Legal Document: Leahy, Linda vs. Federghi, V.

On July 27, 2023 a Request Judicial Notice in Support of Demurrer to complaint was filed involving a dispute between Linda Leahy, and E. Keenan, T. Adams, V. Federghi, for Civil-Roseville in the District Court of Placer County.

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1 Natalie P. Vance, Bar No. 206708
Tara R. Burd, Bar No. 276676
2 Kaleigh E. Thomas, Bar No. 340194
KLINEDINST PC
3 801 K Street, Suite 2100
Sacramento, California 95814
4 (916) 282-0100/FAX (916) 444-7544
nvance@klinedinstlaw.com
5 tburd@klinedinstlaw.com
kthomas@klinedinstlaw.com
6

7 Attorneys for THERESE ADAMS

9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF PLACER
11
SACRAMENTO, CALIFORNIA 95814

12 LINDA G. LEAHY, Case No. S-CV-0050908
801 K STREET, SUITE 2100

13 Plaintiff, REQUEST FOR JUDICIAL NOTICE IN
KLINEDINST PC

SUPPORT OF DEMURRER TO
14 v. COMPLAINT
15 THERESE ADAMS and DOES 1 -10, Date: November 30, 2023
Time: 8:30 a.m.
16 Defendants. Dept.: 3

18 Defendant THERESE ADAMS hereby requests, pursuant to Code of Civil procedure

19 section 430.30, subdivision (a) and California Evidence Code section 452, subdivision (d) and (h)

20 and section 453, et seq. that this Court take judicial notice of the following document(s) in support

21 of its Demurrer to Plaintiff’s Complaint:

22 1. The Motion for Damages and Breach of Fiduciary Duty filed April 20, 2022 in

23 Placer County Superior Court, case number SPR010445. A true and correct copy of the Motion is

24 attached hereto as Exhibit 1.

25 2. The Order Denying Motion for Damages and Breach of Fiduciary Duty filed

26 August 19, 2022, in Placer County Superior Court, case number SPR010445. A true and correct

27 copy of the Order is attached hereto as Exhibit 2.

28 / / /

1
REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEMURRER TO COMPLAINT
1 3. The Opposition to Plaintiff’s Motion for Damages and Breach of Fiduciary Duty

2 filed July 18, 2022 in Placer County Superior Court, case number SPR10445. A true and correct

3 copy of the Opposition is attached hereto as Exhibit 3

4 The foregoing exhibits are subject to judicial notice as they are “not reasonably subject to

5 dispute and are capable of immediate and accurate determination by resort to sources of

6 reasonably indisputable accuracy.” (Evid. Code, § 452, subd. (h); see also Columbia Cas. Co. v.

7 Nw. Nat’l Ins. Co. (1991) 231 Cal.App.3d 457, 469-469; Maryland Cas. Co. v. Reeder (1990) 221

8 Cal.App.3d 961, 977 [a court has authority to take judicial notice of documents that cannot be

9 reasonably be controverted].) Certain of the exhibits are also subject to judicial notice as records

10 of the court under Evidence Code section 452, subdivision (d).

11 Judicial notice is mandatory if the party requests it, gives the adverse party notice of the
SACRAMENTO, CALIFORNIA 95814

12 request, and furnishes the court with sufficient information to enable it to take judicial notice of
801 K STREET, SUITE 2100

13 the matter. (Evid. Code, § 453.) As such, Ms. Adams respectfully requests that this Court take
KLINEDINST PC

14 judicial notice of the documents and facts set forth above.

15 KLINEDINST PC

17
DATED: October 13, 2023 By:
18 Natalie P. Vance
Tara R. Burd
19
Kaleigh E. Thomas
20 Attorneys for THERESE ADAMS
23206171.1
21

2
REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEMURRER TO COMPLAINT
EXHIBIT 1
Your name: Atil,4 CL
Your address: 3), /1--elU2, 42c'

Self-Represented

Placer County Superior Court
öse;1-1)e 7C1.- 9.5.(0)

L„-d, G, ) Case No.: sPgo(
10 Plaintiff, ) NOTICE OF MOTION AND MOTION TO
) -Szglitzt-Ad-2
11 VS. e4icz,et.,
12
)) Hearing date:
13 Defendant/,5 ) Dept.
) Time:
14

