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1 Jackson Glick, Esq .; SBN 262682
Christopher Q. Heckman, Esq.; SBN 300526
2 SacValleyLaw LLP
660 Ohio Street 1/21/2022
3 P. 0 . Box 908
Gridley, CA 95948
4 Telephone: (530) 846-5691
Fax: (530) 846-5738
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Attorneys for Petitioner, JOHN I. MAGUIRE
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SUPERIOR COURT OF CALIFORNIA
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COUNTY OF BUTTE
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GERALD E . MAGUIRE, Attorney-in-Fact for Case No. 21PR00608
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MARIE A. MAGUIRE, DECLARATION OF MICHAEL A.
12 MAGUIRE IN SUPPORT OF OBJECTIONS
Petitioner, AND RESPONSE OF JOHN I. MAGUIRE
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v.
15 JOHN I. MAGUIRE,
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Respondent.
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19 I, MICHAEL A. MAGUIRE., declare:
20 I have personal knowledge of the facts stated herein, and I could competently testify about
21 the contents of this declaration ifl were called as a witness in the above-referenced proceeding.
22 1. I am the Grandson of Petitioner, Gerald E . Maguire, and his wife, Marie A. Maguire, and
23 son to Respondent, John I. Maguire.
24 2. I am 32 years old and a resident of Folsom, California.
25 3. After the Camp Fire destroyed their home in Paradise on November 8, 2018, my
26 Grandparents moved in with my father John and mother Lucy Maguire in their Folsom, California
27 home.
20 Ill
DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF
OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE
1 4. By this point m time, my father was already retired and frequently visited my
2 grandparent's home to help care for them and their property . Fortunately, my father was in
3 Paradise the morning of the Camp Fire and he rescued my grandparents, driving them from their
4 home to safety. It took three and a half hours in bumper-to-bumper traffic, at times driving through
5 roadside flames, to reach safety . He arrived at their home the prior evening, at the request of my
6 grandfather, to take my grandmother to a dentist appointment in Paradise the following morning.
7 He had the presence of mind that morning to rush them out the door, with their medications and
s a few small family heirlooms, just about an hour before the fire reached the house. He abandoned
9 his own car, which ultimately was destroyed, and drove my grandparents out of the fire through
1o the most difficult and life-threatening portion of their evacuation.
11 5. My father has always shown a great deal of concern and commitment to the care of my
12 grandparents, especially my grandmother. As I previously mentioned, he spent a lot of time at
13 their Paradise home helping them, particularly in the last several months leading up to the Fire.
14 Although my uncle Michael E. Maguire and his family lived only a few miles away in Paradise,
15 it was my father who spent the most time by far of any of his siblings helping my grandparents,
16 despite having to drive 100 miles each way between Folsom and Paradise, which he did typically
17 weekly.
1s 6. My other uncle, Gerald A. Maguire, would typically visit Paradise only a handful of times
19 a year. When he did, he would only stay for a day or two, and spent very little time helping my
20 grandparents. He provided no to little help caring for them or their property, which were their
21 greatest needs.
22 7. My aunt, Louise Maguire, who has suffered from mental illness for decades, has relied on
23 my grandparents for financial support and has been unable to provide any help to my grandparents
24 because of her limitations.
25 8. Upon moving to Folsom, it became clear just how much care my grandmother needed. In
26 the year or two leading up to the fire, my grandparent's home frequently smelled like urine.
27 Initially, I assumed itwas their dog but in time it became clear to me that my grandmother' s
28 cognitive and physical decline had resulted in her inability to go to the bathroom on her own, and
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DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF
OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE
1 she would instead be left in her living room chair-for hours, soaked in her own urine. Despite this,
2 my grandfather did not arrange for professional caregiving at their home in Paradise. As a result,
3 my father made a concerted effort to frequently drive to Paradise to care for my grandmother and
4 to help manage the three-acre property.
5 9. When my grandparents moved to Folsom after their home was destroyed in the fire, I
6 noticed immediately just how much further my grandmother' s condition had deteriorated.
