arrow left
arrow right
  • VINCENT M. LUCY VS MATTHEW R. STALL Other Promissory Note/Collections Case (General Jurisdiction) document preview
  • VINCENT M. LUCY VS MATTHEW R. STALL Other Promissory Note/Collections Case (General Jurisdiction) document preview
  • VINCENT M. LUCY VS MATTHEW R. STALL Other Promissory Note/Collections Case (General Jurisdiction) document preview
  • VINCENT M. LUCY VS MATTHEW R. STALL Other Promissory Note/Collections Case (General Jurisdiction) document preview
  • VINCENT M. LUCY VS MATTHEW R. STALL Other Promissory Note/Collections Case (General Jurisdiction) document preview
  • VINCENT M. LUCY VS MATTHEW R. STALL Other Promissory Note/Collections Case (General Jurisdiction) document preview
  • VINCENT M. LUCY VS MATTHEW R. STALL Other Promissory Note/Collections Case (General Jurisdiction) document preview
  • VINCENT M. LUCY VS MATTHEW R. STALL Other Promissory Note/Collections Case (General Jurisdiction) document preview 
						
                                
Preview

                                20TRCV00137
                                  Assigned for all purposes to: Torrance Courthouse, Judicial Officer: Ramona See


Electronically FILED by Superior Court of California, County of Los Angeles on 02/11/2020 03:52 PM Sherri R. Carter, Executive Officer/Clerk of Court, by T. Rhodes,Deputy Clerk


                      1     Brad Baker (SBN: 065106)
                            Albro L. Lundy, III (SBN: 123133)
                      2     Evan R. Koch (SBN: 275144)
                            BAKER, BURTON & LUNDY,
                      3     A Professional Corporation
                            515 Pier A venue
                      4     Hermosa Beach, CA 90254
                            Telephone: (310) 3 76-9893
                      5     Facsimile: (310)376-7483

                      6     Attorneys for Plaintiff,
                            VINCENT M. LUCY
                      7

                      8                                SUPERIOR COURT OF THE STATE OF CALIFORNIA

                      9                                             FOR THE COUNTY OF LOS ANGELES

                    10
                    11      VINCENT M. LUCY,                     )                                       CASE NO:
                                                                 )
                    12                   Plaintiff,              )                                       COMPLAINT FOR:
                                                                 )
                    13      v.                                   )                                       (1) BREACH OF ORAL CONTRACT
                                                                 )
                    14                                           )                                       (2)COMMONCOUNT-ACCOUNTSTATED
                            MATTHEW R. STALL as Administrator of )
                    15      the ESTATE OF RICHARD J. STALL, JR., )                                       (3) BREACH OF WRITTEN CONTRACT
                            MATTHEW R. STALL as Trustee of THE   )
                    16      RICHARD J. STALL, JR. TRUST and      )                                       (4)COMMONCOUNT-ACCOUNTSTATED
                            DOES 1 through 50, Inclusive,        )
                    17                                           )
                                         Defendants.             )
                    18                                           )
                                                                 )
                    19                                           )
                                                                 )
                    20

                    21                 Plaintiff, VINCENT M. LUCY, alleges:

                    22                 1.          This action involves the refusal by the Estate and Trust of Decedent Richard J.

                    23      Stall, Jr., a California attorney, to repay large loans made to him by his friend and client for many

                    24      years, Plaintiff Vincent M. Lucy.

                    25                 2.          Plaintiff VINCENT M. LUCY (hereinafter "Plaintiff'), at all times herein was and

                    26      is a resident of Manhattan Beach in Los Angeles County, California.

                    27                 3.          Decedent Richard J. Stall, Jr. died on October 26, 2018. At the time of his death,

                    28      Decedent Richard E. Stall, Jr. was a resident of Los Angeles County, California.


                                                                                    Complaint for Damages
             4.      At all times mentioned herein, Decedent Richard J. Stall, Jr. was a longtime friend

 2   and longtime attorney of the Plaintiff.
 3           5.      The ESTATE OF RICHARD J. STALL, JR., sued herein as Defendant

 4   MATTHEW R. STALL as Administrator of the ESTATE OF RICHARD J. STALL, JR.

 5   (hereinafter "ESTATE") is the Probate Estate of Richard E. Stall Jr., decedent, Case No.

