On March 24, 2022 a
Motion-Secondary
was filed
involving a dispute between
Tzankov, Victor R,
and
for Petition for Probate of Will and for Letters Testamentary
in the District Court of San Bernardino County.
Preview
To: Clerk Cour‘t Page: 03 of 24 2023-09—01 22:23:38 GMT 13103883143 From: Odessa Chin LLC
F I L E D
SUPERIOR COURT 0F CA IF
COUNTY 0F SAN BERNkRémg'A
sAN BERNARDINO DISTRI :‘r
Victor Tzankov SEP 0 1 20 23
6333 Green. Tree Blvd. General Delivery
'1
‘
Victowille, CA. 92393 BY
ANGELICA SEéIJPA. D :PUTY
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
In Re: Case N0.: PROSB22004] 6
RESPONSE TO TH E OBJEC'I‘ION
Estate Of-‘Bcuy Joan Turner OIF WILL FILED 04-22-2022 BY
Decedent KELLY & KENDALL TURNER
(Objectors)
Date: Sep. 18, 2023
Time: 09:00 AM
Dep. F3 FONTANA DISTRICT
Hon. Michelle Gilleece
BY FAX
PER CAC 2.303
TO Respondents, Kelly Turner/Kendal Turner AND HER ATTORNEYS 0F
RECORD:
COMES NOW, Victor R Tzankov “me, myself, I” without the benefit
0f counsel, files RESPONSE TO THE OBJECTION OF FILED 04-22-
WII,,.I,_,
2022 BY KEI...-I_,Y & KENDAI...I., TURNER (Kelly, Kendall, them, they, he,
objectors).
Pleadings, in this case, are being filed by the Petitioner In Propria
Persona, wherein pleadings are t0 be considered Without regard t0
technicalities. Propria, pleadings are not t0 be held to the same high
standards of perfection as practicing lawyers. See Haines V. Kerner 92
Sct 594, also See Power 914 F2d 1459 (11th Cir1990), also See Hulsey v.
Ownes 63 FSd 354 (5th Cir 1995). also See In Re: HALL V. BELLMON
935 F.2d 1106 (10th Cir. 1991)." In Puckett V. Cox, it was held that a
pro-se pleading requires less stringent reading than one drafted by a
lawyer (456 F2d 233 (1972 Sixth Circuit USCA). Justice Black in
Conley v. Gibson, 355 U.S. 41 at. 48 (1957) "The Federal Rules rejects
RESPONSE TO THE OBJECTION OF WILL FILED 04-22—2022 BY KELLY &: KENDALL TURNER
(OBJECTORS)DATE: SEP, 18, 2023'1‘1ME; 09:00 AEVIDEP, F3 FONTANA DISTRICTHON. MICHELLE
GILLEECE - .l
To: Clerk Court Page: 04 of 24 2023-09-01 22:23:38 GMT 13163883143 From: Odessa Chin LLC
"the approach that pleading is a game
0f skill in which one misstep by
counsel may be decisive to the outcome and accept thq principle that the
purpose of pleading is to facilitate a proper decision on the merits."
According to Rule S(f), FRCP and the State Court rule hold that all
pleadings shall be construed to d0 substantial justice.
This response is based on underlying fasts.
l. STA'I‘EMEN'I‘S OF FACTS-
This response is made under court order In Probate Note from 07-20-23
under objection by Victor R Tzankov petitioner.
1. In order to object. to the Will‘s validity objectors, have the legal.
burden to prove that the will is invalid.
0 Lack 0f tcstamentzuy intent
I Lack. 0f testamentary capacity
Undue influence
Fraud
Duress
Mistake
o Revocation
2. The abjection flied. 0n 0444-2022 is not valid 0n the grounds is in conflict
with the Pmbate code § 8250(3).
a have never been served with a summrm.
‘I
0 Service at address objectors knew is not my residence. Case
EAPVSZOOOOM Minute order 02-09-202 .l .r‘xt‘tached hereto is;
EXHIBIT A.
. e Objecturs allcging that. Gilbert Ray Turncr has been u lawful husband t0
Betty Turner since 1956“ Perhaps! Legally separated in 984. Attached
'1
hereto EXHIBIT B, C. Ifobjectors are correct that Betty and Gilbert "l‘umer
arc husband & wife what .l’m doing living with Betty 'l‘umer since 2005 as
submitted in all moving papers by Objectors? In what capacity?
. As to the “Lack. of‘lestamenlary intent” there is no one Fact t0 support it.
