Complaint,Petition: IN THE MATTER OF THE ROSIA L. HART REVOCABLE TRUST

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                                IEMA

SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

Document Scanning Lead Sheet
Aug-20-2012 9:01 am

Case Number: PTR-06-288755
Filing Date: Aug-17-2012 9:00
Filed by: GINA R. S. GONZALEZ
Juke Box: 001 Image: 03730296
DECLARATION

IN THE MATTER OF THE ROSIA L. HART REVOCABLE TRUST

001P03730296

Instructions:
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Andrew K. Schultz (State Bar No, 215917)
WITHERSPOON & SIRACUSA

1550 Bryant Street, Suite 875 E
San Francisco, CA 94103 San Fraps

Telephone (415) 552-1814
Fax (415) 552-2158
aschultz@witsir.com

Attorneys for Herb Thomas,

Successor Trustee Deputy Clerk

SUPERIOR COURT OF THE STATE OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO

Case No. PTR-06-288755
THE ROSIA L. HART
REVOCABLE TRUST
dated May 19, 2004

DECLARATION OF ATTORNEY RE: RE-
QUEST TO SPECIALLY SET PETITION
FOR INSTRUCTIONS REGARDING THE
MANAGEMENT OF THE SETTLOR’S
REAL PROPERTY AND FINANCES

Cross Ref. Case No. PCN-06-288756
Conservatorship of Rosia Lee Hart

Herb Thomas, as Successor Trustee of the Rosia L. Hart Revocable Trust, and also as
Conservator of the Estate of Rosia L. Hart, the Settlor, presents his Petition for Instructions
Regarding the Management of the Settlor’s Real Property and Finances, alleging:

1, Andrew K. Schultz, declare:

1. lam an attorney at law in good standing, duly licensed to practice law in the
State of California, and | represent the petitioner in these proceedings, Herb Thomas, a
licensed, professional conservator, as Trustee of The Rosia L. Hart Revocable Trust (the

“Trust”).

DECLARATION TO SPECIALLY SET T Case No. PTR-06-288755eo oe ID

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2. Petitioner's amended third accounts as both Trustee of the Trust and Conserva-
tor of the Estate of the Settlor are currently scheduled for hearing on September 17, 2012.

3. Petitioner's attorneys have been in close contact with the Court Investigator
regarding a number of issues regarding the Settlor's real properties and finances. Last year,
Petitioner obtained an Order recovering title to several properties, and numerous questions
have arisen regarding their management. In coordination with the Court Investigator,
Petitioner has prepared a Petition for Instructions Regarding the Management of the
Settlor’s Real Property and Finances to accompany his two accountings, which will also be
accompanied by the Court Investigator’s report. All of this filings have been coordinated to
present the Court with a complete and unified picture and should be read and evaluated
together. Moreover, hearing them together is in the interest of judicial economy. Additionally,
it is urgent that Petitioner receive the Court's instructions, because of the ongoing risk of
financial loss to the Settlor and her estate.

4. This, it is respectfully requested that the Petition for Instructions be specially set
for hearing on September 17, 2012, so that it can be heard in conjunctions with the accountin-

gs already calendared for that date.

| declare under penalty of perjury under the laws of the State of California that the
foregoing is true, insofar as it is based on my own knowledge, and that | believe it to be true,

insofar as it is based on information and belief.

Dated A191 , 2012 Aw day be. SA tty

Andrew K. Schultz,
Attorney for Herb Thomas

DECLARATION TO SPECIALLY SET 2 Case No. PTR-06-288755