 6   19STB03149 with his son, Matthew R. Stall, now as the Personal Representative and

 7   Administrator of said Estate.

 8           6.      THE TRUST OF RICHARD J. STALL, JR. sued herein as Defendant

 9   MATTHEW R. STALL as Trustee of THE RICHARD J. STALL, JR. TRUST (hereinafter

1O "TRUST"), is a trust created under the laws of the State of California entered into in Los

11   Angeles, California on August 17, 2010 with Matthew R. Stall, son of Decedent Richard E. Stall,

12   Jr., now as trustee for said trust.

13           7.      "Notice of Administration of the Estate of Richard J. Stall, Jr.- Notice to

14   Creditors" was mailed to Plaintiff on August 29, 2019. Said Notice is attached hereto as Exhibit

15   1.
16           8.      Plaintiff served a Creditor's Claim on the ESTATE by mail on October 21 , 2019

17   in the sum of $383 ,631.18, plus $95 .45 per day commencing on October 16, 2019 based on a

18   loan made by the Plaintiff to Decedent Richard J. Stall, Jr. A true and correct copy of said

19   Creditor's Claim is attached hereto as Exhibit 2.

20           9.      Plaintiffs Creditor's Claim in the sum of $383 ,631.18 plus $95.45 per day was

21   rejected in its entirety by the ESTATE's personal representative, Matthew R. Stall on November

22   19, 2019. Said Rejection of the Creditor's Claim stated that the estimated value of the Estate was

23   $150,000, less then the amount owed to the plaintiff/creditor by Decedent Richard J. Stall, Jr. A

24   true and correct copy of said Rejection of Creditor' s Claim is attached hereto as Exhibit 3.

25           10.     Plaintiff served an additional Creditor' s Claim on the ESTATE by mail on

26   October 21, 2019 in the sum of $493,101.50, plus $41.09 per day commencing on October 16,

27   2019 based on a written promissory note for a loan made by the Plaintiff to Decedent Richard J.

28   Stall, Jr. A true and correct copy of said Creditor' s Claim is attached hereto as Exhibit 4 with a


                                           Complaint for Damages
     true and correct copy of said promissory note attached thereto.

 2           11.     Plaintiffs Creditor' s Claim in the sum of$493,101.50, plus $41.09 per day was

 3   rejected in its entirety by the ESTATE ' s personal representative, Matthew R. Stall, on November

 4   19, 2019. Said Rejection of the Creditor's Claim stated that the estimated value of the Estate was

 5   $150,000, less then the claimed amount owed to the Plaintiff/creditor by Decedent Richard J.

 6   Stall, Jr. A true and correct copy of said Rejection of Creditor's Claim is attached hereto as

 7   Exhibit 5.

 8           12.    The true names and capacities, whether individual, business, corporate, associate

 9   or otherwise, of the defendants named as DOES 1 through 50, inclusive, are unknown to Plaintiff

10   at this time. Therefore, Plaintiff sues these Defendants by such fictitious names. Plaintiff will

11   seek leave to amend this complaint to show the Defendants ' true names and capacities when the

12   same have been ascertained.

13           13.    On information and belie±: each of the Defendants and DOES 1 - 50 were and are

14   now, the personal representatives, beneficiaries, trustees, administrators, executors, agents, alter

15   egos, authorized representatives and/or employees of their co-Defendants, and in committing the

16   wrongful conduct alleged, were acting within the course and scope of such agency, service and/or

17   employment, and/or that all of the acts and/or commissions were authorized and/or ratified by

18   each Defendant, and/or were done with each Defendant ' s knowledge and/or consent.

19           14.    Plaintiff is allowed to bring suit against the Trustee of the TRUST because it has

20   been shown that the probate estate has insufficient assets to satisfy plaintiff's claims.

21                                     FIRST CAUSE OF ACTION

22                    (Breach of Oral Contract against all Defendants and Does 1-25)

23          15.     Plaintiff re-alleges and incorporates herein by reference all of the fore going

24   allegations in Paragraphs 1-14 of this complaint, inclusive.

25          16.     Plaintiff and Decedent Richard J. Stall, Jr. and Does 1-25 entered into an oral

26   agreement in 1993 in Los Angeles, California whereby Plaintiff loaned said Decedent the sum of

27   $348,418 .02 at 10% simple interest per annum, which interest was to be paid by Decedent

28   Richard J. Stall, Jr. each year in 12 equal monthly installments of $2,934.43 with said interest to


                                           Complaint for Damages
 1   continue being paid in monthly payments of $2,934.43 until Plaintiff demanded payment in full

 2   of the $348,418.02 loan from Decedent Richard J. Stall, Jr. By way of the Creditor's Claim filed

 3   on October 21 , 2019. All monthly payments of interest had been made by Decedent for

 4   approximately 25 years until his death. Attached hereto as Exhibit 2 are true and correct copies

 5   of samples of the Plaintiff's deposit slips for $2,934.43 and checks for $2,934.43 signed by

 6   Decedent Richard J. Stall, Jr. for 2016, 2017 and 2018 for interest payments on the $348,418.02

 7   loan. Included in Exhibit 2 is the October 10, 2018 check signed by the Decedent to the Plaintiff

 8   in the sum of $2,934.43 which was the last interest payment the Decedent made on the loan, just

 9   prior to his death.

10           17.     As set forth in Article IV B. on page 2 of The Richard J. Stall, Jr. Trust, original

11   Trustee and Trustor Richard J. Stall, Jr. acknowledged said debt to " Vincent M. Lucy" in the

12   sum of "$365 ,000 or so" for the successor Trustee to pay upon Richard J. Stall, Jr. 's death.

13           18.     After having received the "Notice of Administration of the Estate of Richard J.