7 Looking back on this, it is painfully obvious that my grandfather neglected to properly care for
8 my grandmother during their final year or two in paradise, and despite living just a few miles
9 away, my Uncle Michael did nothing to help in this regard. And, although a medical professional,
10 my Uncle Gerald did nothing to help in this regard, either.
11 10. In the final months leading up to the fire, the only outside care my grandmother received
12 was from a neighbor (Jill). Jill visited the house twice a week to help mostly with housework and
13 cooking. She only occasionally showered and changed my grandmother. Based upon her
14 condition at the time, that care was grossly insufficient. With that said, my grandfather has never
15 shown much concern for my grandmother, and this became more problematic as my grandmother
16 mentally and physically declined due to her dementia and age.
17 11. Although stillphysically capable and mentally sharp following the fire, my grandfather
18 provided very little assistance in helping my parents care for my grandmother. And, even worse,
19 he resisted paying for the professional care that my grandmother desperately needed, which
2o created more stress on my parents, as the full burden of my grandmother' s care fell on them . My
21 grandfather had more than sufficient financial means to hire help, but resisted doing so despite
22 repeated requests from my parents, my sister Christina and me. This lack of concern for my
23 grandmother and an unwillingness to pay for her care frustrated my father, which caused friction
24 in his relationship with my grandfather.
25 12. After my grandparents moved into my parent's home in Folsom, I began staying primarily
26 with my sister and her husband at their home in Sacramento, while I was attending graduate
27 school in Davis (late 2018 through early 2020). Following grad school, I moved out of my sister' s
28 home in March 2020 to live with my brother in Folsom . Over this time, I became aware of the
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DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF
OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE
1 strained relationship between my father and grandfather mostly from other family members, as I
2 did not witness it first-hand . I eventually learned that the strained relationship was mostly a result
3 of my grandfather' s unwillingness to provide adequate care for my grandmother. And during the
4 pandemic, the already strained relationship became worse as the pressure from having to isolate
5 and my grandmother' s declining condition was a stress on everyone.
6 13 . I was troubled about my grandfather' s continued lack of concern but knowing that my
7 grandmother was now under my mother' s full care (7 days/week) rather than part-time caregivers
s roughly two to three days a week, it gave me great comfort. For reference, my mother retired from
9 her job at the beginning of the pandemic, in order to care for my grandmother and prevent the
10 need for caregivers to enter the house risking exposing my grandparents to the virus. During the
11 pandemic, my parents were very careful and asked that my siblings and I, as well as other family,
12 visit with them and my grandparents in the backyard in order to properly social distance.
13 14. Prior to vaccinations becoming widely available in early 2021 , my siblings and I
14 understood and respected our parent's request to properly social distance in order to prevent any
15 covid exposure to my grandparents. In fact, we frequently visited them during the pandemic and
16 complied with their requests. However, my cousins and other family refused to respect my
17 parent's reasonable request to visit in the backyard and properly social distance. Instead, they
18 accused my parents of isolating them from the rest of the family .
19 15. At no point were my grandparents isolated from the family, nor did my father prevent any
20 communication with them. Since I lived in a separate household through the vast majority of my
21 grandparent's stay in Folsom, I did not witness any friction between my grandfather and my father
22 first-hand . Despite this, I was well aware that my grandfather was the primary source of the
23 friction, based upon his previous denial to provide my grandmother with proper care while they
24 stilllived in Paradise. After the fire, I could sense how much the fire affected my father, in what
25 I suspected was PTSD, and I became concerned about his emotional state, which I shared with
26 my Uncle Gerald. This was the purpose of the text messages exchanged with my uncle and sister,
27 Christina, in April 2019. I did this with the understanding that these text messages would be kept
2s confidential, as my uncle is a medical professional, and my understanding was that he was
4
DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF
OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE
1 obligated to keep these confidential. I was quite shocked to learn that they were included in court
2 documents. I feel that my uncle has betrayed my trust, particularly in a situation when I asked
3 him to help me with my father during a very difficult time, and instead he used them completely
4 out of context to attack him . To be abundantly clear, my grandfather was the primary source of
5 the friction and my father was becoming more and more frustrated over the lack of concern my
6 grandfather showed for my grandmother' s care. I did not contact my Uncle Gerald with similar
7 concerns about my father after this.