15 To: ---tx,„„„ Ç2ej
1-fo Hplaintiff

16 [ ]and his/her attorney of record,

17 PLEASE TAKE NOTICE that at the time and place spedfied above, moving party will ask the court to make

18 the following orders:

19 471 .9-;,7-z, .5cem.,pr,(1
20 At244 ftlo,c'e-vii
21

22 This motion is based on the attached declaration of moving party

23 [1.44-4 the attached Points and Authorities

24 -IL )122;/( 7,,_t U1-7

25 Respectfully Submitted, (signature)
Print name:
DECIARATION (Explanation for this MoWO

I, (your name) L IA,,is, G.,. L47 aly ,declare:

I am the [ Plaintiff [ ] Defendant in this action. I have personal knowledge of the matters discussed

,-
below and, if called as a witness, I could competently testify to them.

1,,) 1,,i, 77.-r-t aid.O. /ip A.e

Linda Leahy , Courts Transcript Requests

ct 04, 2021 08:42 AM

Court Transcript Request

r •our email. A court rcrxirtcr was not present at these hearings. For anything further from your tile please contact the civil division at 916 40S-6LXV.

Thank you.

From: Linda Leahy
Sent: Sunday, October 03, 2021 12:30 PM
To: Courts Transcript Requests
Subject: Court Transcript Request

he following data was submitted via the online Court Transcript Request form.

Personal Information
First Name: Linda
Last Name: Leahy
Law Firm:
Street: 377 Pine Tree Way #242
City: Selma
Slate: Oregon
Zip: 97538
Email Address: lleahy@netzero.net

Case Information
Court Reporter: petition to distribute and objectors
Case Number: S PR 0010445
Case Name: Keenan Family 1998 Revocable Trust
Proceeding Dates: 10-2-20. 12-2-20. 12-4-20
Name of Judicial Officer Glenn M. Holley
Department / Courtroom: Department 40
Message: I recently requested the court files on these matters. When I received the files, there was very little in them, regarding communications, conversations and testimony.
Actually, nothing. As I am submitting complaints to California Judicial Commission, California Professional Fiduciary Bureau, and The California State Bar, testimony, which was
biased and discriminatory, by 5 attorneys, approved the the seated judge was used to influence the court and its decisions.-The decisions are what they are, but the testimony is
questionable, and led to undue influence by the trustee, the former trustee, their 4 lawyers and the other of two, beneficiaries:Needless to say, these violations beg to be scrutinized
as to their verity and impact upon a matter, where one beneficiary, was voiceless against 5 attorneys, in a forum with was to be protecting the rights of both beneficiaries. This conduct
is in need of review and it starts with the transcripts of testimony used on these dates, via phone due to COVID. If there was no reporter, anethe docket sheets do not indicate one.
then them matter to go before CJC, will be expanded to question why such remarks were used, influenced the judge and were not documented for scrutiny. After all, we are talking
about a process which is to not be biased and a Professional Trustee's behavior and conduct, the conduct of 5 attorney's and a judge, against the other beneficiary, when a set aside
of $100.000 was determined, solely based upon allegations against the absent beneficiary who lives in another stale. Oregon. More alarming is that the trustee, the former trustee
and the other beneficiary, enjoined to protest, which is absolutely biased and violations of ethics, code of conduct and many other serious failures to protect an estate and the
beneficiaries. Thank you..

End of submission.
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ADA FORM, M 410 Back to Messages
Inbox From: lleahy@netzero.ner ‹Ileahy@i View Contact I Invite Sender I Block Sender Full Header
Draft To: dhunt&htrustlaw.com. jgalvirt©DowncyBrand.com, adams©tadfiduciary.com
Sent (2) Sent: Tue, Oct 05,2021 02:42 PM
Trash (21)
Junk Mail Did any of you ever file an ADA form M 410 with the court. for Probate case 4 SPR13010/1545? Was
Judge Holley ever informed of my need for accommodation to participate in the court proceedings?