14   Stall, Jr.- Notice to Creditors" on August 29, 2019, Plaintiff made demand on October 21, 2019

15   for full payment of this loan in the sum of $383,631.18 which includes 10% interest to October

16   15, 2019 plus $95.45 per day in interest thereafter.

17           19.     The oral agreement for repayment of the $383,631.18 loan including 10% per

18   annum interest to October 15 , 2019 from Plaintiff to Decedent Richard J. Stall, Jr. was breached

19   by Defendants, and each of them, and Does 1-25 on November 19, 2019 when Matthew R. Stall,

20   administrator of the Estate of Richard J. Stall, Jr. , rejected Plaintiff's claim in its entirety.

21           20.     From October 21, 2019 and thereafter demand has been made and continues to be

22   made by Plaintiff to all Defendants to pay to Plaintiff the amounts due on the 1993 loan for

23   $348,418 .02, including the interest thereon. All of said Defendants and Does 1-25 have refused

24   to pay the Plaintiff the amounts due and demanded, nor any sum whatsoever, thereby breaching

25   the terms of the 1993 oral agreement that payment would be made after 1994 on demand.

26           21.     Plaintiff has performed all obligations to Defendants and Does 1-25 except those

27   obligations Plaintiff was prevented or excused from performing.

28           22.     Plaintiff has suffered damages legally caused by the Defendants ' and Does 1-25


                                             Complaint for Damages
 1   breach of the agreement in the sum of$383,631.18 as of October 15 , 2019 and $95.45 per day

 2   thereafter in interest pursuant to the terms of the 1993 oral agreement.

 3           23.      Plaintiff is entitled to reasonable attorneys fees pursuant to Pro bate Code Section

 4   9354 (c) since Plaintiffs Creditors Claim was rejected in bad faith by Defendants, and each of

 5   them, and Does 1-25 .

 6                                     SECOND CAUSE OF ACTION

 7                  (Common Counts-Account Stated against all Defendants and Does 1-25)

 8           24.      Plaintiff re-alleges and incorporates herein by reference all of the foregoing

 9   allegations in Paragraphs 1-23 of this complaint, inclusive.

10           25.      Defendants and each of them and Does 1-25 owed Plaintiff money after they

11   entered into an oral agreement in 1993 in Los Angeles, California whereby Plaintiff loaned said

12   Decedent the sum of $348,418.02 at 10% simple interest per annum, which interest was to be

13   paid by Decedent Richard J. Stall, Jr. each year in 12 equal monthly installments of $2,934.43

14   with said interest to continue being paid in monthly payments of $2,934.43 until Plaintiff

15   demanded payment in full of the $348,418.02 loan from Decedent Richard J. Stall, Jr. All of said

16   monthly payments were made for approximately 25 years until Decedent's death. Attached

17   hereto as Exhibit 6 are true and correct copies of samples of the Plaintiffs deposit slips for

18   $2,934.43 and checks for $2,934.43 signed by Decedent Richard J. Stall, Jr. for 2016, 2017 and

19   2018 for interest payments on the $348,418 .02 loan. Included in Exhibit 6 is the October 10,

20   2018 check signed by the Decedent to the Plaintiff in the sum of $2,934.43 which was the last

21   interest payment the Decedent made on the loan.

22            26.     Plaintiff and Decedent Richard J. Stall, Jr. by words and/or conduct agreed that

23   the amount stated in the account of $348,418.02 at 10% simple interest per annum, was the

24   correct amount owed to Plaintiff by Decedent.

25           27.      Decedent Richard J. Stall, Jr. and Defendants and Does 1-25 by words and/or

26   conduct promised to pay the stated amount of $348,418.02 at 10% simple interest per annum, to

27   Plaintiff.

28           28.      Decedent Richard J. Stall, Jr. and Defendants and Does 1-25 have not paid


                                            Complaint for Damages
 1   Plaintiff all of the amounts owed under this account.

 2          29 .    The amount of money Defendants and Does 1-25 owes to Plaintiff on this account

 3   1s $383 ,631.18 as of October 15, 2019 and $95.45 per day thereafter in interest.

 4           30.    Less than four (4) years have lapsed since the last payment on account was made.

 5           31.    Plaintiff is entitled to reasonable attorneys fees pursuant to Probate Code Section

 6   9354 (c)since Plaintiffs Creditors Claim for said Account Stated was rejected in bad faith by

 7   Defendants and each of them and Does 1-25.

 8                                     THIRD CAUSE OF ACTION

 9                  (Breach of Written Contract against all Defendants and Does 26-50)

10           32 .   Plaintiff re-alleges and incorporates herein by reference all of the foregoing

11   allegations of this complaint set forth in paragraphs 1-31 , inclusive.

