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_.L
Marc E. Grossman (SBN 197627)
F LED l
James T. Lee (SBN 110838) SUPERIOR
ooumOFcAup
100 North Euclid Ave, 2nd Floor COUWOFSAN eenmnémg"
UpIand, CA 91786
Phone: (909) 608—7426 OCT 12 2023
Fax: (909) 949-01 19
Email: info@wefight4you.com
iim@wefight4you.com
BY:
m
9W“ VWUOO. D‘Puty
OQOWNOUU'ILOON
Attorney for Kendall F. Turner, Kelly James Turner
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
A
A A
GROSSMAN
A N
949-0119
In re the:
FLOOR
A (JO
Case No. PROSBZZOO416
OF
2ND (909)
_\
A Estate 0f Betty J. Turner. DECLARATION OF KENDALL F.
AVE., FX
TURNER IN REPLY TO VICTOR
ELLIOT
91786
A
(J'l Decedent TZANKOV’S VARIOUS PLEADINGS
OFFICES
EUCLID
CA
608-7426
_A C) Date: October 19, 2023
Time: 9:00 a.m.
N. UPLAND,
(909)
A N Dept: F3
MARC
LAW
100
PH
_\
(Cm
m6 Ea
A
DECLARATION OF KENDALL F. TURNER
NO l, Kendall F. Turner do hereby declare as follows:
1. That I am an individual over 18 years of age and have personal first-hand
knowledge of the following facts, except those that are stated on information and belief
and as to those facts, believe them to be true.
mem-hQJNA
2. That | am the son of the decedent, Betty Joan Turner. On May 23, 2022,
NNNNNNNN
this Court appointed myself and my brother Kelly J. Turner as Special Administrators
of the Estate of Betty Joan Turner, with limited authority. On March 4, 2020, Judge
Tara Reilly appointed me as Temporary Conservator of the Person and Estate of Betty
Joan Turner in Case No. CONPS 2000054. The Conservatorship over the Person
1
DECLARATION 0F KENDALL F. TURNER
ended upon my Mother’s death on May 31, 2021. That the entire case is now
concluded with the Order Approving and Settling First and Final Account And Report
of Temporary Conservator entered on December 28, 2022; and a Remittitur filed on
September 12, 2023 dismissing Mr. Tzankov’s appeal of that December 28, 2022
Order.
O(OWVOJO'IhOONA
3. Victor Tzankov (“Tzankov”) filed a Petition for Probate of Will and for Letters
Testamentary on March 24, 2022. My brother Kelly and | filed Objections on April 22,
2022. My brother Kelly and | filed our competing Petition for Probate of Will & Letters
Testamentary on May 13, 2022, with the aforementioned Order appointing my brother
Kelly and l as Special Administrators on May 23, 2022.
4. Numerous documents have been filed subsequently, including many
GROSSMAN
documents that were filed by Tzankov, on or after August 30, 2023, but not sen/ed, as
949-0119
FLOOR
Tzankov continues to file Proofs of Service purportedly signed by a person who does
2ND (909) 44—34444;
OF
, not exist, at an address for our attorney, James T. Lee, that is not the address that is
FX NmmthJ
AVE.
786
ELLIOT
91
listed on the pleadings; at which, as stated in Attorney Lee’s Declaration, he has
OFFICES
608-7426
CA
EUCLID
never received any of the documents purportedly served by mail.
MARC
N. UPLAND,
(909)
5. The issues addressed in those documents overlap. However, the intent of
LAW
100 PH
A this Declaration is to provide evidence as to those overlapping issues.
Challenges To the April 1, 2017 Will - Fraud
m6
6. My brother Kelly and | submit that the April 1, 2017 Will is fake and Tzankov
is attempting fraud upon this Court in submitting his Petition to Probate that Will.
My Mother and Tzankov were never married.
mfimm-kth-AOCOQ
7. My mother was never married to Tzankov. 11 5 of Tzankov’s 3/24/2022
NNNNNNNNNA
Petition states that my Mother was survived by a spouse. That is true, however, that
spouse was my father, Gilbert R. Turner, not Tzankov.
