Motion-Secondary: PETE G. CORRALES & CARMEN C. CORRALES TRUST Print

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              LOUIE       A.   RUIZ (SBN: 309657)
              GEORGE V. KARR (SBN: 339298)                                                             ae ”'4 j
              VISTAs LAW GROUP, LLP
              430 N. Vineyard Ave., Suite 303                                                        COUSET OFRCNAkggsgm
                                                                                           StépOEURégYR

              Ontario, California 91764                                                        SAN BSRNARDWD DISTRICT
              Telephone:     (213) 745-8747                                                                         h
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              Facsimile:     (213) 745—8748                                                            NUV 1a            2023
              Email:                lruiz@vistaslawgroup.com
                                    gkarr@vistaslawgroup.com                             N      Daniel Richard              Morena
                                                                                                                            DEPWY
              Attorneys for Respondent,

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              LORRAINE CORRALES

                                      SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                                  COUNTY OF SAN BERNARDINO


                                                                           Case No.: PROPSl 100680
              IN   THE MATTER OF:                                          Honorable Michelle Gillece, Judge
                                                                           Presiding
              PETE  CORRALES AND CARMEN C.
                        G.
              CORRALES REVOCABLE TRUST Dated
              November         25, 1994                                    RESPONDENT LORRAINE
                                                                           CORRALES’ MANDATORY
                                                                              SETTLEMENT CONFERENCE BRIEF

              GILERT CORRALES,

                                    Petitioner,                            MSJ Judge:               Damian Garcia
                                                                           Date:                    November 13, 2023
                    vs.                                                    Time:                    1:30 pm.
                                                                           Location:                Superior Coufi of
              LORRAINE CORRALES,                                                                              County of
                                                                                                    California,
                                                                                                    San Bernardino —
                                    Respondent.                                                     Department F1 -
                                                                                                    Fontana


                        PLEASE TAKE NOTICE                that   Respondent    LORRAINE CORRALES                (“Lorraine),


              through her counsel, hereby submits her Mandatory Settlement Conference Brief pursuant to

              California Rules ofCourt, Rule 3.1380(0):

                   I.          PROCEDURAL POSTURE OF THE CASE
                          On   June 18, 2019, Petitioner,   GILBERT CORRALES           (“Petitioner”) filed the Petition


              to/for: (1)      An   Immediate Order   that Lorraine Corrales   Not Use Funds   to   Pay   for the       Defense of




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                   RESPONDENT LORRAINE CORRALES’ MANDATORY SETTLEMENT CONFERENCE BRIEF
             this   Action; (2)         An Immediate that Lorraine Corrales Prepare a Formal Accounting;                                       (3)   An Order

             that Lorraine Corrales Distribute the Trust Assets to Gilbert Corrales; (4)                                                 Damages due        to


             Lorraine Corrales Breach of Trust and Failure to Distribute Assets (“Petition”)                                               MORE THAN
 AWN



             FIVE         (5)   YEARS AFTER he                     signed a “Waiver of Accounting/Approval of Continued Use of

             Client Trust         Account            for Corrales Trust                Funds/Approval of          Any        Future Sale of Real Property

             Owned by            Trust/Approval of Trust and Amendments” on January 28, 2013 (“January 28, 2013


 \DOOQGLII
             Waiver and Approval”).

                          Lorraine has filed an objection and the case                              is   now     live.   Discovery has    now been      closed

             per Petitioner’s convenient request with exception to the Deposition of the administration

             attorney, Jason L.                    Gaudy’s deposition and four                    (4)    motions to compel of written discovery
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             pending and filed by Lorraine due t0 Petitioner’s conduct constituting misuse of the discovery
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             process.
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                          Trial    is    set for         March     4,       2024. The evidence will                 show       that (1) Lorraine did not
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             mismanage            Petitioner’s share           of the        estate; (2)      Lorraine has not been compensated by a trustee
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             t0 this date;        and    (3) Petitioner has not               been damaged              in   any way by Lorraine.
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                    II.          STATEMENT OF RELEVANT FACTS
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                          The     estate          began with the Pete G. Corrales (“Trustor Pete”) and Carmen C. Corrales
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             (“Trustor          Carmen”)            (collectively as the “‘Trustors”) created the                            “November   25, 1994 Trust.”
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             Attached hereto and incorporated by reference as “Exhibit 1”                                               is   a copy 0f the   November       25,
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             1994 Trust. This                is   a sad case that truly illustrates that “n0 good deed goes unpunished.” Lorraine
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             has done nothing but care for her brother, Petitioner, and has done nothing to                                            damage him       or his
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             estate.       Petitioner         is   a recovering alcoholic and would be dead 0r homeless but for Respondent’s
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             care.
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                           From    this context,           it is   important to understand                   how we      got here.   The Trustors      are the
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             deceased parents of the parties. Trustor Pete died on July 3 1, 2011 and Trustor Carmen died on
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             October        11,   201    1.        On   October    1   1,   201   1,   the   November        25, 1994 Trust       became     irrevocable.   On
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             October        1,   201    1,    Petitioner    and Respondent inherited the following                            assets as follows:
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                RESPONDENT LORRAINE CORRALES’ MANDATORY SETTLEMENT CONFERENCE BRIEF