12           33.    Plaintiff and Decedent Richard J. Stall, Jr. and Does 26-50 entered into a written

13   agreement sometime after November 25, 1996 in Los Angeles County, California which

14   memorialized Plaintiffs loan to Decedent in the sum of $150 ,000 at 10% interest per annum to

15   be paid by Decedent Richard J. Stall, Jr. on demand. A true and correct copy of the written

16   Promissory Note signed by Decedent Richard E . Stall, Jr. is attached hereto as part of Exhibit 4.

17           34.    Since 1987, Decedent Richard Stall, Jr. and Plaintiff would meet socially. The

18   two of them would on average meet for breakfast, coffee and/or lunches three times per year in

19   addition to any professional meetings they might have.

20           35.    Since 1992, Decedent Richard J. Stall, Jr. was Plaintiff's business and personal

21   attorney.

22           36.    On at least 9 or 10 occasions over the years, Richard J. Stall, Jr. would ask

23   Plaintiff if Plaintiff wanted repayment at that time of the $150,000 promissory note with the

24   accumulated interest. Plaintiff would decline, responding to Richard that Plaintiff would let

25   Richard know when Plaintiff demanded repayment.

26           37.     Decedent Richard J. Stall, Jr. always stated to Plaintiff that Richard would be the

27   person who paid on the promissory note. The Decedent never referred to any third party trust

28   being responsible for repayment of the $150 ,000 promissory note.


                                            Complaint for Damages
 1            38.   Plaintiff never believed that anyone but Decedent Richard J. Stall, Jr., in his

 2   personal capacity, owed Plaintiff payment of the promissory note plus interest.

 3            39.   As set forth in Article IV B. on page 2 of The Richard J. Stall, Jr. Trust, original

 4   Trustee and Trustor Richard J. Stall, Jr. acknowledged this Promissory Note and debt to Plaintiff

 5   for the successor Trustee to pay upon Richard J. Stall, Jr. 's death.

 6            40.   After having received the "Notice of Administration of the Estate of Richard J.

 7   Stall, Jr.- Notice to Creditors" on August 29, 2019, Plaintiff made demand on October 21, 2019

 8   for payment of this Note in the sum of $493,101.50 which includes the $150,000 principal and

 9   10% interest from November 25, 1996 to October 15 , 2019 plus$ 41.09 per day thereafter.

10            41.   The November 25, 1996 Promissory Note was breached by Defendants and each

11   of them and Does 26-50 on November 19, 2019 when Matthew R. Stall, Administrator of the

12   Estate of Richard J. Stall, Jr., rejected in its entirety Plaintiff's claim and demand for payment of

13   the $493,101.50 owed to Plaintiff.

14            42.   From October 21, 2019 and thereafter demand has been made and continues to be

15   made to all Defendants by Plaintiff to pay to Plaintiff the amounts due on the November 25,

16   1996 Promissory Note, including the interest thereon. All of said Defendants and Does 26-50

17   have refused to pay the Plaintiff the amounts due and demanded, thereby breaching the terms of

18   the November 25, 1996 Promissory Note that payment would be made after July 25, 1997 on

19   demand.

20            43.   Plaintiff has performed all obligations to Defendants and Does 26-50 except those

21   obligations Plaintiff was prevented or excused from performing.

22            44.   Plaintiff has suffered damages legally caused by the Defendants ' and Does 26-50

23   breach of the written agreement in the sum of$493,101.50 as of October 15 , 2019, and $41.09

24   per day thereafter in interest pursuant to the terms of the November 25 , 1996 Promissory Note.

25            45.    Under the terms of the November 25, 1996 Promissory Note, Plaintiff is entitled

26   to reasonable attorneys fees as the court may determine. In addition, Plaintiff is entitled to

27   attorneys fees pursuant to Probate Code Section 9354 (c) for bad faith rejection of a Creditor' s

28   Claim.


                                            Complaint for Damages
 1                                       FOURTH CAUSE OF ACTION

 2                   (Common Counts-Account Stated against all Defendants and Does 26-50)

 3            46.      Plaintiff re-alleges and incorporates herein by reference all of the foregoing

 4   allegations in Paragraphs 1-45 of this complaint, inclusive.

 5            47.       Defendants and each of them and Does 26-50 owed Plaintiff money from a loan

 6   from Plaintiff to Richard J. Stall which was later memorialized in a promissory note dated

 7   November 25 , 1996 in Los Angeles County, California. The note entitled Plaintiff to a sum of

 8   $150,000 at 10% interest per annum to be paid by Decedent Richard J. Stall, Jr. on demand. A

 9   true and correct copy of the written promissory note signed by Decedent Richard E. Stall, Jr. is

1O attached hereto as part of Exhibit 4.
11            48.       Plaintiff and Decedent Richard J. Stall, Jr. the original trustee and trustor of

12   Defendant TRUST by words or conduct agreed that the amount stated in the account of $150,000

13   at 10% simple interest per annum from November 25 , 1996 to the time of Decedent' s death on

14   October 26, 2018, was the correct amount owed to Plaintiff by Decedent Richard J. Stall, Jr.

15   and Does 26-50 .

16            49.       Decedent Richard J. Stall, Jr. and Defendants and Does 26-50 by words and/or

17   conduct promised to pay the entire stated amount of the loan of $150,000 at 10% simple interest

18   per annum from November 25 , 1996 upon demand.

