On October 24, 2023 a
Complaint,Petition
was filed
for Trust
in the District Court of San Bernardino County.
Preview
F l
SUPERIOR COURT 0F CALIFORNIA
LE D
Y
COUNTY OF SAN BERNARDINO
Ricardo Martel",
1414 Brett Place, #144
San Pedro, CA. 90732 OCT 2 4 2023
In Pro Per
BY:
”L
Briaha Flores. Deputy
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO - CIVILIPROBATE DIVISION
TQ‘I"
~
asfifinm‘mfi
"’ u u ‘- 'U’UUUUI
VINCENT P. MARTELLI, JR., MARIELA )
Case NO. ‘
MARTELLI, RICARDO V. MARTELLI, LUKE AV
MARTELLI; MARTELLI FAMILY TRUST, g
NOTICE OF PETITION T0 REMOVE TRUSTEE 0F TRUST
)
Plalntlffs, AND PETITION T0 REMOVE TRUSTEE 0F TRUST;
)
MEMORANDUM 0F POINTS AND AUTHORITIES IN
lO VS.
SUPPORT THEREOF
g
11 ANTHONY M. CONTRATTO, and DOES 1-25 {
Defendants_
g
Date: ll
'
l0 ,
2023 Time: q Dept.: \nl
12 )
Action Filed:
)
l3 )
l4
15
16
TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE
l7
18
NOTICE that on ,
2023 at 8:30 am. in Department _ of the above—entitled Court, located
at 14455 Civic Dr, Victorville, California, 92392. P1aintiff(s), VINCENT P. MARTELLI, JR., MARIELA
l9
20 MARTELLI, RICARDO V. MARTELLI, LUKE A. MARTELLI; THE MARTELLI FAMILY TRUST, Will Petition
21 ANTHONY M. CONTRATTO, the trustee of the
both generally and specially to permanently remove
22
MARTELLI FAMILY TRUST pursuant to California Probate Code § 17.200; California Probate Code §
23
15642 (b)(l—S), (b)(6)(B).
24
Plaintiffs petition on the following grounds:
25
26 1. The first cause of action for Breach 0f fiduciary duty to the trust in failure to satisfy
27 “Independent review” clause of (California Code, Probate Code — PROB S 15642 (b)(6)(BD,
28
_ l _
NOTICE OF PETITION AND PETITION TO REMOVE TRUSTEE OF TRUST
2. The second cause of action for breach of fiduciary duty to the trust; insolvent or
otherwise unfit t0 administer; hostility or lack of cooperation; fails or declines to act; compensation is
excessive under the circumstances (California Code, Probate Code - PROB S 15642 (b)( 1—3),
3. This Petition will be based upon this Notice, the accompanying Memorandum 0f
Points and Authorities upon the pleadings and papers on file herein, and upon such other oral and
documentary evidence as may be presented at the time of hearing of this Motion.
4. The MARTELLI FAMILY TRUST and the Family (captioned herein) has been taken
advantage 0f by the self named Successor trustee ANTHONY M. CONTRATTO (hereinafter
“Defendant”), and now suffers through direct threats, hostile emails, unprofessional phone calls, and
continuous breach. The settlor and inheritors 0f the trust collectively move upon this courts
jurisdiction and compassion to permanently remove the trustee of record accordingly...
Dated: By:
wwmgw
THE MARTELLI FAMILY TRUST
MM
LQK MAW3VLU
_ 2 _
NOTICE OF PETITION AND PETITION TO REMOVE TRUSTEE OF TRUST
Preview
F l SUPERIOR COURT 0F CALIFORNIA LE D Y COUNTY OF SAN BERNARDINO Ricardo Martel", 1414 Brett Place, #144 San Pedro, CA. 90732 OCT 2 4 2023 In Pro Per BY: ”L Briaha Flores. Deputy SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO - CIVILIPROBATE DIVISION TQ‘I" ~ asfifinm‘mfi "’ u u ‘- 'U’UUUUI VINCENT P. MARTELLI, JR., MARIELA ) Case NO. ‘ MARTELLI, RICARDO V. MARTELLI, LUKE AV MARTELLI; MARTELLI FAMILY TRUST, g NOTICE OF PETITION T0 REMOVE TRUSTEE 0F TRUST ) Plalntlffs, AND PETITION T0 REMOVE TRUSTEE 0F TRUST; ) MEMORANDUM 0F POINTS AND AUTHORITIES IN lO VS. SUPPORT THEREOF g 11 ANTHONY M. CONTRATTO, and DOES 1-25 { Defendants_ g Date: ll ' l0 , 2023 Time: q Dept.: \nl 12 ) Action Filed: ) l3 ) l4 15 16 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE l7 18 NOTICE that on , 2023 at 8:30 am. in Department _ of the above—entitled Court, located at 14455 Civic Dr, Victorville, California, 92392. P1aintiff(s), VINCENT P. MARTELLI, JR., MARIELA l9 20 MARTELLI, RICARDO V. MARTELLI, LUKE A. MARTELLI; THE MARTELLI FAMILY TRUST, Will Petition 21 ANTHONY M. CONTRATTO, the trustee of the both generally and specially to permanently remove 22 MARTELLI FAMILY TRUST pursuant to California Probate Code § 17.200; California Probate Code § 23 15642 (b)(l—S), (b)(6)(B). 24 Plaintiffs petition on the following grounds: 25 26 1. The first cause of action for Breach 0f fiduciary duty to the trust in failure to satisfy 27 “Independent review” clause of (California Code, Probate Code — PROB S 15642 (b)(6)(BD, 28 _ l _ NOTICE OF PETITION AND PETITION TO REMOVE TRUSTEE OF TRUST 2. The second cause of action for breach of fiduciary duty to the trust; insolvent or otherwise unfit t0 administer; hostility or lack of cooperation; fails or declines to act; compensation is excessive under the circumstances (California Code, Probate Code - PROB S 15642 (b)( 1—3), 3. This Petition will be based upon this Notice, the accompanying Memorandum 0f Points and Authorities upon the pleadings and papers on file herein, and upon such other oral and documentary evidence as may be presented at the time of hearing of this Motion. 4. The MARTELLI FAMILY TRUST and the Family (captioned herein) has been taken advantage 0f by the self named Successor trustee ANTHONY M. CONTRATTO (hereinafter “Defendant”), and now suffers through direct threats, hostile emails, unprofessional phone calls, and continuous breach. The settlor and inheritors 0f the trust collectively move upon this courts jurisdiction and compassion to permanently remove the trustee of record accordingly... Dated: By: wwmgw THE MARTELLI FAMILY TRUST MM LQK MAW3VLU _ 2 _ NOTICE OF PETITION AND PETITION TO REMOVE TRUSTEE OF TRUST