Oniy theory; assumptiona and cases we‘re dismissed for Iack 0f prosecution
On the contraly, why did Betty Turner dishonor them:
RESPONSE TO THE OBJECTION OF WILL FILED 04-22—2022 BY KELLY &: KENDALL TURNER
(OBJEC'I‘ORS)DA'I‘E: SEP. 18, 2023'1‘IME; 09:00 A_NLDEP. F3 FONTANA DIS’I‘RIC'I‘HON, MICHELLE
GILLEECE - 2
Document Filed Date
September 01, 2023
Case Filing Date
March 24, 2022
Category
Petition for Probate of Will and for Letters Testamentary
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To: Clerk Cour‘t Page: 03 of 24 2023-09—01 22:23:38 GMT 13103883143 From: Odessa Chin LLC F I L E D SUPERIOR COURT 0F CA IF COUNTY 0F SAN BERNkRémg'A sAN BERNARDINO DISTRI :‘r Victor Tzankov SEP 0 1 20 23 6333 Green. Tree Blvd. General Delivery '1 ‘ Victowille, CA. 92393 BY ANGELICA SEéIJPA. D :PUTY SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO In Re: Case N0.: PROSB22004] 6 RESPONSE TO TH E OBJEC'I‘ION Estate Of-‘Bcuy Joan Turner OIF WILL FILED 04-22-2022 BY Decedent KELLY & KENDALL TURNER (Objectors) Date: Sep. 18, 2023 Time: 09:00 AM Dep. F3 FONTANA DISTRICT Hon. Michelle Gilleece BY FAX PER CAC 2.303 TO Respondents, Kelly Turner/Kendal Turner AND HER ATTORNEYS 0F RECORD: COMES NOW, Victor R Tzankov “me, myself, I” without the benefit 0f counsel, files RESPONSE TO THE OBJECTION OF FILED 04-22- WII,,.I,_, 2022 BY KEI...-I_,Y & KENDAI...I., TURNER (Kelly, Kendall, them, they, he, objectors). Pleadings, in this case, are being filed by the Petitioner In Propria Persona, wherein pleadings are t0 be considered Without regard t0 technicalities. Propria, pleadings are not t0 be held to the same high standards of perfection as practicing lawyers. See Haines V. Kerner 92 Sct 594, also See Power 914 F2d 1459 (11th Cir1990), also See Hulsey v. Ownes 63 FSd 354 (5th Cir 1995). also See In Re: HALL V. BELLMON 935 F.2d 1106 (10th Cir. 1991)." In Puckett V. Cox, it was held that a pro-se pleading requires less stringent reading than one drafted by a lawyer (456 F2d 233 (1972 Sixth Circuit USCA). Justice Black in Conley v. Gibson, 355 U.S. 41 at. 48 (1957) "The Federal Rules rejects RESPONSE TO THE OBJECTION OF WILL FILED 04-22—2022 BY KELLY &: KENDALL TURNER (OBJECTORS)DATE: SEP, 18, 2023'1‘1ME; 09:00 AEVIDEP, F3 FONTANA DISTRICTHON. MICHELLE GILLEECE - .l To: Clerk Court Page: 04 of 24 2023-09-01 22:23:38 GMT 13163883143 From: Odessa Chin LLC "the approach that pleading is a game 0f skill in which one misstep by counsel may be decisive to the outcome and accept thq principle that the purpose of pleading is to facilitate a proper decision on the merits." According to Rule S(f), FRCP and the State Court rule hold that all pleadings shall be construed to d0 substantial justice. This response is based on underlying fasts. l. STA'I‘EMEN'I‘S OF FACTS- This response is made under court order In Probate Note from 07-20-23 under objection by Victor R Tzankov petitioner. 1. In order to object. to the Will‘s validity objectors, have the legal. burden to prove that the will is invalid. 0 Lack 0f tcstamentzuy intent I Lack. 0f testamentary capacity Undue influence Fraud Duress Mistake o Revocation 2. The abjection flied. 0n 0444-2022 is not valid 0n the grounds is in conflict with the Pmbate code § 8250(3). a have never been served with a summrm. ‘I 0 Service at address objectors knew is not my residence. Case EAPVSZOOOOM Minute order 02-09-202 .l .r‘xt‘tached hereto is; EXHIBIT A. . e Objecturs allcging that. Gilbert Ray Turncr has been u lawful husband t0 Betty Turner since 1956“ Perhaps! Legally separated in 984. Attached '1 hereto EXHIBIT B, C. Ifobjectors are correct that Betty and Gilbert "l‘umer arc husband & wife what .l’m doing living with Betty 'l‘umer since 2005 as submitted in all moving papers by Objectors? In what capacity? . As to the “Lack. of‘lestamenlary intent” there is no one Fact t0 support it. Oniy theory; assumptiona and cases we‘re dismissed for Iack 0f prosecution On the contraly, why did Betty Turner dishonor them: RESPONSE TO THE OBJECTION OF WILL FILED 04-22—2022 BY KELLY &: KENDALL TURNER (OBJEC'I‘ORS)DA'I‘E: SEP. 18, 2023'1‘IME; 09:00 A_NLDEP. F3 FONTANA DIS’I‘RIC'I‘HON, MICHELLE GILLEECE - 2