My Folders Add TAD knew of my disabilities, Mr. Hunt knew. I don't know if Mr. Galvin knew. I don't know if Judge Holley
knew and I don't know if anyone filed a JCForm M 410. -\
DentiCal (7)
NYT (7) I also know. that testimony was presented, by petition and verbal, that I was in need of Psychological ri
counseling (Mr. Gibbons) and a threat. Also implied or testified to. that I have a mental illness, or other
PGE mental disorder that caused this threat. f. •.pic1)-\(
SOROA
So, who, filled out a form M 410? , t 1 I,
TAD '"I, t
apartmente (13) Here is the truth of my disabilities. I have been deaf since I was 21. and in fact have the same condition,
Meniere's Disease, that my Mom. Catherine Keenan had. I am now 80, you do the math. Records of my
bank of Ame... (9) medical condition are always put forward for any situation where i need to participate.
barcase (3)
I also have macular degeneration and low vision, also needs accommodation, as I rely upon hp reading for
bruce (4) my hearing.
chase (18)
The mental condition? Well I think someone used that to discredit me and exclude me in the proceedings
checks and as a credible witness on my own behalf.
clyde (7)
Needless to say, all of this, would fall under discrimination, and all of it is quite apparent in the files I do
computer (8) have. The only question tell unanswered is why would officers of the court, behave so badly?
credit cards (3)
Did the Judge know? If yes, he also was a player, using tactics to use bias and partiality in a very
credit score (1) important series of hearings.
evidence (274)
I currently have left a message with Maryanne. the ADA coordinator with PCSC. to see if anyone
extra (2) submitted this form on my behalf? All 3 of you had a duty to keep the proceedings far and reasonable. To
fidelity (34) ensure that I could participate by accommodation. And to ensure that I was not discriminated against in
the proceedings by accusations of a disability by actually having it. or being accused of having it, so that it
land (77) influenced Judge Holley and the Court proceedings with bias and discrimination. This is very serious and
legal (12) a pivotal issue going into complaints to Cat Bar and CJC. So I do need clarification on who knew what,
and when. Who did not know, and who decided to not inform the court and the Judge. Who decided to
loan (23) accuse me and exclude me?
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From: Ileahy@neUero.ner .ctleahy@netzero.net>
To: dhurit@dhtrustlaw.com. jgalvin@DowneyBrand.com. adams@tadfiduciary.com

ge.„,
Sent: Tue, Oct 05. 2021 02:42 PM
Subject: ADA FORM, M 410
__ .
Did any of you ever file an ADA form M 410 with the court. for Probate case 4 SPR 00104545? Wns Judge Holley ever infoued of my need for accommodation to participate ir the court/
;AI .1

proceedings? e
TAD knew of my disabilities. Mr. Hunt knew. I don't know if Mr. Galvin knew. I don't know if Judge Holley knew and I don't know if anyone filed a JCForm M 410.

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I also have macular degeneration and tow vision, also needs accommodation, as I rely upon Up reading for my hearing.

The mental condition? Well I think someone used that to discredit me and exclude me in the proceedings and as a credible witness on my own behalf.

Needless to say, all of this, would fall under discrimination, and at of it Is quite apparent In the files I do have. The only question left unanswered is why would officers of the court, behave so badly?

Did the Judge know? If yes. he also was a player, using tactics to use bias and partiakty in a very important series of hearings.

•I currently have left a message with Maryanne. the ADA coordinator with PCSC. to see If anyone submitted this form on my behalf? All 3 of you had a duty to keep the proceedings far and
reasonable. To ensure that I could participate by accommodation. And Co ensure that I was not discriminated against In the proceedings by accusations of a disability by actually having it. or being
accused of having it, so that it influenced Judge Holley and the court proceedings with bias and discrimination. This is very serious and a pivotal issue going into complaints to Cal Bar and WC. So I
do need clarification on who knew what. and when. Who did not know, and who decided to not inform the court and the Judge. Who decided to accuse me and exclude me?

eV% ••• ••• .111,4 0," I, e N.... 4.6 IC •)••••, ; •••••••1;••••• • •••"•42.,f"-41...fil A A eg. r 'I A cocA 4120,9,...“-•-7.6...P A 9 •••• " • g ." A n 0 4 904- ,n9 .."•••• 1.1
October 6, 2021

Commission on Judicial Performance
455 Golden Gate Ave., Suite 14400
San Francisco, Ca 94102

RE: Judicial misconduct, bias, discrimination by disability or perceived
disability, exclusion of petitioner from court process, while petitions and
conversations were ALL, BY ALL PRESENT at the hearing, significantly
negative and aimed solely at the only person na" present. Not even my
council sought to stop the carnage. No one told the court that I am 80 years
old, low visioned and deaf. No one asked for accommodation so that I could
be present and participate. Not the Trustee, Therese Adams, not her council
Jeff Galvin and not my attorney, Daniel Hunt, sought to include me.