8 16. My grandfather moved out of my parent's home to his newly rebuilt home in Paradise in
9 February 2021 , and was urged by my Uncle Gerald to do so despite my uncle knowing that the
10 home and community was not safe for him . This was concerning because the home was built on
11 a steep slope and the community lacked important public services and facilities, including
12 adequate cell phone service, high-speed internet and an emergency medical facility . On top of
13 that, my Uncle Michael and his family were also still recovering from the fallout of the fire, and
14 were still in the process of rebuilding their home in Paradise. I did not think it was safe or fair to
15 assume they could be relied upon to respond in an emergency situation, considering they have
16 their own jobs and responsibilities to tend to while also living 30 minutes away in Oroville.
17 17. On March 16, 2021 , my grandfather called me and asked that I help him deal with an issue
18 involving my father. Apparently, my father had initiated a conservatorship process for my
19 grandmother. I learned from talking with my father that he did so because he feared my
20 grandfather, encouraged by my Uncle Gerald, was planning to move my grandmother out of my
21 parents' home in Folsom to live with him in Paradise. This concerned me because my grandfather
22 did not take good care of my grandmother while she lived with him for a short time at my Uncle
23 Michael ' s Oroville home in late 2019 and early 2020, and he did not take good care of her prior
24 to the fire. She was seriously injured from a fall she sustained there, and also developed a urinary
25 tract infection, both resulting because of poor care.
26 18. Around this time, my grandfather asked that I help him negotiate an agreement with my
27 father that would result in my father dropping the conservatorship. I agreed to do so. My
28 grandfather was genuinely very interested in doing the agreement, as it was literally his idea to
5
DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF
OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE
1 draft one to prevent the filing of any conservatorship. In fact, he proposed the initial terms that
2 would result in my grandmother staying in Folsom as her primary residence.
3 19. My Uncle Gerald called me to object to the agreement. While he agreed that my
4 grandmother should be provided full professional care and that my grandfather should cover those
5 expenses, he was very angry with my father and made threats against him if he did not drop the
6 conservatorship. He specifically stated to me on the phone that he would "assassinate your
7 father' s character'', if he did not drop the conservatorship.
8 20. My discussions with my father and grandfather continued into the following day, as my
9 sister and I served as the mediators between them . They came to a consensus on the terms of the
10 agreement early in the evening of March 17, 2021 , and my father drove to Paradise that evening
11 to finalize and sign the agreement with my grandfather.
12 21. Given all of this, I believe my father isbest suited to have Power of Attorney over my
13 grandmother in the event something happens to my grandfather. When the family home burned
14 down in Paradise, it was my father who rescued my grandparents from one of the largest and
15 deadliest wildfires in the state' shistory. When my grandparents lost nearly everything they
16 owned, including their home of 61 years, my father took them in to his own home and cared for
17 them . When my grandfather needed help with processing allthe insurance claims from the fire
18 and getting all the permits to clean up the lot and rebuild the home in Paradise, it was my father
19 who helped him navigate that process and complete the paperwork. When the pandemic hit, it
20 was my mother that retired from her job to care for my grandmother, along with my father. When
21 my grandfather refused to cover the full financial cost to care for my grandmother's medical and
22 caregiving expenses, my father was there to pay the bills. At no point have any other members of
23 our family cared for or looked after my grandparents to anything close to how my parents did
24 between November 2018 and June 2021. The sacrifices they made added to stress to their own
25 lives at times, like how I described in texts to my Uncle Gerald in 2019, but my
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DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF
OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE
1 parents deserve to be applauded for everything they have done to help my grandparents when
2 they needed it most. Nobody, including my father, should be punished for being a good son and
3 protector of his mother.
4 I declare under penalty of perjury under the las of the State of California that the foregoing is
5 true and correct.
