Preview
ELECTRONICALLY FILED
superior Court of California,
County of Placer
Zenaida P. Graves, Respondent, Pro-Se 10/05/2020
2351 SUNSET BLVD., STE 170-238 By: LaurelSanders, Deputy Clerk
ROCKLIN, CA, 95765
(415) 350-8956
Zpgraves16sja@yahoo.com
SUPERIOR COURT OF CALIFORNIA
COUNTY OF PLACER
Case No.: M-CV-0076678
SURETEC INSURANCE CO.
10
vs. RESPONDENT’S
11 STATUS REPORT AS
Zenaida P. Graves OF OCTOBER 2, 2020
12
i3
14
L5
16
Respondent, Zenaida P. Graves, reports that a second Meet and Confer meeting occurred on
17
October 1, 2020 at 4:50-5:28pm pm with Mr. David F. Myers, attorney for Suretec Insurance
18
Co.
19
Mr. Myers wanted to stipulate as to what is disputed and agree on non-disputed issues. Mr.
20
Myers was obsessed with and repeatedly asked the Respondent to answer yes or no in regard to
21
verifying her signature on documents. Respondent did not have Plaintiff's exhibits on hand.
22
NON-DISPUTED ISSUES:
23
1. The Bond in the complaint was exonerated.
24
2. The Bond is a Bond.
25
3. The Respondent/Trustee stated a signature on Plaintiff's Exhibit 1 and further clarified
26
that Plaintiff's Exhibit 1 is an application to Vreeland Bonding Services, not Suretec.
27
4. The Respondent/Trustee stated a signature on Plaintiff's Exhibit 2 along with a signature
28
RESPONDENT’S STATUS REPORT AS OF OCTOBER 2, 2020
1
from Paul Fazzio who works for Vreeland, not Suretec.
DISPUTED ISSUES: Indemnification claim that he mentioned in his Complaint
A. Mr. Myers would not stipulate that he is a debt collector per the FDCPA and RFDCPA
for purposes of this complaint.
Mr. Myers would not stipulate that he violated the FDCPA and RFDCPA regulations.
Mr. Myers would not agree to stipulate that his Exhibit 1 of the Complaint isan
application to Vreeland Bonding Services, not Suretec.
Mr. Myers would not stipulate that Suretec filed a petition for Release of Liability
(Exhibit 2), even though Suretec filed itat San Francisco Superior Court on 9/2017.
10 Mr. Myers is disputing his managing partner Mr. Curran’s statement made under oath
pi to the Superior Court of San Francisco County, that there were no claims filed against
12
the bond (captured by the Court Reporter at the hearing). (Exhibit 3).
Mr. Myers stated that the claim he alleges was during the active period of the alleged
13
bond in San Francisco court before itwas exonerated, but not presented to Trustee.
14
Mr. Myers also stated that the alleged claim was referred to in the failed “Settlement
15
Agreement” (Plaintiff filed with his Objection) that his former colleague, Ms.
16
Szczechwicz and the Trust’s former attorney, Ms. Friedeberg had been engaged to
17
handle. The Settlement Agreement was repudiated by the Trustee and beneficiaries.
18
Mr. Myers denied that his complaint lacked evidentiary support.
19
Mr. Myers would not stipulate that he has no evidence. He has not disclosed any.
20
Mr. Myers denied that he was supposed to submit evidence with his complaint. When
Zk
the Respondent pointed out that his objection to the Motion for Sanction, later
22
admitted facts he failed to acknowledge in his complaint, he lectured the Respondent
23
and said that legally his complaint does not have to contain evidence. “It will be
24 proven at Trial.” Plaintiff has the burden of proof and should disclose the evidence.
25 In our previous Meet and Confer, Mr. Myers alleged that the indemnity breach he is
26 trying to pursue is a legally separate issue from the Bond exoneration. When
2d challenged about the dispute of an invalid bond contract, he continued to proffer a
28 claim was made against the alleged bond. He has not presented a claim.
RESPONDENT’S STATUS REPORT AS OF OCTOBER 2, 2020
2
L. Mr. Myers failed to provide the Respondent with any evidence upon request and
refused to respond to Discovery requests emailed to him and stated that the
Respondent’s discovery request was not properly formatted. When Respondent
reminded Mr. Myers of his duty to be truthful and his responsibility to prevent
frivolous complaints, he ranted about the Respondent isnot a lawyer and needs to get
a lawyer.