That Judge Holley does this type of hearing all the time, he had a duty to
question the remarks and why only one person was not present, when all
accusations of misconduct, or potential misconduct were laid at her door.

Judicial Misconduct:

Bias:

Discrimination by disability, or perceived disability:

Exclusion of Petitioner by court process:

Partiality:
by not providing Form M 410, accommodation, prejudice, and conflict of
interest.

This supplement from page one of the complaint form, the descriptions,
activities, words, comments, behavior and actions by Judge Glenn M.
Holley; case S PR 0010445. Hearings held on multiple occasions in Placer
County Superior Court.

There was no accommodation for me a deaf and low visioned person, I am 80
years old, was referred to in discriminatory manner, excluded from
proceedings, and from the Court file information, I was made the space goat
of the days events. The day's event were to seek distribution, but were
changed by new council coming in and filing a petition, ** attached, accusing
me of bad behavior or potential bad behavior. This culminated it the Judge
changing his ruling from 2 days prior, December 2, 2020, and increasing his
set aside from $75,000, to $100,000. The reasons are as listed in the petition
by Jeffry Galvin, Downey and Burke. This also was the culmination of 5
attorney's who had worked to exclude me and defame me for purpose of
billable hours and forcing me to sign 3 waivers. The waivers also included m
y own attorney, Daniel Hunt, who assured me if I signed, we could get the
matter out of probate court and correct later. This was misinformation as he
quit and returned by retainer, same say.

All this is back ground, so we come now to Judge Holley. He made such a
confused ruling, and since I was the only party not in his hearing that day, I
was made to be the space goat. Something he should have caught, since he
does this every day. I was excluded because no one, not my trustee, not her
council, nor her other 3 councils, and no my attorney, arranged to file a form
to provide accommodation. So, I was told I did not need to be present, but I
did not know what happened that day, until I just got the court file. My
lawyer's paralegal did sent me an e mail and told me that "they" threw me
under the bus, with accusations and testimony that I was mentally ill, I sue
my own family, I am a trouble maker, I hired someone to threaten my brother,
the other beneficiary, and his wife, the previous trustee, that I would sue
them. The petition also denied me any discovery, I was excluded from the
process and I was told: Take the higher ground, be bigger, or Karma will get
them. I was dupe and so was Judge Holley, unless he was part of it.

Now, I believe he knew, in part, this was improper treatment, as I was the
only person not there and the only person being ridiculed, blamed and
accused. And, within 2 days of his order from December 2, 2020. I have
filed a civil rights complaint against Judge Holley for not speaking of me, or
treating me with dignity.
October 18, 2021

attachment to complaint form:

Here is a list of the support documents that go with the attached
complaint for your review and consideration.

1. EXHIBIT A, 2 PAGES OF REQUEST FOR MEDICAL
ACCOMMODATION AND WHY

2. EXHIBIT B. 1 PAGE OF E MAIL NOTES, JUST ONE
EXAMPLE OF HUNDREDS OVER 2 YEARS, WHERE MS.
ADAMS MADE MISTAKES IN HER RECORD KEEPING. THIS
ONE IS ABOUT MIXUP'S IN BANK RECORDS. THE ESTATE
HAD SEVERAL BANK ACCOUNTS, CREDIT CARDS AND
INVESTMENT ACCOUNTS. RATHER THAN IDENTIFYING
EACH WITH COMPANY NAME AND ACCOUNT NUMBER,
SHE SIMPLY CALLED THEM "THE CHECKING ACCOUNT"
OR "THE CREDIT CARD" OR SUCH. IN THIS PARTICULAR E
MAIL, THE RESULTING CONFUSION IS BEING DISCUSSED
AND HOW SHE MADE ERRORS IN "ACCIDENTALLY"
TAKING MONEY OUT OF THE WRONG ACCOUNT, AGAIN
SHE DID NOT MENTION THE ACCOUNT LABEL SO THIS E
MAIL IS SORTING OUT 2 THINGS, THE BAD RECORDS AND
THE MISTAKEN WITHDRAWAL THE ACCOUNTS BEING
DISCUSSED ARE LPL ACCOUNT 7062, LPL ACCOUNT 5365, U
S BANK ACCOUNT 5262 AND U S BANK ACCOUNT 5325. IN
PARAGRAPH 2, UNDER WE RESPOND AS FOLLOWS, IT
BEGINS WITH "WE PREVIOUSLY EXPLAINED THAT MS.
ADAMS NOTICED MONEY BEING TRANSFERRED OUT OF
LPL 7062 MS. ADAMS PROMPTLY CORRECTED"
Page 1 of 2
did not know what happened that day, until I just got the court file. My
lawyer's paralegal did sent me an e mail and told me that "they" threw me
under the bus, with accusations and testimony that I was mentally ill, I sue
my own family, I am a trouble maker, I hired someone to threaten my brother,
the other beneficiary, and his wife, the previous trustee, that I would sue
them. The petition also denied me any discovery, I was excluded from the
process and I was told: Take the higher ground, be bigger, or Karma will get
them. I was dupe and so was Judge Holley, unless he was part of it.