6 Executed at Folsom, California on January j:1_, 2022.
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DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF
OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE
PROOF OF SERVICE
1
I am employed in the County of Butte, State of California. I am over the age of eightee
2
years and not a party to the within above-entitled action; my business address is: 660 Ohio Street,
3
P.O. Box 908, Gridley, CA 95948.
4
On January 21 , 2022, I served the following documents:
5
6 DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF OBJECTIONS AND
RESPONSE OF JOHN I. MAGUIRE
7
8 in the following manner:
9 (BY MAIL) By placing a true copy thereof enclosed in a sealed envelope, postage prepaid,
10 with the U. S. Postal Service at Gridley, California 95948, addressed as follows :
11
Gerald E. Maguire Gerald A. Maguire
12 c/o Todd A. Murray 30381 Via Festivo
Law Offices of Todd A. Murray, Inc. San Juan Capistrano, CA 92675
13 1050 Fulton Avenue, Suite 218
Sacramento, CA 95825
14
tmurray@tamurraylaw.com
15
Michael E . Maguire Louise Maguire
16 260 Dove Song Court 43 Murata Avenue
Paradise, CA 95969 Sacramento, CA 95823
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18 Marie A. Maguire
1710 Ryan Road
19 Paradise, CA 95969
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21 I, Sara Mull, declare under penalty of perjury under the laws of the State of California tha
22 the foregoing is true and correct.
23 Executed on January 21 , 2022, at Gridley, California.
24
25
26 Sara Mull
27
28
PROOF OF SER VICE
Preview
1 Jackson Glick, Esq .; SBN 262682 Christopher Q. Heckman, Esq.; SBN 300526 2 SacValleyLaw LLP 660 Ohio Street 1/21/2022 3 P. 0 . Box 908 Gridley, CA 95948 4 Telephone: (530) 846-5691 Fax: (530) 846-5738 5 Attorneys for Petitioner, JOHN I. MAGUIRE 6 7 SUPERIOR COURT OF CALIFORNIA 8 COUNTY OF BUTTE 9 10 GERALD E . MAGUIRE, Attorney-in-Fact for Case No. 21PR00608 11 MARIE A. MAGUIRE, DECLARATION OF MICHAEL A. 12 MAGUIRE IN SUPPORT OF OBJECTIONS Petitioner, AND RESPONSE OF JOHN I. MAGUIRE 13 14 v. 15 JOHN I. MAGUIRE, 16 Respondent. 17 18 19 I, MICHAEL A. MAGUIRE., declare: 20 I have personal knowledge of the facts stated herein, and I could competently testify about 21 the contents of this declaration ifl were called as a witness in the above-referenced proceeding. 22 1. I am the Grandson of Petitioner, Gerald E . Maguire, and his wife, Marie A. Maguire, and 23 son to Respondent, John I. Maguire. 24 2. I am 32 years old and a resident of Folsom, California. 25 3. After the Camp Fire destroyed their home in Paradise on November 8, 2018, my 26 Grandparents moved in with my father John and mother Lucy Maguire in their Folsom, California 27 home. 20 Ill DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE 1 4. By this point m time, my father was already retired and frequently visited my 2 grandparent's home to help care for them and their property . Fortunately, my father was in 3 Paradise the morning of the Camp Fire and he rescued my grandparents, driving them from their 4 home to safety. It took three and a half hours in bumper-to-bumper traffic, at times driving through 5 roadside flames, to reach safety . He arrived at their home the prior evening, at the request of my 6 grandfather, to take my grandmother to a dentist appointment in Paradise the following morning. 7 He had the presence of mind that morning to rush them out the door, with their medications and s a few small family heirlooms, just about an hour before the fire reached the house. He abandoned 9 his own car, which ultimately was destroyed, and drove my grandparents out of the fire through 1o the most difficult and life-threatening portion of their evacuation. 11 5. My father has always shown a great deal of concern and commitment to the care of my 12 grandparents, especially my grandmother. As I previously mentioned, he spent a lot of time at 13 their Paradise home helping them, particularly in the last several months leading up to the Fire. 14 Although my uncle Michael E. Maguire and his family lived only a few miles away in Paradise, 15 it was my father who spent the most time by far of any of his siblings helping my grandparents, 16 despite having to drive 100 miles each way between Folsom and Paradise, which he did typically 17 weekly. 1s 6. My other uncle, Gerald A. Maguire, would typically visit Paradise only a handful of times 19 a year. When he did, he would only stay for a day or two, and spent very little time helping my 20 grandparents. He provided no to little help caring for them or their property, which were their 21 greatest needs. 