M. Mr. Myers could not answer why Wolkin-Curran’s former attorney who handled this
case, (Ms. Szczechowicz) as aggressive as she was, did not submit this alleged claim
when the alleged bond was being adjudicated and did not inform the San Francisco
Superior Court. |understand Ms. Szczechowicz recently parted ways with Wolkin-
10
Curran around May 2020 and Mr. Myers took over and filed this case inJune 2020.
11
12
UNPROFESSIONAL BEHAVIOR BY MR. MYERS:
13
The Respondent informed Mr. Myers of an Expedited Trial Date she learned from the Court’s
14
website that was set by the Court for December 4, 2020. Mr. Myers then badgered the
15
Respondent and stated that he was going to depose her and insisted right then for a date that he
16
can set for a formal deposition in front of a court reporter to be taken under oath. When
17
questioned about sending the deposition questions in writing, he refused and said itwill be live
18 and in person. When the Respondent told him, she would get back to him within a week for a
19 date, he continued to rant and insisted on knowing a date right then and there on the phone.
20 The Respondent had to end the call because Mr. Myers continued to be uncooperative and
21 bullying.
22 CONCLUSION:
Zo The Respondent through her Answers to the Petitioner, her Motion to Sanction, Meet and Confer
24 conversations and this Status Report, has demonstrated that the evidence in the records clearly
25 shows that the Plaintiff has failed to meet his level of burden for bringing and attempting to
sustain his complaint in Placer County Superior Court. It has been further demonstrated by the
26
Plaintiff's objection to the Motion to Sanction, that the Plaintiff has failed to provide evidence
27
to refute the Respondent’s motion.
28
RESPONDENT’S STATUS REPORT AS OF OCTOBER 2, 2020
3
Mr. Myers has provided no evidence of a claim being submitted to Suretec, he has not established
a valid bond contract with Suretec, he has failed to explain how or prove that an application for
a bond with Vreeland (bond broker) somehow became a bond contract with Suretec he is
alleging. His complaint for attorney fees seems to be the claim that he isstating was made against
the bond, yet there is no correspondence from Suretec to the Trustee / Respondent, stating a
claim has been received and demanding reimbursement for any sums paid against a claim. Mr.
Myers has failed to prove any damages to Suretec and provides no evidence of damages. The
Respondent again charges Mr. Myers with filing a frivolous complaint that issolely intended to
harass and cause financial waste.
The fact that Mr. Myers ispresenting aclaim without evidence from Suretec Insurance Company
10 is, in my opinion, an Insurance Fraud. He has attempted to say the Respondent is personally
il liable for the Plaintiff's unnecessary legal bill for an unproven breach of contract and has used
12 Suretec’s name to seam the Respondent/Trustee who isa senior citizen.
13 The Respondent labels Mr. Myers a mendacious attorney who has attempted to venue shop this
14 complaint. The Respondent also intends to file a complaint with the California State Bar’s
LD Ethics division and the California Department of Insurance. Mr. Myers should not be allowed
to practice law.
16
ad Attached is a copy of the letter dated June 18, 2020 from a solicitor who informed me of this
lawsuit I received on June 26, 2020. (Exhibit 4). The Answer was filed on July 10, 2020.
18
19 VERIFICATION
20
I am the Respondent/Trustee in this action; the foregoing is true of my own knowledge, except
241
as to the matters stated in iton my information or belief, and as to those matters I believe them
22 to be true.
23
I declare under penalty of perjury under the laws of the State of California that the foregoing
24 is true and correct and that this declaration was executed atPlacer County, California.
25
26 Dated: October 4, 2020
2d
28
‘¢naida P. Graves, Respondent/Trustee, Pro Se
Vv
RESPONDENT’S STATUS REPORT AS OF OCTOBER 2, 2020
4
Exhibit 1
Kavear in ms) 19167736405 To? 4155663402 Pasesi/2
(Vin fie S506 3f02 Tei Faub, Fizzle
H.M. Vreeland Surety Bonding Services
TG? Vicente
Street,
Suits
102San and Surety 0 Fax G15) ao
Probate and Fiduciary Bo:
Bond Number:
Type of Bond:Probete Hearing Date:May 23,2017 ee
Case Number:PTR-16-299858
EstateName: The BlundinaD. PedianRevocable Trustof May16, 2000
Name: Zenaida PadianGraves_ Telephone Number: 415-350-8956
Aeteear: 225) Snes See ee eae E-mail zppraves!