8. Tzankov states in 1] 8 of the Petition that he was the decedent’s spouse.
That is not true. Neither in the pleadings filed in the aforementioned pleadings, nor in
his Spousal Property Petition, where he has the burden of proving he is a spouse has
2
DECLARATION 0F KENDALL F. TURNER
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_.L Marc E. Grossman (SBN 197627) F LED l James T. Lee (SBN 110838) SUPERIOR ooumOFcAup 100 North Euclid Ave, 2nd Floor COUWOFSAN eenmnémg" UpIand, CA 91786 Phone: (909) 608—7426 OCT 12 2023 Fax: (909) 949-01 19 Email: info@wefight4you.com iim@wefight4you.com BY: m 9W“ VWUOO. D‘Puty OQOWNOUU'ILOON Attorney for Kendall F. Turner, Kelly James Turner SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO A A A GROSSMAN A N 949-0119 In re the: FLOOR A (JO Case No. PROSBZZOO416 OF 2ND (909) _\ A Estate 0f Betty J. Turner. DECLARATION OF KENDALL F. AVE., FX TURNER IN REPLY TO VICTOR ELLIOT 91786 A (J'l Decedent TZANKOV’S VARIOUS PLEADINGS OFFICES EUCLID CA 608-7426 _A C) Date: October 19, 2023 Time: 9:00 a.m. N. UPLAND, (909) A N Dept: F3 MARC LAW 100 PH _\ (Cm m6 Ea A DECLARATION OF KENDALL F. TURNER NO l, Kendall F. Turner do hereby declare as follows: 1. That I am an individual over 18 years of age and have personal first-hand knowledge of the following facts, except those that are stated on information and belief and as to those facts, believe them to be true. mem-hQJNA 2. That | am the son of the decedent, Betty Joan Turner. On May 23, 2022, NNNNNNNN this Court appointed myself and my brother Kelly J. Turner as Special Administrators of the Estate of Betty Joan Turner, with limited authority. On March 4, 2020, Judge Tara Reilly appointed me as Temporary Conservator of the Person and Estate of Betty Joan Turner in Case No. CONPS 2000054. The Conservatorship over the Person 1 DECLARATION 0F KENDALL F. TURNER ended upon my Mother’s death on May 31, 2021. That the entire case is now concluded with the Order Approving and Settling First and Final Account And Report of Temporary Conservator entered on December 28, 2022; and a Remittitur filed on September 12, 2023 dismissing Mr. Tzankov’s appeal of that December 28, 2022 Order. O(OWVOJO'IhOONA 3. Victor Tzankov (“Tzankov”) filed a Petition for Probate of Will and for Letters Testamentary on March 24, 2022. My brother Kelly and | filed Objections on April 22, 2022. My brother Kelly and | filed our competing Petition for Probate of Will & Letters Testamentary on May 13, 2022, with the aforementioned Order appointing my brother Kelly and l as Special Administrators on May 23, 2022. 4. Numerous documents have been filed subsequently, including many GROSSMAN documents that were filed by Tzankov, on or after August 30, 2023, but not sen/ed, as 949-0119 FLOOR Tzankov continues to file Proofs of Service purportedly signed by a person who does 2ND (909) 44—34444; OF , not exist, at an address for our attorney, James T. Lee, that is not the address that is FX NmmthJ AVE. 786 ELLIOT 91 listed on the pleadings; at which, as stated in Attorney Lee’s Declaration, he has OFFICES 608-7426 CA EUCLID never received any of the documents purportedly served by mail. MARC N. UPLAND, (909) 5. The issues addressed in those documents overlap. However, the intent of LAW 100 PH A this Declaration is to provide evidence as to those overlapping issues. Challenges To the April 1, 2017 Will - Fraud m6 6. My brother Kelly and | submit that the April 1, 2017 Will is fake and Tzankov is attempting fraud upon this Court in submitting his Petition to Probate that Will. My Mother and Tzankov were never married. mfimm-kth-AOCOQ 7. My mother was never married to Tzankov. 11 5 of Tzankov’s 3/24/2022 NNNNNNNNNA Petition states that my Mother was survived by a spouse. That is true, however, that spouse was my father, Gilbert R. Turner, not Tzankov. 8. Tzankov states in 1] 8 of the Petition that he was the decedent’s spouse. That is not true. Neither in the pleadings filed in the aforementioned pleadings, nor in his Spousal Property Petition, where he has the burden of proving he is a spouse has 2 DECLARATION 0F KENDALL F. TURNER