22 7. My aunt, Louise Maguire, who has suffered from mental illness for decades, has relied on 23 my grandparents for financial support and has been unable to provide any help to my grandparents 24 because of her limitations. 25 8. Upon moving to Folsom, it became clear just how much care my grandmother needed. In 26 the year or two leading up to the fire, my grandparent's home frequently smelled like urine. 27 Initially, I assumed itwas their dog but in time it became clear to me that my grandmother' s 28 cognitive and physical decline had resulted in her inability to go to the bathroom on her own, and 2 DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE 1 she would instead be left in her living room chair-for hours, soaked in her own urine. Despite this, 2 my grandfather did not arrange for professional caregiving at their home in Paradise. As a result, 3 my father made a concerted effort to frequently drive to Paradise to care for my grandmother and 4 to help manage the three-acre property. 5 9. When my grandparents moved to Folsom after their home was destroyed in the fire, I 6 noticed immediately just how much further my grandmother' s condition had deteriorated. 7 Looking back on this, it is painfully obvious that my grandfather neglected to properly care for 8 my grandmother during their final year or two in paradise, and despite living just a few miles 9 away, my Uncle Michael did nothing to help in this regard. And, although a medical professional, 10 my Uncle Gerald did nothing to help in this regard, either. 11 10. In the final months leading up to the fire, the only outside care my grandmother received 12 was from a neighbor (Jill). Jill visited the house twice a week to help mostly with housework and 13 cooking. She only occasionally showered and changed my grandmother. Based upon her 14 condition at the time, that care was grossly insufficient. With that said, my grandfather has never 15 shown much concern for my grandmother, and this became more problematic as my grandmother 16 mentally and physically declined due to her dementia and age. 17 11. Although stillphysically capable and mentally sharp following the fire, my grandfather 18 provided very little assistance in helping my parents care for my grandmother. And, even worse, 19 he resisted paying for the professional care that my grandmother desperately needed, which 2o created more stress on my parents, as the full burden of my grandmother' s care fell on them . My 21 grandfather had more than sufficient financial means to hire help, but resisted doing so despite 22 repeated requests from my parents, my sister Christina and me. This lack of concern for my 23 grandmother and an unwillingness to pay for her care frustrated my father, which caused friction 24 in his relationship with my grandfather. 25 12. After my grandparents moved into my parent's home in Folsom, I began staying primarily 26 with my sister and her husband at their home in Sacramento, while I was attending graduate 27 school in Davis (late 2018 through early 2020). Following grad school, I moved out of my sister' s 28 home in March 2020 to live with my brother in Folsom . Over this time, I became aware of the 3 DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE 1 strained relationship between my father and grandfather mostly from other family members, as I 2 did not witness it first-hand . I eventually learned that the strained relationship was mostly a result 3 of my grandfather' s unwillingness to provide adequate care for my grandmother. And during the 4 pandemic, the already strained relationship became worse as the pressure from having to isolate 5 and my grandmother' s declining condition was a stress on everyone. 6 13 . I was troubled about my grandfather' s continued lack of concern but knowing that my 7 grandmother was now under my mother' s full care (7 days/week) rather than part-time caregivers s roughly two to three days a week, it gave me great comfort. For reference, my mother retired from 9 her job at the beginning of the pandemic, in order to care for my grandmother and prevent the 10 need for caregivers to enter the house risking exposing my grandparents to the virus. During the 11 pandemic, my parents were very careful and asked that my siblings and I, as well as other family, 12 visit with them and my grandparents in the backyard in order to properly social distance. 13 14. Prior to vaccinations becoming widely available in early 2021 , my siblings and I 14 understood and respected our parent's request to properly social distance in order to prevent any 15 covid exposure to my grandparents. In fact, we frequently visited them during the pandemic and 16 complied with their requests. However, my cousins and other family refused to respect my 17 parent's reasonable request to visit in the backyard and properly social distance. Instead, they 18 accused my parents of isolating them from the rest of the family . 