Address: Gsja@ya hoo.com
SocialSecury Number; REDACTED DriversLic REDACTEDensoN NSCS
—~=S*~*~—“—«~Samber
Your Net Worth:$10,000 Your Annual Income:$30,000
Do youownahome? No Rent? Yes Other:
Your Bank: PatelcoCreditUnion Bank Account Number: 45333 a
Are youcurrentlyemployed? Yes Employer:Macy’s
Position/If
retired,
previouspasition: Ifsalfemptoyed,explainnarureofbusiness:
Address: City: Roseville State:CA Zip Code:
Telephone Number: Length of cmployment/ownership:| mo
What is yourrelationship
to theDecedent,Conservatee,or Minor?Daughtcr_
‘Whatis yourshareofthisestate
(Decedent'sextateonly)1/6
Have you hed acriminal
conviction?No Lasta civil judgment?
No
ifyes,explain: Be
Have you oryour spousefiledpersonal
bankruptcy? No If yea,when?
Are you indebtedto Deceden’Conservatee?No Ifyes,amount:
ESTATE INFORMATION
Name of Deceden¥Conservatee/Minor:
Biandina D. Padlan
Date ofBirthaf Conservatee/Minor:
Amount ofCash inEstate:
$645,000. Value ofSecurities:
a * Valuc of RealPraperty:6
Other Assets:
None Annual Tacome (Alt Sources):
N/A _
Bunk where ESTATE ACCOUNT will beopened:J.P,Morgan Chase Bank
Address: 2200Sunset Suite
Bivd., 200 City: Rocklin Stste: CA Zip Code: 95765
Where will
securities
be kept?N/A
{Safe deposit
box, Srokerage-~ Inetading
Neme & Address)
Does estatecontain
an ongoing business?No ifyes, name:
Type: Will itbe continued?
if yes,doyou understand
the Suretywiltrequire
you toobtaina courtorder
to continue
business?
APPLICANT'S ATTORNEY INFORMATION
Your Attomey’s Name: CharicsR. Perry E-mail Address:rick(@@emermylaw.com
Law Firm: Law Officesof R.
Charles Perry Phone Number: 415-800-3937
Address:100 PineStreet,
Suite1250
City:San Francisco State: CA_ Zip Code: 94111
Do you understand
thatthefirstyear's
bend premium isnet refimdable? YES
Do you understeadthecourtmust order
allincreasesandreductionstothebond? YES
Do you understandthebondis ineffectuntil 1s
dlecherge
a final signedbythejudge anda copydeliveredtothesurcty? Yes
Do you understandthebond premium is tobepaidannually? YS
Do you understandyou mustretainanattomey throughouttheedministation
of thisestate? YES
Continged on other side...
“ MAY-30-2OL7 12:48 From: 191677356485 To: 4188663492 Pase:2/2
REQUIRED
AUTHORIZATION TO CHARGE CREDIT ar THE EVENT OF NON-PAYMENT OF PREMIUM)
HLM. Vreelond andSon InsuranceAgency, Inc.willcontinue
to providebondsundservicetoitsclients
on atimelybasis,fromqualitySurety
Companies whorequirethatguaranteedpremiums bepaid withinforty-five
(45)
days after
issuanceofany bond(s}and withinforty-five
(45)
Gaysafterdateof renewaleachyeuruntilwe arefurnished,byyou oryourattomeywith a final
dischurge
or otherjudgmentexoneratingthe
bond or Surety
inthismatter.The authorization
informationbelow willbsheldon file
in confidence.
Thecreditcard number maybe checked
for validity
before
iesuanceofthe bond.No chargewillbe made unlessoruntilnon-paymentof premiumas describedbelow.
HM. Vreelandand Son InsuranceAgency,Inc.will hoidthisauthorization
information
on fifeuntil
there
is 0non-payment ofpremium
through normalmeans ofbilling
practice.
If,after
a billing
eyeleofthirty(20)
days fromthedate ofissuanceofthe bond(epeeifically
thedate
of execution
on thebond form),premium tsnot received
in this
officebycloseof business
onthe thirtieth
(30th)
day,then youauthorizeusto
chargethe cardbelawfor “premium(s)duc".
Gace the“premium({s)due“becomes thirty-one
(31)days late,
thecard numberbelow may be usedtopay thepremium for thebond whichwas
providedto youby H.M.,Vreelandand Son InsuranovAgency,Inc.at P.O.Box 2628Petaluma, CA $4953.