I ASK THAT THIS, AND THE E MAIL COMPLAINTS BE MY REQUEST FOR
REVIEW OF THE PROCESS, THE DISCRIMINATION BY IMPLIED
DISABILITY AND DENIAL OF A REAL DISABILITY. I FURTHER
SUGGEST ANY SUCH PROCEEDINGS, IN THE FUTURE, TOWARDS ANY
DISABILITY, USE TRANSCRIBERS TO ENSURE JUSTICE AND FAIR
LANGUAGE WHEN ASSAULTING SOMEONE WHO IS DISABLED AND
NOT PRESENT.

I AM VERY SADDENED THAT IS 2021, THIS COULD HAPPEN, DID
HAPPEN AND WAS ACTUALLY ALLOWED TO BE A PROCEDURE USED
BY A $400 AN HOUR ATTORNEY, WHO DEALS IN TRUST LAW, FOR VERY
VULNERABLE PERSONS, AND HAS NOT ONLY A HIGHER DUTY TO
KNOW, AS A LAWYER, BUT AN EVEN HIGHER DUTY AS A PROBATE
LAWYER. TO MAKE A BENEFICIARY, WHO IS TO BE PROTECTED IN
THE PROBATE PROCESS, THE GARBAGE CAN OF AN ARGUMENT SO
DISCRIMINATORY AND EXCLUSIVE AS TO NOT EVEN INCLUDE THE
ACCUSED IN THE CONVERSATION, BECAUSE HER PRESENCE MAY
HAVE BEEN IMPORTANT TO THE BIASED LANGUAGE AND
CONCLUSIONS DRAWN AGAINST DISABLED PERSONS.

I ASK THAT THIS CASE, STILL BEING OPEN, BE REVIEWED BY THE
JUDGE TO CLEAR THE DISCRIMINATORY INFLUENCE. THAT THE CASE
BE REVIEWED AND CLOSED, THAT I BE PRESENT, ACCOMMODATED
AND THAT THERE BE A EQUAL PLATFORM, OF TREATMENT AND
PARTICIPATION. THAT YOUR HONOR REVIEW OF THE PROBATE
LAWYERS USED HIS COURTROOM AND HIM, TO PERPETRATE
DISCRIMINATION AND EXCLUSION.

