On September 16, 2016 a
Complaint,Petition
was filed
involving a dispute between
Brown, Eloyce,
Brown, Jerry,
Pacheco, Annelise,
and
Brown, Eloyce,
Brown, Jerry,
for Petition for Letters of Administration
in the District Court of San Bernardino County.
Preview
SUPERIOR COURt OF CALIFORNIA
1 LAW OFFICE OF MARK W REGUS II COUNTY OF SAN BERNARDINO
876 N Mountain Ave Suite 200i SAN BERNARDINO DISTRICT
Upland CA 91786
2
SEP 05 2018
Tel 909 938 2289
3
MARK W REGUS II SBN 279653 p d
4
BY
ANYA
A O PUTY
1
Attorney for Petitioner Annelise Pacheco
5
SUPERIOR COURT OF THE STATE OF CALIFORNIA
6
FOR THE COUNTY OF SAN BERNARDINO
7
8
ESTATE OF Case No PROPS 1600930
9 Case N
TROY A BROWN aka TROY BROWN i Ql
10 COMPLAINT FOR FRAUD AGAINST
JERRY L BROWN ELOYCE BROWN
1 ROBERT PATRICK PA1tKER AND AMY
LYNN PARKER
12
13
31 2
pC i
4 rfp
ANNELISE PACHECO an individual
is
Plaintiff
16
vs
1
JERRY L BROWN an individual ELOYCE
ig
BROWN an individual ROBERT PATRICK
PARKER an individual AMY LYNN
19
pARI ER an individual DOES 1 through 10
20 Defendants
21
22
23
Plaintiff Annelise Pacheco Plaintiff hereby sets forth the following Complaint for Fraud
24 against
Jerry L Brown Eloyce Brown Robert Patrick Parker and
Amy Lynn Parker Defendants
25
In accordance therewith Plaintiff alleges as follows
26
VENUE AND PARTIES
27 1 Plaintiff Annelise Pacheco is and at all times herein mentioned was a resident of the
28
County of San Bernardino State of California
1
COMPLAINT FOR FRAUD
1 2 Defendants Jerry L Brown and Eloyce Brown is and at all times herein mentioned
2
was a resident of the County of San Bernardino State of California
3 3 Defendants Robert Patrick Parker and Amy Lynn Parker is and at all times herein
4
mentioned was a resident of the County ofRiverside State of California
5 4 Plaintiff is ignorant ofthe true names and capacities of defendants sued herein as DOES
6 1 through 10 inclusive therefore these defendants fictitious
and sues
by such names Plaintiff will
amend this complaint to allege their true names and capacities when ascertained
8 5 Plaintiffis informed and believes and thereon alleges that at all times herein mentioned
9
each of the defendants sued herein was the agent and employee of each of the remaining defendants
10
and was at all times acting within the purpose and scope of such agency and employment
11 6 Venue is proper in this County because because a substantial part of the events or
12
omissions giving rise to the claims occurred in this County
13 INTRODUCTION
14 7 Plaintiff is the natural child of Decedent Troy Brown Decedent
15 8 Jerry L Brown and Eloyce Brown are the parents of Decedent Troy Brown
6 9 Decedent Troy Brown died without a will
17 10 Upon Jerry L Brown and Eloyce Brown learning that they would not inherit
t8
Decedent s real property Jerry L Brown and Eloyce Brown created a fraudulent will for Decedent
19
identifying Jerry L Brown and Eloyce Brown as the sole heirs of the estate of Decedent Said will is
20
attached hereto as Exhibit A and incorporated herein by reference
2 t 11
Robert Patrick Parker and Amy Lynn Parker are close friends of Jerry L Brown and
22 Eloyce Brown Robert Patrick Parker and Amy Lynn Parker agreed to serve as witnesses to the
23 fraudulent will so as to ensure that Plaintiff and her siblings would not inherit from Decedent
24 12 Jerry L Brown then used the fraudulent will to file a Petition for Probate of the Estate
25
of Troy Brown and thereby transfer Decedent s real property to Jerry L Brown and Eloyce Brown
26 13 In particular the fraudulent will made a specific gift ofDecedent s real property located
27 at 729 N Arrowhead Ave Rialto CA 92376 to his parents