ApplicantagreesthetH.M. Veeetandend Soninsurance Agenoy,Inc.muy pursueallavenucsofcolicction,
includinguscof collection
agenciesand authorizes
H.M, Vreeland andSon InsuranceAgency,Inc.to submitcredit
cardchangesusing thechargecardlisted
below to
recoverallpayments dueandallother unpaidamounts dueto non-paymentof premium.
CARD TYPE: [7 VISA [2 Mester Card Card Number: Exp. Date:
i herebydeclare
thatI amthe holderoftheabove creditcard,
or havebeensuthorizedbythe holderofsaidcard,touseitto paypremlum(s}
ar services
providedby H.M. Vreelandand Son insuranceAgency,Inc.| also
understandthatthis
creditcardmay be chargedforanyfuture
iavoicerenewalpremiums thatbecome more than (30)dayspastdus asdescribedabove.
Name on Card; Cardholder Signature; Date:
. INDEMNITY AGREEMENT
‘TheIndemmitoss
represent
that
allsturements
mudsinthisApplication
andinanyApplication
Supplement
aretrucandmade without
ceservation
toinduce
the
Suretyendits
successors,
assigns,
co-sureties
andrelnsurere,
severally
oot jointly,
and/or
forwhichsurcty
business
isunderatitien
by theSurety
toextend
sucetycredit
in anymanner,
included
butnotlimited
toproviding
orhavingprovided
requested
Bond{s).
Indemnttoreherebyagreeazfollows:
Firsts
topayallpremiumswhen due;Seconds
todeliverevidence
satiefactosy
toSurety,
oftherelease
ofallHablilty;
Thirds
tocxoncrate
endIndemmify
Suretyfromandagainst
all
claims,
losses,
lisbility
damagesofunylype{including
punitive
dammges),
costs,
foes,expense,
sults,
orders,
judgments,
or
adjudications
whatsoever
whichSuretymayincurinconnection
withtheextension
afsurety
credit,
including
theeafomementoftheagreements
contained
herein
(collectively
“LOSS");
Forth:thatSurety
shallhave
theright,
at its
solediscrction,
topay,sdjust,
settle
orcompromiseany LOSSand the
voucheror
otherevidence
ofauchpayment,settlement
orcompromise,whetherSurety
wasliable
therefore
ornot,shell
beprimefacieevidence
oftheIndemmitors’
linbility;
Fils topaytheSurety
immediatelyupondemand,intheamountSuretydeemsnecessary
toprotect
thoSurety
fromeny LOSSor poteatial
LOSS,
whetherarnotSurety
hes madepaymentorpostedareserve,
Surety
havingtheright
touse
allorpartofthese
fundsinpaymentorselllement
of anyLOSSor
inreimbursement
toSurety
forpaymentof same;Sixth:
that
Indemmitors
herebyauthorize
Surety
to investigate
ststements
made herein
andtocheckcredit
with creditors,
credit
reporting
agencies
and/orlending
institutions,
andfurther
authorize
unypresent
orformeremployer,
or anyother
person,
firmor
corpernilen,
tofurnish
information
conceming
indemnltors
in connection
withtheSurety’s
extension
ofsuretycredit
and withIndemualtors
compliance
with —
obligations
hereunder
and under
any bondorunderlying
obligation,
andIndemnltors
hereby
release
anyoftheeforementioned
fromliability
inconsequence
of
fumishingordisclosing
suchinfonnation;
Seventh:thatSurety
maybringseparate
sultstorecover
hereunder
ascauses
of action
shall
eecrue
and that
the
bringing
ofsuitorrecovery
ofjudgmentuponenycauseofection
shallnot
prejudice
orbarthebringing
of other
sultsupon
othercausesofestion,
whether
heretofore
orthereafter
arising:
Elghth:
thatanyendallother
rightswhichSurety
may have
or acquire
against
Indemnitors
under
otheroradditions!