LINDA LEAHY
10/19/21, 3:44 PM NetZero Message Center

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ADA Good afternoon,
(5)
DentiCal (7)
NYT (7)
Attached please find the Court's response to your ADA related correspondence.
PGE
SOROA
TAD (7)
Thank you,
apartmentC (13)
bank of Ame... (9)
barcase (2)
bruce (4)
chase (18) Court Administration
cid:image001.png@01032D2A.EEF7F420 superior Court of California, County
clyde (7) of Placer
computer (13) (916) 408-6000
credit cards (3) wwwplacer.courts.Ga.gov
credit score (1)
evidence (259)
extra From: Ileahy@netzero.net
(3)
Sent: Tuesday, October 19, 2021 10:08 AM
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To: Court Administration
huntbills Subject: RE: ADA Coordinator, ADA Complaint
land (64)
legal (2)
loan (24) Good morning Mr. Chatters. I see that your title is Court Executive Officer. Are you also the ADA
Coordinator? I was looking at the ADA procedures for filing an ADA complaint. What struck me as
miranda questionable, were two things; one was the 60 day rule, and the other, is that no ADA Coordinator spoke
my will (13) to me, after I filed, for clarifications.
netzero (2)
orders (42) So, I sought 10 find precise procedures on ADA grievance filing. I know there were, are, mitigating
oregonbar (27) circumstances in my situation, So these are what I seek to clarify, by filing an appeal for review. Hopefully
with someone who will actually give roe a voice. What I lost out on by no accommodation, even though I
payee! (7) requested it, was no voice. So now, here again, I am denied a voice because I did not ask with in the 60
schwab (38) day time line. I did not know in that 60 day time line, as I stated in my grievance. I only was informed of
the situation when I requested and received the court documents. So my grievance is filed timely within
synchronyba... (2) the 60 days. when I found out I was denied accommodation. So that rote, seeks clarification in my case.
verizon (4)
veterans (43)
zoom (2) My case is Probate, was a review before a Court Commissioner, and I was not informed. The whole
review was about me, and my perceived mental state, which would be a disability perceived not actual. I
would have no idea of this hearing, or its content, until I got the court documents, as close of probate
issues. Until close, all information goes through to me from the Trustee, who is also an attorney, officer of
the Placer County Superior Court and Judge Pro Tern in the Placer County Superior Court. I relied up
her.

I hired council to seek distribution, and there would have been no need for me to be present, but I did
inform him as well, if I were needed in court. I would need accommodation why and what. So both of
these officers of the court knew. What no one but the trustee knew, was that she would hire council
against me, to prevent Judge Holley's ruling, with only a 2 day window. That proceeding is the one I
should have been present. Had MC 410 been in place, the fact remains, that there was no time for me to
come, as I live in Oregon. and there would have been no time to arrange real time captioning, for me to be
in the court with the Judge. All others were on the phone due to COVID. So circumstances were not
accommodating for me to be present. He also was to have informed me and given me opportunity to be
present. But, there was only less then 2 days, from hearing on distribution Dec. 2, 2020, and hearing
Dec. 4, 2020.

I want to know why you, not the ADA coordinator wrote to me. denying me access yet again, and who is
the ADA administrator. Again, there are additional mitigating circumstances. I have not mentioned here,
that apply. And it appears they will need to be a pan of my grievance matters, even though they are
separate. The Judge himself, is at issue, as he allowed a hearing to proceed, against a perceived
IlItrIS•nwahrnailh n0t70rn natiuscahmn;lh,c.,Adc")caecirse, A A .. roc. A c -in ctn. a- - _ n .
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Ileahy@netzero.ner
courtadmin@placer.courts.ca.gov
Wed, Oct 06, 2021 09:23 PM
ADA Coordinator, ADA Complaint

Good morning. I tried to call and left a message yesterday. Since this issue is already past the 60 days to file. it is urgent that I file immediately. It does miss the 60 days passed since December
hearing. I did not know about this. until I just got the court files, so this complaint does fail within 60 days of discovery of discrimination.

The matter took place in several hearings in the court of Judge Glenn Holley. The hearings were October 2, 2020. November 2, 2020, December 2, 2020 and the specific hearing where discrimination
was the most evident was December 4, 2020. It was at this hearing, where Judge Holley was asked by Petitioner Jeff Galvin. to consider my state of mind to be Crazy or mentally ill. This was a
situation used by Judge Holley to influence his ruling and actions, against me. California Rule of Court 1.100 (a)(1) Definition of a disability to be known or perceived to exist. And CRC 1.100 (b)
Policy.

All petitions, responses and documents, are in the court files, for Probate Case S PR 0010445.

These are the people who knew of my disability, but did not request on my behalf, accommodation so I could be present. I did ask them to make sure I was able to participate in alt proceedings and
that I would need accommodation, by way of real time captioning for my deafness, and to sit close enough to read lips, and that I would need time, as the real time captioning requires a few minutes
to type and then for me to read and consider. No one asked for my accommodation and rather than tell the court about my need for low vision and deafness, that I lip read, also a problem for mask
wearing and that phone hearings are not doable, due to the various different voices and phones, being used in a conference call. I can not do that and participate.