28
2
COMPLAINT FOR FRAUD
Document Filed Date
September 05, 2018
Case Filing Date
September 16, 2016
Category
Petition for Letters of Administration
Status
Under Court Supervision
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SUPERIOR COURt OF CALIFORNIA 1 LAW OFFICE OF MARK W REGUS II COUNTY OF SAN BERNARDINO 876 N Mountain Ave Suite 200i SAN BERNARDINO DISTRICT Upland CA 91786 2 SEP 05 2018 Tel 909 938 2289 3 MARK W REGUS II SBN 279653 p d 4 BY ANYA A O PUTY 1 Attorney for Petitioner Annelise Pacheco 5 SUPERIOR COURT OF THE STATE OF CALIFORNIA 6 FOR THE COUNTY OF SAN BERNARDINO 7 8 ESTATE OF Case No PROPS 1600930 9 Case N TROY A BROWN aka TROY BROWN i Ql 10 COMPLAINT FOR FRAUD AGAINST JERRY L BROWN ELOYCE BROWN 1 ROBERT PATRICK PA1tKER AND AMY LYNN PARKER 12 13 31 2 pC i 4 rfp ANNELISE PACHECO an individual is Plaintiff 16 vs 1 JERRY L BROWN an individual ELOYCE ig BROWN an individual ROBERT PATRICK PARKER an individual AMY LYNN 19 pARI ER an individual DOES 1 through 10 20 Defendants 21 22 23 Plaintiff Annelise Pacheco Plaintiff hereby sets forth the following Complaint for Fraud 24 against Jerry L Brown Eloyce Brown Robert Patrick Parker and Amy Lynn Parker Defendants 25 In accordance therewith Plaintiff alleges as follows 26 VENUE AND PARTIES 27 1 Plaintiff Annelise Pacheco is and at all times herein mentioned was a resident of the 28 County of San Bernardino State of California 1 COMPLAINT FOR FRAUD 1 2 Defendants Jerry L Brown and Eloyce Brown is and at all times herein mentioned 2 was a resident of the County of San Bernardino State of California 3 3 Defendants Robert Patrick Parker and Amy Lynn Parker is and at all times herein 4 mentioned was a resident of the County ofRiverside State of California 5 4 Plaintiff is ignorant ofthe true names and capacities of defendants sued herein as DOES 6 1 through 10 inclusive therefore these defendants fictitious and sues by such names Plaintiff will amend this complaint to allege their true names and capacities when ascertained 8 5 Plaintiffis informed and believes and thereon alleges that at all times herein mentioned 9 each of the defendants sued herein was the agent and employee of each of the remaining defendants 10 and was at all times acting within the purpose and scope of such agency and employment 11 6 Venue is proper in this County because because a substantial part of the events or 12 omissions giving rise to the claims occurred in this County 13 INTRODUCTION 14 7 Plaintiff is the natural child of Decedent Troy Brown Decedent 15 8 Jerry L Brown and Eloyce Brown are the parents of Decedent Troy Brown 6 9 Decedent Troy Brown died without a will 17 10 Upon Jerry L Brown and Eloyce Brown learning that they would not inherit t8 Decedent s real property Jerry L Brown and Eloyce Brown created a fraudulent will for Decedent 19 identifying Jerry L Brown and Eloyce Brown as the sole heirs of the estate of Decedent Said will is 20 attached hereto as Exhibit A and incorporated herein by reference 2 t 11 Robert Patrick Parker and Amy Lynn Parker are close friends of Jerry L Brown and 22 Eloyce Brown Robert Patrick Parker and Amy Lynn Parker agreed to serve as witnesses to the 23 fraudulent will so as to ensure that Plaintiff and her siblings would not inherit from Decedent 24 12 Jerry L Brown then used the fraudulent will to file a Petition for Probate of the Estate 25 of Troy Brown and thereby transfer Decedent s real property to Jerry L Brown and Eloyce Brown 26 13 In particular the fraudulent will made a specific gift ofDecedent s real property located 27 at 729 N Arrowhead Ave Rialto CA 92376 to his parents 28 2 COMPLAINT FOR FRAUD