aprecments
(slongwiththis
Agreementcollectively
"INDEMNITY" related
totheextension
ofsuretycrodif,
chalbein addition
toandnotInlice
of the
rights
afforded
Suretyunder
thisAgreement;Ninth:
thstifSurety
exscutes
enyBond{s)with
any co-surety
orreinsures
ol]
or anypart
of Bond{s),
thatsll
the
termsofthisagreement
shall
applyandoperate
forthebenefit
ofsuchco-surcty
endrcinsurer,
astheir
interest
mayappear;Tenth:
thatthesecovenants
shall
be jointly
andseverally
binding
uponIndemnitors,
thelrrespective
helrs,
executors,
sdministestors,
successors
und assigns;
Eteventh;
that
Surcry
shallhave
theright
todecline
toissue
orto cancel
Bond{s)
at anytime,
freeofclaim
forlossordamagebyIndemnitors,
endSuretyshall
bounderno-obligation
to
disclose
its
reasons
therefore,
theprovision
ofanylawto thecontery
beingherebywaived;Tweilth;
thattheexerelse
,dcloy
of orfailure
bySuretyto
exercise
anyright,
remedyorpower whatesever
shall
notprectuds
Suroty's
Preview
ELECTRONICALLY FILED superior Court of California, County of Placer Zenaida P. Graves, Respondent, Pro-Se 10/05/2020 2351 SUNSET BLVD., STE 170-238 By: LaurelSanders, Deputy Clerk ROCKLIN, CA, 95765 (415) 350-8956 Zpgraves16sja@yahoo.com SUPERIOR COURT OF CALIFORNIA COUNTY OF PLACER Case No.: M-CV-0076678 SURETEC INSURANCE CO. 10 vs. RESPONDENT’S 11 STATUS REPORT AS Zenaida P. Graves OF OCTOBER 2, 2020 12 i3 14 L5 16 Respondent, Zenaida P. Graves, reports that a second Meet and Confer meeting occurred on 17 October 1, 2020 at 4:50-5:28pm pm with Mr. David F. Myers, attorney for Suretec Insurance 18 Co. 19 Mr. Myers wanted to stipulate as to what is disputed and agree on non-disputed issues. Mr. 20 Myers was obsessed with and repeatedly asked the Respondent to answer yes or no in regard to 21 verifying her signature on documents. Respondent did not have Plaintiff's exhibits on hand. 22 NON-DISPUTED ISSUES: 23 1. The Bond in the complaint was exonerated. 24 2. The Bond is a Bond. 25 3. The Respondent/Trustee stated a signature on Plaintiff's Exhibit 1 and further clarified 26 that Plaintiff's Exhibit 1 is an application to Vreeland Bonding Services, not Suretec. 27 4. The Respondent/Trustee stated a signature on Plaintiff's Exhibit 2 along with a signature 28 RESPONDENT’S STATUS REPORT AS OF OCTOBER 2, 2020 1 from Paul Fazzio who works for Vreeland, not Suretec. DISPUTED ISSUES: Indemnification claim that he mentioned in his Complaint A. Mr. Myers would not stipulate that he is a debt collector per the FDCPA and RFDCPA for purposes of this complaint. Mr. Myers would not stipulate that he violated the FDCPA and RFDCPA regulations. Mr. Myers would not agree to stipulate that his Exhibit 1 of the Complaint isan application to Vreeland Bonding Services, not Suretec. Mr. Myers would not stipulate that Suretec filed a petition for Release of Liability (Exhibit 2), even though Suretec filed itat San Francisco Superior Court on 9/2017. 10 Mr. Myers is disputing his managing partner Mr. Curran’s statement made under oath pi to the Superior Court of San Francisco County, that there were no claims filed against 12 the bond (captured by the Court Reporter at the hearing). (Exhibit 3). Mr. Myers stated that the claim he alleges was during the active period of the alleged 13 bond in San Francisco court before itwas exonerated, but not presented to Trustee. 14 Mr. Myers also stated that the alleged claim was referred to in the failed “Settlement 15 Agreement” (Plaintiff filed with his Objection) that his former colleague, Ms. 16 Szczechwicz and the Trust’s former attorney, Ms. Friedeberg had been engaged to 17 handle. The Settlement Agreement was repudiated by the Trustee and beneficiaries. 18 Mr. Myers denied that his complaint lacked evidentiary support. 19 Mr. Myers would not stipulate that he has no evidence. He has not disclosed any. 20 Mr. Myers denied that he was supposed to submit evidence with his complaint. When Zk the Respondent pointed out that his objection to the Motion for Sanction, later 22 admitted facts he failed to acknowledge in his complaint, he lectured the Respondent 23 and said that legally his complaint does not have to contain evidence. “It will be 24 proven at Trial.” Plaintiff has the burden of proof and should disclose the evidence. 