19            50 .      Decedent Richard J. Stall, Jr. and Defendants and Does 26-50 have not paid

20   Plaintiff any of the amount owed under this account.

21            51.       Less than four (4) years have elapsed since demand has been made for payment.

22            52.       The amount of money Defendants and Does 26-50 owe to Plaintiff on this account

23   1s $493,101.50 as of October 15, 2019 and $41.09 per day thereafter in interest.

24            53.       Under the terms of the November 25, 1996 Promissory Note, Plaintiff is entitled

25   to reasonable attorneys fees as the court may determine. In addition, Plaintiff is entitled to

26   attorneys fees pursuant to Probate Code Section 9354 (c) for bad faith rejection of a Creditor' s

27   Claim.

28   ///


                                               Complaint for Damages
 1          WHEREFORE, Plaintiff prays for judgment against Defendents, and each of them, as

 2   follows:

 3                               First Cause of Action Against All Defendants

 4          1.    For compensatory damages in the sum of$383,631.18 through October 15 , 2019;

 5          2.    Prejudgment interest in the sum of $95 .45 per day from October 15, 2019 until

 6                 fully paid;

 7          3.    For reasonable attorneys ' fees pursuant to Probate Code Section 9354 (c);

 8          4.     For costs of the suit; and

 9          5.    For such other relief as this court deems just and proper.

10                             Second Cause of Action Against All Defendants

11          1.     For compensatory damages in the sum of $383,631.18 through October 15 , 2019;

12          2.     Prejudgment interest in the sum of $95.45 per day from October 15, 2019 until

13                 fully paid;

14          3.     For reasonable attorneys ' fees pursuant to Probate Code Section 9354(c) ;

15          4.     For costs of the suit; and

16          5.     For such other relief as this com1 deems just and proper.

17                               Third Cause of Action Against All Defendants

18          1.     For compensatory damages in the sum of $493,101.50 through October 15 , 2019 ;

19          2.     Prejudgment interest in the sum of $41.09 per day from October 15 , 2019 until

20                 fully paid;

21          3.     For attorneys ' fees pursuant to contract and pursuant to Probate Code Section

22                 9354 (c).

23          4.     For costs of the suit; and

24          5.     For such other relief as this court deems just and proper.

25                             Fourth Cause of Action Against All Defendants

26          1.     For compensatory damages in the sum of $493 , 101.50 through October 15, 2019;

27          2.     Prejudgment interest in the sum of $41.09 per day from October 15 , 2019 until

28                 fully paid;


                                            Complaint for Damages
 1         3.    For attorneys' fees pursuant to Probate Code Section 9354 (c) .

 2         4.    For costs of the suit; and

 3         5.    For such other relief as this court deems just and proper.

 4
 5   DA TED: February   j_l_, 2020              BAKER, BURTON & LUNDY
                                                A Professional Corporation
 6
 7
                                        By:
 8
                                                Attorneys for Plaintiff Vincent M. Lucy
 9

10

11

12

13

14
15

16
17

18

19
20

21

22

23

24

25

26
27

28


                                        Complaint for Damages
EXHIBIT 1
                                                                                                                                              DE -157


                                                   NOTICE OF ADMINISTRATION
                                                          OF i HE ESTATE OF

                                                             Richard J. Stall Jr.
                                                                      (NAME)


                                                                 DECEDENT

                                                          NOTICE TO CREDITORS

  1.          (Name):      Matthew Richard Stall
           (Address):      Law Office of Edgar Saenz
                           8921 S, Sepulveda Blvd., Suite 101
                           Los Angeles, California 90045
        (Telephone):       (310) 417-9900
        is the personal representative of the ESTA TE OF (name) :                     Richard J. Stall, Jr.                 , who is deceased.

 2. The personal representative HAS BEGUN ADMINISTRATION of the decedent's estate in the
        a. SUPERIOR COURT OF CALIFORNIA, COUNTY OF (specify):                 Los Angeles
            STREET ADDRESS:  111 N. Hill St.
           MAILINGADDRESS: 111 N, Hill St.

          cITY AND 2IP cooE: Los Angeles, CA 90012
              BRANCH NAME: Central

       b. Case number (specify): 19 STPB 03149
3. You must FILE YOUR CLAIM with the court clerk (address in item 2a) AND mail or deliver a copy to the personal representative
   before the last to occur of the following dates:
       a. four months after (date) : /     June 14, 2019           /, the date letters (authority to act for the estate) were first
          issued to a general personal representative, as defined in subdivision (b) of section 58 of the California Probate Code, OR
       b. 60 days after (date) : /     August 29, 2019         / , the date this notice was mailed or personally delivered to you .
4. LATE CLAIMS: If you do not file your claim within the time required by law, you must file a petition with the court for permission to
   file a late claim as provided in Probate Code section 9103. Not all claims are eligible for additional time to file. See section 9103(a).

       EFFECT OF OTHER LAWS: Other California statutes and legal authority may affect your rights as a creditor. You may want
       to consult with an attorney knowledgeable in California law.