Rather than tell the court of ray need and fill out a MF 410, the lawyers and Judge, entertained and mocked me, ruled against me and excluded me as they all. all of them, decided I was mentally
and a threat of litigation. Thus Judge Holley decided to make a set aside of $75,000 from the estate, on Dec 2, 2020, and based upon Jeff Galvin coming back of Dec 4. 2020. and argued that I was
mentally ill and I might, might. litigate. so Judge Holley opted to increase the sot aside to $100,000. I was not present. I was the only party to. not present. two people who were classified as not a part
to, but objectors, who claimed I was mentally ill and a trouble maker, hired council, Knowlton, and were present. This was layers of lawyers, and a Judge, all violating the ADA. CRC 1.100, (a) (1)
where it says to have a disability or be perceived as having one. If they really thought I was mentally ill, and so much so that Judge Holley sought to punish me with a huge set aside, then why did not
he request I be present and accommodated?

In truth I am disabled, buy not mentally ill, as was the accusation, but low vision and deaf. Both of the objectors, David Keenan and Veda Federighi knew as they are family. Yet they chose to exclude
me and accuse me of mental illness and inappropriate behavior and I was not notified, nor given opportunity to read the petition by John Knowlton, nor Jeff Galvin. until just this week. My own lawyer
Daniel Hunt's paralegal, Miranda Fernandez, who was also present for the hearings, told me I was thrown under the bus. I was given no chance to respond to such biblical discrimination and
treatment. t I did not know until I received and road the court petitions. And no one gave them to me. I had to order them and pay for them, to gel these files. Had I not done this, which I could not do
until the case closed. I would never have known.

The case is still open in Probate and could still be corrected. I humbly ask that this Federal Violation be considered and that I be given all opportunity to be heard and this travesty corrected.

These are the people who discriminated against me for a perceived disability, mental illness, and discriminated against me for a real disability of low vision and deafness and did not seek
accommodation. Had Judge Holley followed the ADA, and the lawyers, the outcome would have included my being present, accommodated and able to relate facts and dispel discriminatory remarks
and accusations.

Therese Adams, the Trustee, who was sworn to protect my rights and interests In the estate
Jeff Galvin. her council who was representing her interests of more billable hours, as wet as his own, for another 7 months from the set aside.
—These two were not looking out for my interests, per probate law. They used the set aside money for billable hours for 7 months.
John Knowlton, who claimed to be representing David Keenan the other beneficiary, Veda Federighi his wife and previous and current trustee along with Therese Adams. This is my brother and sister
in law, who both know I am deaf and have low vision. I have no history of mental illness, and if I did, I would require extra protection for accusations of such a biased and hateful nature.
Garin Clyma. who briefly represented David Keenan, Veda Federighi and Therese Adams in August of 2020, in Front of Judge Holley before turning the case over to Jeff Galvin.
Judge Glenn Holley who does this every day and knows the law, represents the law and is to uphold the law. It should have been suspect to him, when accusations of any disability came forward that
the disabled person be present and accommodated to participate.

These accusations were used to provide support to the theory that a huge set aside. $100000 was needed, to keep all players safe from my real disability or perceived disability of mental illness,
while excluding me from the process and court room. They took my voice and replaced it with a lie. It do not know if anyone was sworn it to provide this testimony, but if they were, it then included
perjury. But oven if they were not sworn in, just being in a court of law, and testifying before a Judge, things not supported in fact, and things that were actually being used to influence the court and
the rulings by Judge Holley. not to mention discriminatory.

If I were mentally ill, so much more should the court have made sure I was present, rather than a kangaroo court of bias, prejudice and discrimination.

Do you need anything else? I just wanted to file this via e mail right away, I will also snail mail it. I will include the comment from my lawyer's office of how the court threw me under the bus.