25 In our previous Meet and Confer, Mr. Myers alleged that the indemnity breach he is 26 trying to pursue is a legally separate issue from the Bond exoneration. When 2d challenged about the dispute of an invalid bond contract, he continued to proffer a 28 claim was made against the alleged bond. He has not presented a claim. RESPONDENT’S STATUS REPORT AS OF OCTOBER 2, 2020 2 L. Mr. Myers failed to provide the Respondent with any evidence upon request and refused to respond to Discovery requests emailed to him and stated that the Respondent’s discovery request was not properly formatted. When Respondent reminded Mr. Myers of his duty to be truthful and his responsibility to prevent frivolous complaints, he ranted about the Respondent isnot a lawyer and needs to get a lawyer. M. Mr. Myers could not answer why Wolkin-Curran’s former attorney who handled this case, (Ms. Szczechowicz) as aggressive as she was, did not submit this alleged claim when the alleged bond was being adjudicated and did not inform the San Francisco Superior Court. |understand Ms. Szczechowicz recently parted ways with Wolkin- 10 Curran around May 2020 and Mr. Myers took over and filed this case inJune 2020. 11 12 UNPROFESSIONAL BEHAVIOR BY MR. MYERS: 13 The Respondent informed Mr. Myers of an Expedited Trial Date she learned from the Court’s 14 website that was set by the Court for December 4, 2020. Mr. Myers then badgered the 15 Respondent and stated that he was going to depose her and insisted right then for a date that he 16 can set for a formal deposition in front of a court reporter to be taken under oath. When 17 questioned about sending the deposition questions in writing, he refused and said itwill be live 18 and in person. When the Respondent told him, she would get back to him within a week for a 19 date, he continued to rant and insisted on knowing a date right then and there on the phone. 20 The Respondent had to end the call because Mr. Myers continued to be uncooperative and 21 bullying. 22 CONCLUSION: Zo The Respondent through her Answers to the Petitioner, her Motion to Sanction, Meet and Confer 24 conversations and this Status Report, has demonstrated that the evidence in the records clearly 25 shows that the Plaintiff has failed to meet his level of burden for bringing and attempting to sustain his complaint in Placer County Superior Court. It has been further demonstrated by the 26 Plaintiff's objection to the Motion to Sanction, that the Plaintiff has failed to provide evidence 27 to refute the Respondent’s motion. 28 RESPONDENT’S STATUS REPORT AS OF OCTOBER 2, 2020 3 Mr. Myers has provided no evidence of a claim being submitted to Suretec, he has not established a valid bond contract with Suretec, he has failed to explain how or prove that an application for a bond with Vreeland (bond broker) somehow became a bond contract with Suretec he is alleging. His complaint for attorney fees seems to be the claim that he isstating was made against the bond, yet there is no correspondence from Suretec to the Trustee / Respondent, stating a claim has been received and demanding reimbursement for any sums paid against a claim. Mr. Myers has failed to prove any damages to Suretec and provides no evidence of damages. The Respondent again charges Mr. Myers with filing a frivolous complaint that issolely intended to harass and cause financial waste. The fact that Mr. Myers ispresenting aclaim without evidence from Suretec Insurance Company 10 is, in my opinion, an Insurance Fraud. He has attempted to say the Respondent is personally il liable for the Plaintiff's unnecessary legal bill for an unproven breach of contract and has used 12 Suretec’s name to seam the Respondent/Trustee who isa senior citizen. 13 The Respondent labels Mr. Myers a mendacious attorney who has attempted to venue shop this 14 complaint. The Respondent also intends to file a complaint with the California State Bar’s LD Ethics division and the California Department of Insurance. Mr. Myers should not be allowed to practice law. 16 ad Attached is a copy of the letter dated June 18, 2020 from a solicitor who informed me of this lawsuit I received on June 26, 2020. (Exhibit 4). The Answer was filed on July 10, 2020. 