    WHERE TO GET A CREDITOR'S CLAIM FORM: If a Creditor's Claim (form DE-172) did not accompany this notice, you may
    obtain a copy of the form from any superior court clerk or from the person who sent you this notice. You may also access
    a fillable version of the form on the Internet at www.courts.ca.gov/forms under the form group Probate-Decedents'
    Estates. A letter to the court stating your claim is not sufficient.
    FAILURE TO FILE A CLAIM: Failure to file a claim with the court and serve a copy of the claim on the personal
    representative will in most instances invalidate your claim.
   IF YOU MAIL YOUR CLAIM: If you use the mail to file your claim with the court, for your protection you should send your
   claim by certified mail, with return receipt requested. If you use the mail to serve a copy of your claim on the personal
   representative, you should also use certified mail.


   Note: To assist the creditor and the court, please send a blank copy of the Creditor's Claim form with this notice.

                                                      (Proof of Service by Mail on reverse)                                                Pago 1 of 2

Fonn Adopted for Mandatory Use                                                                                               Ptoboto Code, §§ 905 0, 9052
  Judicial Council of California
                                           NOTICE OF ADMINISTRATION TO CREDITORS                                                      \'AV\'1.courls.ca.gov
 DE-1 57 (Rev. January 1, 20131                       (Probate-Decedents' Estates)
                                                                                                                                             DE-157
                                                                                                                  CASE NUMBER:
         ESTATE OF (Name):
                                              Richard J. Stall, Jr.                                              19 STPB 03149
     -                                                                                            DECEDENT

                                                                                [Optional]
                                                                     PROOF OF SERVICE BY MAIL
     1. I am over the age of 18 and not a party to this cause. I am a resident of or employed In the county where the mailing occurred.
     2. My residence or business address is (specify):
           8921 S. Sepulveda Blvd., Ste. 101
           Los Angeles, CA 90045
     3. I served the foregoing Notice of Administration to Creditors D         and a blank Creditors Claim form• on each person named
        below by enclosing a copy In an envelope addressed as shown below AND
        a. [lJ depositing the sealed envelope with the United States Postal Service with the postage fully prepaid.
        b.   D    placing the envelope for collection and mailing on the date and at the place shown in item 4 following our ordinary
                  business practices. I am readily familiar with the business's practice for collecting and processing correspondence for
                  mailing. On the same day that correspondence Is placed for collection and mailing, it Is deposited in the ordinary course
                  of business with the United States Postal Service in a sealed envelope with postage fu!ly prepaid.

  4. a. Date of deposit: August               29, 2019                  b. Place of deposit (city and state):   Los Angeles, California

  I declare under penalty of perjury under the laws of the State of California that the foregoing is true and ·correct.

  Date:     AVG- u-rr            2..'cf, 2, 0    I9
                                  Mladen Singer
                                   (TYPE OR PRINT NAME)                                                          (SIGNATURE OF DEClARANT)

                                      NAME AND ADDRESS OF EACH PERSON TO WHOM NOTICE WAS MAILED

                            Name of 12erson                                       Address (number, street, city, state, and zip code)

 1.      !First Financial Bank                                 255 East Fifth Street, Suite 700
                                                               Cincinnati, OH 45202
                                                           1
 2.
           =========================~:=:========================================================::::
                                      515 North Sepulveda Boulevard, Suite D
          Law Office of Steven F. Carvel
          (Courtesy Copy)                                      Manhattan Beach, CA 90266

 3.
         ~===================! 34
         !Vincent Michael Lucy                                   Fairway Drive.
                                                               ~anhattan Beach, CA 90266
                                                           1
4.
         ~====================
         I!======================I~=================================================!
         I::=:====================::I;:=::::::::==========================================~
5.


6.


7.
         I ===================/ ;:===================================================~
      I ===========================:' :==========================================================
      I _ ______,/,____ _
8.


      D        List of names and addresses continued in attachment. (You may use form PO~),30(P) to show additional persons to whom a
               copy of this notice was malled. Do not use page 2 of this form or form POS-030 1P) to show that you personally delivered a
               copy of this notice to a creditor. You may use forms POS-020 and POS-020(P) f,ir that purpose.)
• NOTE: To assist the creditor and the court, please send a blank copy of the Creditor's Claim (form DE- 172) with the notice.
DE-167 IRov, Jonuo,y 1, 20131
                                                          NOTICE OF ADMINISTRATION TO CREDITORS                                             Page 2 or 2

                                                                     (Probate-Decedents' Estates)
EXHIBIT 2
Electronically FILED by Superior Court of California , County of Los Angeles 10/2 1/20 19 12:07 PM Sherri R. Carter, Executive Officer/Clerk, By A Malfavo n, Deputy Clerk




