Document for In re the Conservatorship and Guardianship of Wayne Robert Enos, Protected Person

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                30-PR-19-81
                                                                                                    Filed in District Court
                                                                                                      State of Minnesota
                                                                                                    5/29/2020 12:02 PM




STATE OF MINNESOTA                                                               DISTRICT COURT
COUNTY OF ISANTI                                                        10TH JUDICIAL DISTRICT
                                                                               PROBATE DIVISION
                                                                      Court File No.: 30-PR-19-81
In Re: Conservatorship of
Wayne Robert Enos,                                        EX PARTE PETITION FOR ORDER
                                                          ALLOWING FOR PAYMENT OF CLAIM
                            Protected Person.

Petitioner, Mary Lou Johnson, President of A&G Business Services, LLC, states the following:

   1. A&G Business Services, LLC (A&G) was appointed as Conservator for Wayne Robert Enos
      pursuant to Court Order dated September 26, 2019 (“Order”).

   2. A&G Business Services received an invoice from attorney Tom Satrom related to various
      estate planning matters handled for the Protected Person over a period of nearly two
      years. Upon information and belief, Mr. Satrom represented the protected person in an
      ongoing capacity for nearly 30 years.

   3. Attorney Satrom’s invoice is for a total of $6,804.38. A copy of his invoice, together with
      a letter in support of its payment is filed confidentially with this petition as Exhibit A.

   4. Both A&G Business Services and counsel for A&G Business Services have reviewed the
      invoice and discussed the services rendered with Attorney Satrom. In response to a
      request to adjust the charges for some of the services rendered, attorney Satrom
      agreed to discount a portion of the bill. That letter and enclosure is filed confidentially
      with this petition as Exhibit B. The total balance after adjustments is $6,047.38.

   5. According to Minnesota Statutes 524.5-429, the majority of the Satrom bill is entitled to
      a lower priority for payment than other debts or claims against the Protected Person.
      However, the Protected Person has sufficient assets to pay this debt, does not have
      unpaid claims or debts having priority that will go unpaid if this debts is paid, and the
      conservatorship is not at risk of insolvency if this bill is paid.

   6. Upon information and belief, the work performed by attorney Satrom on behalf on the
      Protected Person was for his benefit and appropriate. As such, the amount of $6,047.38
      should be paid to attorney Satrom from the Protected Person’s assets.

       NOW, THEREFORE, based on this Petition and the submissions made herewith,
       Petitioner requests an Ex Parte Order allowing the Conservator to pay to the law firm of
       Parker Satrom Law, P.A. $6,047.38 as and for legal services rendered to the Protected
       Person.



                                                1
                                    30-PR-19-81
                                                                                          Filed in District Court
                                                                                            State of Minnesota
                                                                                          5/29/2020 12:02 PM




                                                               Court File No.: 30-PR-19-81

FURTHER, under penalties for perjury for deliberate falsification therein, I declare or
affirm that I have reviewed the foregoing Petition and attachments, and, to the best of
my knowledge or information, its representations are true, correct and complete.

Dated: 5/29/2020                     /s/ Mary Lou Johnson
                                     Mary Lou Johnson
                                     President of A&G Business Services, LLC




                                        2
30-PR-19-81
              Filed in District Court
                State of Minnesota
              5/29/2020 12:02 PM