18 19 VERIFICATION 20 I am the Respondent/Trustee in this action; the foregoing is true of my own knowledge, except 241 as to the matters stated in iton my information or belief, and as to those matters I believe them 22 to be true. 23 I declare under penalty of perjury under the laws of the State of California that the foregoing 24 is true and correct and that this declaration was executed atPlacer County, California. 25 26 Dated: October 4, 2020 2d 28 ‘¢naida P. Graves, Respondent/Trustee, Pro Se Vv RESPONDENT’S STATUS REPORT AS OF OCTOBER 2, 2020 4 Exhibit 1 Kavear in ms) 19167736405 To? 4155663402 Pasesi/2 (Vin fie S506 3f02 Tei Faub, Fizzle H.M. Vreeland Surety Bonding Services TG? Vicente Street, Suits 102San and Surety 0 Fax G15) ao Probate and Fiduciary Bo: Bond Number: Type of Bond:Probete Hearing Date:May 23,2017 ee Case Number:PTR-16-299858 EstateName: The BlundinaD. PedianRevocable Trustof May16, 2000 Name: Zenaida PadianGraves_ Telephone Number: 415-350-8956 Aeteear: 225) Snes See ee eae E-mail zppraves! Address: Gsja@ya hoo.com SocialSecury Number; REDACTED DriversLic REDACTEDensoN NSCS —~=S*~*~—“—«~Samber Your Net Worth:$10,000 Your Annual Income:$30,000 Do youownahome? No Rent? Yes Other: Your Bank: PatelcoCreditUnion Bank Account Number: 45333 a Are youcurrentlyemployed? Yes Employer:Macy’s Position/If retired, previouspasition: Ifsalfemptoyed,explainnarureofbusiness: Address: City: Roseville State:CA Zip Code: Telephone Number: Length of cmployment/ownership:| mo What is yourrelationship to theDecedent,Conservatee,or Minor?Daughtcr_ ‘Whatis yourshareofthisestate (Decedent'sextateonly)1/6 Have you hed acriminal conviction?No Lasta civil judgment? No ifyes,explain: Be Have you oryour spousefiledpersonal bankruptcy? No If yea,when? Are you indebtedto Deceden’Conservatee?No Ifyes,amount: ESTATE INFORMATION Name of Deceden¥Conservatee/Minor: Biandina D. Padlan Date ofBirthaf Conservatee/Minor: Amount ofCash inEstate: $645,000. Value ofSecurities: a * Valuc of RealPraperty:6 Other Assets: None Annual Tacome (Alt Sources): N/A _ Bunk where ESTATE ACCOUNT will beopened:J.P,Morgan Chase Bank Address: 2200Sunset Suite Bivd., 200 City: Rocklin Stste: CA Zip Code: 95765 Where will securities be kept?N/A {Safe deposit box, Srokerage-~ Inetading Neme & Address) Does estatecontain an ongoing business?No ifyes, name: Type: Will itbe continued? if yes,doyou understand the Suretywiltrequire you toobtaina courtorder to continue business? APPLICANT'S ATTORNEY INFORMATION Your Attomey’s Name: CharicsR. Perry E-mail Address:rick(@@emermylaw.com Law Firm: Law Officesof R. Charles Perry Phone Number: 415-800-3937 Address:100 PineStreet, Suite1250 City:San Francisco State: CA_ Zip Code: 94111 Do you understand thatthefirstyear's bend premium isnet refimdable? YES Do you understeadthecourtmust order allincreasesandreductionstothebond? YES Do you understandthebondis ineffectuntil 1s dlecherge a final signedbythejudge anda copydeliveredtothesurcty? Yes Do you understandthebond premium is tobepaidannually? YS Do you understandyou mustretainanattomey throughouttheedministation of thisestate? YES Continged on other side... “ MAY-30-2OL7 12:48 From: 191677356485 To: 4188663492 Pase:2/2 REQUIRED AUTHORIZATION TO CHARGE CREDIT ar THE EVENT OF NON-PAYMENT OF PREMIUM) HLM. Vreelond andSon InsuranceAgency, Inc.willcontinue to providebondsundservicetoitsclients on atimelybasis,fromqualitySurety Companies whorequirethatguaranteedpremiums bepaid withinforty-five (45) days after issuanceofany bond(s}and withinforty-five (45) Gaysafterdateof renewaleachyeuruntilwe arefurnished,byyou oryourattomeywith a final dischurge or otherjudgmentexoneratingthe bond or Surety inthismatter.The authorization informationbelow willbsheldon file in confidence. Thecreditcard number maybe checked for validity before iesuanceofthe bond.No chargewillbe made unlessoruntilnon-paymentof premiumas describedbelow. HM. Vreelandand Son InsuranceAgency,Inc.will hoidthisauthorization information on fifeuntil there is 0non-payment ofpremium through normalmeans ofbilling practice. If,after a billing eyeleofthirty(20) days fromthedate ofissuanceofthe bond(epeeifically thedate of execution on thebond form),premium tsnot received in this officebycloseof business onthe thirtieth (30th) day,then youauthorizeusto chargethe cardbelawfor “premium(s)duc". Gace the“premium({s)due“becomes thirty-one (31)days late, thecard