4. In response to Paragraph 4 of the Petition, Respondent admits the
allegations contained therein.
5. In response to Paragraph 5 of the Petition, Respondent admits the
allegations contained therein.
6. Respondent does not have adequate information or belief to enable
10 him to respond to the allegations stated in Paragraph 6 of the Petition, and based on
11 such lack of information or belief, Respondent denies generally and specifically the
12 allegations contained therein.
13 7. Respondent denies generally and specifically each and every
14 allegation contained in Paragraph 7 of the Petition as the referenced attachment was
15 not attached to the Petition that was sewed.
16 8. Respondent denies generally and specifically each and every
17 allegation contained in Paragraph 8 of the Petition as the referenced attachment was
18 not attached to the Petition that was sewed.
19 9. In response to Paragraph 9 of the Petition, Respondent admits that
20 she wis the sole Trustee pursuant to the terms of the Trust. Except as specifically
21 admitted above, Respondent denies generally and specifically each and every other
22 allegation contained in Paragraph 9 of the Petition.
23 10. Respondent does not have adequate information or belief to enable
24 her to respond to the allegations stated Paragraph 1O of the
in Petition, and based
25
Document Filed Date
May 08, 2023
Case Filing Date
March 24, 2023
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V F L Priscilla C. Solario, Esq. (State Bar No.1 259607) l SUPERIOR Court gg county 0F SAN seam Dmo ORMA 9431 Haven Avenue moans DEPT. Suite 108 Rancho Cucamonga, CA 91730 MAY 08 2023 Telephone: (909) 529-1011 Facsimile: (866)442-6404 BY: VALERIE GOLDSTEIN, Deputy Attorney for Lisa Bonnell SUPERIOR COURT FOR THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO Case No.: TRUSBZBOOO64 IN RE: IN OPPOSITION TO CHRISTOPHER 10 THE FIRST AMENDMENT TO AND MORRIS’ PETITION FOR 1) REMOVAL OF TRUSTEE; 2) 11 THE MORRIS TRUST AS AMENDED APPOINTMENT OF SUCCESSOR TRUSTEE; 3) INSTRUCTION FOR 12 DISTRIBUTION; 4) DIVISION OF AND RESTATED TRUST; 5) ACCOUNTING AND 6) 13 CONVERSION 14 DATE: May 5, 2023 TIME: 9:00 a.m. 15 DEPT: S36 16 17 COMES NOW, Objector Lisa Bonnell and and submits the following Opposition to Christopher Morris’ Petition For 1) Removal of Trustee; 2) 18 Appointment of Successor Trustee; 3) Instruction for Distribution; 4) Division of 19 Trust; 5) Accounting and 6) Conversion as follows: 20 21 22 GENERAL ALLEGATIONS 23 1. In response to Paragraph 1 of the Petition, Respondent admits the 24 allegations contained therein. 25 2. In response to Paragraph 2 of the Petition, Respondent admits the allegations contained therein. 3. In response to Paragraph 3 of the Petition, Respondent admits the allegations contained therein. 4. In response to Paragraph 4 of the Petition, Respondent admits the allegations contained therein. 5. In response to Paragraph 5 of the Petition, Respondent admits the allegations contained therein. 6. Respondent does not have adequate information or belief to enable 10 him to respond to the allegations stated in Paragraph 6 of the Petition, and based on 11 such lack of information or belief, Respondent denies generally and specifically the 12 allegations contained therein. 13 7. Respondent denies generally and specifically each and every 14 allegation contained in Paragraph 7 of the Petition as the referenced attachment was 15 not attached to the Petition that was sewed. 16 8. Respondent denies generally and specifically each and every 17 allegation contained in Paragraph 8 of the Petition as the referenced attachment was 18 not attached to the Petition that was sewed. 19 9. In response to Paragraph 9 of the Petition, Respondent admits that 20 she wis the sole Trustee pursuant to the terms of the Trust. Except as specifically 21 admitted above, Respondent denies generally and specifically each and every other 22 allegation contained in Paragraph 9 of the Petition. 23 10. Respondent does not have adequate information or belief to enable 24 her to respond to the allegations stated Paragraph 1O of the in Petition, and based 25