Linda Leahy, 9 pm, October 6. 2021.

nttps://weemailb.netzero.net/webmail/new/5?session_redirect.true&userinfo4ef044a534a5664ab605dd683be7be648,count=16336244048,cf=sp&ran... - 2/2
OCTOBER 11, 2021

ADA COORDINATOR
PLACER COUNTY SUPERIOR COURT
P. 0. BOX 619072
ROSEVILLE, CA 95661

RE: DISCRIMINATION COMPLAINT, FILED BY E MAIL AND FOLLOW UP
PAPER FILING. CASE # SPR 0010445, JUDGE HOLLEY
CALIFORNIA RULE OF COURT 1.100 (a)(1) defiinition
CALIFORNIA RULE OF COURT 1.100 (b) policy
ENCLOSED FIND MY MC-410 JUST FYI, IF NEEDED

TO WHOM IT MAY CONCERN,

HERE IS THE FOLLOW UP PAPER ADA COMPLAINT. I HAVE ALSO
FILED A CJC COMPLAINT AGAINST JUDGE HOLLEY, VIA ON LINE
COMPLAINT FORM. I USED ALL COURT CASE DOCUMENTS AS
REFERENCE, AS IT IS ALL IN THERE.

THE ISSUE IS THAT NO ONE ACCOMMODATED FOR ME TO BE
PRESENT, AT A DECEMBER 4, 2020 HEARING. I NOT ONLY HAVE TO
DRIVE DOWN FROM OREGON, BUT I HAVE A BRAIN TUMOR, LOSS OF
VISION AND MENIERE'S DISEASE RENDERING ME DEAR NO ONE,
EVEN THOUGH I ASKED, FILED A MC 410. I GUESS THE JUDGES FIRST
RULINGS WERE ADDRESSED AND IT WAS OVER. THEN THE TRUSTEE,
HIRED AN EXPENSIVE LAWYER, JEFF GALVIN, AND HE CAME IN TO
ARGUE THAT I WAS MENTALLY ILL, AN INDIRECT DISCRIMINATION,
AND BASED UPON THAT, HE WENT ON. HE WAS THE ONLY PERSON IN
THE COURT ROOM. NO ONE INFORMED ME, AND THAT IS ANOTHER
STORY. BUT, JUDGE HOLLEY, SHOULD HAVE KNOWN, THAT
DISCRIMINATION WAS AFOOT, WITH WORDS LIKE MENTALLY ILL,
AND SUE HAPPY BEING USED TO DESCRIBE ME, IN A VERY LENGTHY
DIATRIBE IN FRONT OF THE JUDGE TO REVERSE WHAT THE JUDGE
HAD JUST ORDERED 2 DAYS PRIOR. HE ALSO REQUESTED AND GOT A
$100,000 SET ASIDE, BASED SOLELY ON THE ARGUMENT THAT I WAS
MENTALLY ILL, A TROUBLE MAKER. SINCE THE JUDGE DID NOT USE
A TRANSCRIBER, WE WILL NEVER KNOW WHAT ALL WAS SAID
DAMMING A DISABLED PERSON, PERCEIVED OR REAL, IN ORDER TO

IRA 5h4f
.5:41
10/19/21, 3:44 PM NetZero Message Center

This is why I seek review by the ADA Administrator in your Superior Court. Who is your ADA
Administrator? I need this e mail and my original grievance submitted to them, or I can write it up for
them. I need their contact. Each Court in California, is to have both an ADA coordinator and an ADA
administrator who reviews the Coordinator's finding, if complainant requests in this format. I am seeking
such a review. Thank you. Linda Leahy October 19. 2021 at 9:45 am.

Please note: message attached

From: Court Administration
To: leahy@netzero.net-
Subject: RE: ADA Coordinator, ADA Complaint
Date: Mon. 18 Oct 2021 22:52:12 +MOO

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NETZ ER0 Message Center
From: Court Administration
To: "Ileahy@netzero.ner

Sent: Tue, Oct 19, 2021 03:24 PM
Subject: RE: ADA Coordinator, ADA Complaint
Response_Leahy_AD... (1.4MB)

Good afternoon,

Attached please find the Court's response to your ADA related correspondence.

Thank you,

cid:1mage001.png@01 D32D2A.EEF7F420 Court Administration
Superior Court of California, County of Placer
(916) 408-6000
www,placer.COurtS.ca,goy

From: Ileahy@netzero.net
Sent: Tuesday, October 19, 2021 10:08 AM
To: Court Administration
Subject: RE: ADA Coordinator, ADA Complaint

Good morning Mr. Chatters. I see that your title is Court Executive Officer. Are you also the ADA Coordinator? I was looking at the ADA procedures for filing an ADA complaint. What struck me as
questionable, were two things: one was the 60 day rule, and the other, is that

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October 13, 2023

Case Filing Date

July 27, 2023

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