numberbelow may be usedtopay thepremium for thebond whichwas providedto youby H.M.,Vreelandand Son InsuranovAgency,Inc.at P.O.Box 2628Petaluma, CA $4953. ApplicantagreesthetH.M. Veeetandend Soninsurance Agenoy,Inc.muy pursueallavenucsofcolicction, includinguscof collection agenciesand authorizes H.M, Vreeland andSon InsuranceAgency,Inc.to submitcredit cardchangesusing thechargecardlisted below to recoverallpayments dueandallother unpaidamounts dueto non-paymentof premium. CARD TYPE: [7 VISA [2 Mester Card Card Number: Exp. Date: i herebydeclare thatI amthe holderoftheabove creditcard, or havebeensuthorizedbythe holderofsaidcard,touseitto paypremlum(s} ar services providedby H.M. Vreelandand Son insuranceAgency,Inc.| also understandthatthis creditcardmay be chargedforanyfuture iavoicerenewalpremiums thatbecome more than (30)dayspastdus asdescribedabove. Name on Card; Cardholder Signature; Date: . INDEMNITY AGREEMENT ‘TheIndemmitoss represent that allsturements mudsinthisApplication andinanyApplication Supplement aretrucandmade without ceservation toinduce the Suretyendits successors, assigns, co-sureties andrelnsurere, severally oot jointly, and/or forwhichsurcty business isunderatitien by theSurety toextend sucetycredit in anymanner, included butnotlimited toproviding orhavingprovided requested Bond{s). Indemnttoreherebyagreeazfollows: Firsts topayallpremiumswhen due;Seconds todeliverevidence satiefactosy toSurety, oftherelease ofallHablilty; Thirds tocxoncrate endIndemmify Suretyfromandagainst all claims, losses, lisbility damagesofunylype{including punitive dammges), costs, foes,expense, sults, orders, judgments, or adjudications whatsoever whichSuretymayincurinconnection withtheextension afsurety credit, including theeafomementoftheagreements contained herein (collectively “LOSS"); Forth:thatSurety shallhave theright, at its solediscrction, topay,sdjust, settle orcompromiseany LOSSand the voucheror otherevidence ofauchpayment,settlement orcompromise,whetherSurety wasliable therefore ornot,shell beprimefacieevidence oftheIndemmitors’ linbility; Fils topaytheSurety immediatelyupondemand,intheamountSuretydeemsnecessary toprotect thoSurety fromeny LOSSor poteatial LOSS, whetherarnotSurety hes madepaymentorpostedareserve, Surety havingtheright touse allorpartofthese fundsinpaymentorselllement of anyLOSSor inreimbursement toSurety forpaymentof same;Sixth: that Indemmitors herebyauthorize Surety to investigate ststements made herein andtocheckcredit with creditors, credit reporting agencies and/orlending institutions, andfurther authorize unypresent orformeremployer, or anyother person, firmor corpernilen, tofurnish information conceming indemnltors in connection withtheSurety’s extension ofsuretycredit and withIndemualtors compliance with — obligations hereunder and under any bondorunderlying obligation, andIndemnltors hereby release anyoftheeforementioned fromliability inconsequence of fumishingordisclosing suchinfonnation; Seventh:thatSurety maybringseparate sultstorecover hereunder ascauses of action shall eecrue and that the bringing ofsuitorrecovery ofjudgmentuponenycauseofection shallnot prejudice orbarthebringing of other sultsupon othercausesofestion, whether heretofore orthereafter arising: Elghth: thatanyendallother rightswhichSurety may have or acquire against Indemnitors under otheroradditions! aprecments (slongwiththis Agreementcollectively "INDEMNITY" related totheextension ofsuretycrodif, chalbein addition toandnotInlice of the rights afforded Suretyunder thisAgreement;Ninth: thstifSurety exscutes enyBond{s)with any co-surety orreinsures ol] or anypart of Bond{s), thatsll the termsofthisagreement shall applyandoperate forthebenefit ofsuchco-surcty endrcinsurer, astheir interest mayappear;Tenth: thatthesecovenants shall be jointly andseverally binding uponIndemnitors, thelrrespective helrs, executors, sdministestors, successors und assigns; Eteventh; that Surcry shallhave theright todecline toissue orto cancel Bond{s) at anytime, freeofclaim forlossordamagebyIndemnitors, endSuretyshall bounderno-obligation to disclose its reasons therefore, theprovision ofanylawto thecontery beingherebywaived;Tweilth; thattheexerelse ,dcloy of orfailure bySuretyto exercise anyright, remedyorpower whatesever shall notprectuds Suroty's