                                                                                                                                                                                  DE-172 ·
                   ATTORNEY OR PARTY V\1THOUT ATTORNEY (Nema, s/a/a bar number, and address}:                 TELEPHONE AND FN< NDS,;                   FOR COURT USE ONLY
               _ BRAD N, BAKER (SBN 065106)                                                                       310-376-9893
                 BAKER,BURTON &LUNDY,P.C,                                                                         310-376-7483
                 515 PIER A VENUE
                 HERMOSA BEACH, CA 90254
                   AHORNEY FOR (Name}:
                   SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS                                    ANGELES
                                       111 NORTH HILL STREET
                         STREET ADDRESS;
                      MAILING ADDRESS; 111 NORTH HILL STREET
                     CITYANOZIPCODE; LOS ANGELES, CA 90012
                         BRANCH NAME: CENTRAL

                ESTATE OF (Name):

                RICHARD J. STALL, JR
                                                                                                                        DECEDENT
                                                                                                                                        CASE NUMBER:
                                                             CREDITOR'S CLAIM
                                                                                                                                                       19STPB03149

                   You must file this claim with the court clerk at the court address above before the LATER of (a) four months after the date letters
                   (authority to act for the estate) were first Issued to the personal representative, or (b) sixty days after the dale the Notice of
                   Administration was given to the creditor, If notice was given as provided in Probate Code section 9051. You must also mail or
                   deliver a copy of this claim to the personal representative and his or her attorney, A proof of service Is on the reverse.
                   WARNING: Your claim will in most Instances be invalid If you do not properly complete this form, file It on time with the court, and
                   mall or deliver a copy to the personal representative and his or her attorney,
              1. Total amount of the claim: $ 383,631.18 plus $95 .45 per day
              2, Claimant (name): VINCENT M, LUCY
                 a, Q'.J an individual
                 b,   D  an individual or entity doing business under the fictitious name of (specify):

                   c. D  a partnership. The person signing has authority to sign on behalf of the partnership.
                   d, D  a corporation. The person signing has authority to sign on behalf of the corporation,
                   e. D other (specify):
              3. Address of claimant (specify): 34 Fairway Drive, Manhattan Beach, CA 90266

              4. Claimant Is            [l] the creditor        D       a person acting on behalf of creditor (stete reason):



          5. D Claimant Is D the personal representative D the attorney for the personal representative.
          6, I am authorized to make this claim which Is just and due or may become due. All payments on or offsets to the claim have been
              credited. Facts supporting the claim are    D on reverse D attached.
          I declare under penalty of perjury under the laws of the State of California t~f e for oln$Js'true and correct.       _ ________ •-..
          Date:                                                                                                V           V             __ _           , /}    .L.               _)
                                      VINCENT M. LUCY                                                         ~     ~-7,        -   ,/        ~ ~,.       /           )   _

                                                                                                                                        (s1ONATURE oF cLAliitANti·            .   ___...
          •    •     •    •   ·   ·   (TYPE oR PR1Ni- NAME.AND 11rLEi   •   •   •   •
                                                              INSTRUCTIONS TO CLAIMANT
                                                                                        •   • •


         A On the reverse, Itemize the claim and show the date the service was rendered or the debt Incurred. Describe the Item or serv1c in
                                                                                                                                                                              C
              detail, and Indicate the amount claimed for each Item. Do not Include debts incurred after the date of death, except funeral claims.
         B. If the clalm Is not due or contingent, or the amount Is not yet ascertainable, state the facts supporting the claim.
         C. If the claim is secured by a note or other written Instrument, the original or a copy must be attached (state why original is unava//able.)
              if secured by mortgage, deed of trust, or other lien on property that Is of record, It Is sufficient to describe the security and refer to
              the date or volume and page, and county where recorded. (See Prob, Code, § 9152,)
         D. Mall or take this original claim to the court clerk's office for filing. If mailed, use certified mall, with return receipt requested.
         E. Mall or deliver a copy to the personal representative and his or her attorney. Complete the Proof of Mai/Ing or Personal Delivery on
             the reverse.
         F, The personal representative or his or her attorney will notify you when your claim Is allowed or rejected,
         G. Claims against the estate by the personal representative and the attorney for the personal representative must be flied within the
            claim period allowed In Probate Code section 9100. See the notice box above.
                                                                      (Continued on reverse)
             Form Approvod by lh•                                                                                                  Probola Code,§§ 0000 el soq., 9163
          Judicial Council o/ Callromla                               CREDITOR'S         CLAIM
          DE-172 fRov. January 1, 1998)                                                           (Probate)
    ESTATE OF (Name) :                                                                                   CASE NUMBER:

      RICHARD J. STALL, JR.                                                                   DECEDENT                  19STPB03149
                                                   FACTS SUPPORTING THE CREDITOR'S CLAIM
                                                     [ZJ See attachment (if space ls insufficient)
         Date of item                                             Item and supporting facts                                       Amount claimed
            1993               The sum of $348,418.02 was borrowed by the decedent who paid 10% per                            As of October
                               annum simple interest in 12 equal monthly installments of $2,934.42 each.                         15, 2019 the
                               These payments were made for years and years starting in 1993 and                                       sum of
                               continued until October of 2018 when decedent died. The executor is aware                         $383,631.18
                               of this loan, and as an officer of the Court would hopefully be truthful in                     plus interest at
                               acknowledging this debt.                                                                            the rate of
                                                                                                                              $95.45 per day.
                               Attached hereto are a sampling of the payments made by the decedent for
                               2016, 2017, 2018. More cancelled checks can be provided if requested.




                                                                                                                    TOTAL:    $
                PROOF OF           [ZJ MAILING â–¡ PERSONAL DELIVERY                            TO PERSONAL REPRESENTATIVE
                                (Be sure to mall or take the original to the court clerk's office for filing)
 1. I am the creditor or a person acting on behalf of the creditor. At the time of mailing or delivery I was at least 18 years of age.
 2. My residence or business address Is (specify): 515 PIER AVENUE, HERMOSA BEACH, CA 90254

 3. I mailed or personally delivered a copy of this Creditor's Claim to the personal representative as follows (check either a orb below):
    a. [lJ Mall. I am a resident of or employed in the county where the mailing occurred.
              (1) I enclosed a copy in an envelope AND
                  (a)          D
                            deposited the sealed envelope with the United States Postal Service with the postage fully prepaid.
                  (b) [lJ placed the envelope for collection and mailing on the date and at the place shown in items below following
                            our ordinary business practices. I am readily familiar with this business' practice for collecting and
                            processing correspondence for malling. On the same day that correspondence Is placed for collection and
                            mailing, it Is deposited in the ordinary course of business with the United States Postal Service In a sealed
                            envelope with postage fully prepaid .
              (2) The envelope was addressed and mailed first-class as follows:
                  (a) Name of personal representative served: Matthew Richard Stall
                  (b) Address on envelope: Law Office of Edgar Saenz
                                                        8921 S. Sepulveda Blvd. Suite 101, Los Angeles, CA 90045
                       (c) Date of mailing: 10/21/2019
                       (d) Place of mailing (city and state):   l-lt::rmosa Beach, CA 90254
    b.    D       Personal de/Ivery. I personally delivered a copy of the claim to the personal representative as follows:
                  (1) Name of personal representative served:
                  (2) Address where delivered:

                  (3) Date delivered:
                  (4) Time delivered:
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: 10/21/2019

                          WH1TNEY RICE
                     (TYPE OR PRINT NAME OF CLAIMANT)
DE-172 (Rev. January 1,19981
                                                                                   â–º
                                                                                                                                          Page two
                                                                 CREDITOR'S CLAIM
                                                                     (Probate)
                                                                                                                         CHECKING J'x:1'
         CHASEC.'l                                                              DEPOSIT                                   SAVINGS     D
                                                                                                                      CHASE LIQUID 0
        Today's Dalo                                                                                                         R/T 500001020

           I ;J___7nJ/1~0/
        crs107        I nn1 jG    le    ·                                                          CASH
                                                                                                                  â–º
0         v,                                M J-,_, y
,,
rn
                  ·Y\ ~ " '


        Sign Here (If cash la rscslved from lhl• depo,Jt) -· -- ---- - - • · • • - • • • •;
                                                                                                   CHECK
                                                                                                                  â–º

0       X
"'-t
-      NIJOGO-CH (Ri:rt, 07/12)   6<)17029 bW111

                                            T S\lr\ you, accounl nurnber htr•
                                                                                          '''< â–º
                                                                                                   SUBTOTAL


                                                                                                   Cf,,SH SACK
                                                                                                                  â–º

                                                                                                                  â–º



                                                                                                          TOTAL   $
                                                                                                                   CHECKING    if
         CHASEO                                                         DEPOSIT                                     SAVINGS    0
                                                                                                                CHASE LIQUID   0
                                                                                                                      M 500001020

                                                                                    CASH

C,
,,'"                                                                                CtiECK


                                                                                    T°.:,AELR FSRl o0M   1,,.


0       Sign Hore/II cnsh I• recolved from th/u depo8ff) ------------- ----- -,     0 '"         0•      ,,.

en      X                                                                     :,'
...
-      NIXM-CH \Aw. 01/12)

                                Y !ltu1   yQIH   1u;:counl num~r here
                                                                              ,

                                                                              ''
                                                                               Lâ–º
                                                                                    SUBTOTAl


                                                                                    CASH BACK
                                                                                                         â–º

                                                                                                         â–º



                                                                                           TOTAL$
                                                                                                                       CHECKING     0
                                                                           DEPOSIT                                      SAVINGS     0
                                                                                                                    CHASE LIQUID    0
                                                                                                                          RIT 500001020


                                                                                                              â–º
                                                                                               C~SH


                                                                                               CHE CK
                                                                                                              â–º       :l.131 -15
 Sign Hore (II c•sh I• ror:o/rod from this dapa>II) - - - - • • • - - - - - - - - - - - - ;    ~~~~~~iEII ►       -------
 X                                                                                        :    SUOTOTAL       â–º
Nl:>ooO-CH {Hw. 07112)   60174729 o.s.1 1/J
                                                                                          ''