19 15. At no point were my grandparents isolated from the family, nor did my father prevent any 20 communication with them. Since I lived in a separate household through the vast majority of my 21 grandparent's stay in Folsom, I did not witness any friction between my grandfather and my father 22 first-hand . Despite this, I was well aware that my grandfather was the primary source of the 23 friction, based upon his previous denial to provide my grandmother with proper care while they 24 stilllived in Paradise. After the fire, I could sense how much the fire affected my father, in what 25 I suspected was PTSD, and I became concerned about his emotional state, which I shared with 26 my Uncle Gerald. This was the purpose of the text messages exchanged with my uncle and sister, 27 Christina, in April 2019. I did this with the understanding that these text messages would be kept 2s confidential, as my uncle is a medical professional, and my understanding was that he was 4 DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE 1 obligated to keep these confidential. I was quite shocked to learn that they were included in court 2 documents. I feel that my uncle has betrayed my trust, particularly in a situation when I asked 3 him to help me with my father during a very difficult time, and instead he used them completely 4 out of context to attack him . To be abundantly clear, my grandfather was the primary source of 5 the friction and my father was becoming more and more frustrated over the lack of concern my 6 grandfather showed for my grandmother' s care. I did not contact my Uncle Gerald with similar 7 concerns about my father after this. 8 16. My grandfather moved out of my parent's home to his newly rebuilt home in Paradise in 9 February 2021 , and was urged by my Uncle Gerald to do so despite my uncle knowing that the 10 home and community was not safe for him . This was concerning because the home was built on 11 a steep slope and the community lacked important public services and facilities, including 12 adequate cell phone service, high-speed internet and an emergency medical facility . On top of 13 that, my Uncle Michael and his family were also still recovering from the fallout of the fire, and 14 were still in the process of rebuilding their home in Paradise. I did not think it was safe or fair to 15 assume they could be relied upon to respond in an emergency situation, considering they have 16 their own jobs and responsibilities to tend to while also living 30 minutes away in Oroville. 17 17. On March 16, 2021 , my grandfather called me and asked that I help him deal with an issue 18 involving my father. Apparently, my father had initiated a conservatorship process for my 19 grandmother. I learned from talking with my father that he did so because he feared my 20 grandfather, encouraged by my Uncle Gerald, was planning to move my grandmother out of my 21 parents' home in Folsom to live with him in Paradise. This concerned me because my grandfather 22 did not take good care of my grandmother while she lived with him for a short time at my Uncle 23 Michael ' s Oroville home in late 2019 and early 2020, and he did not take good care of her prior 24 to the fire. She was seriously injured from a fall she sustained there, and also developed a urinary 25 tract infection, both resulting because of poor care. 26 18. Around this time, my grandfather asked that I help him negotiate an agreement with my 27 father that would result in my father dropping the conservatorship. I agreed to do so. My 28 grandfather was genuinely very interested in doing the agreement, as it was literally his idea to 5 DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE 1 draft one to prevent the filing of any conservatorship. In fact, he proposed the initial terms that 2 would result in my grandmother staying in Folsom as her primary residence. 3 19. My Uncle Gerald called me to object to the agreement. While he agreed that my 4 grandmother should be provided full professional care and that my grandfather should cover those 5 expenses, he was very angry with my father and made threats against him if he did not drop the 6 conservatorship. He specifically stated to me on the phone that he would "assassinate your 7 father' s character'', if he did not drop the conservatorship. 8 20. My discussions with my father and grandfather continued into the following day, as my 9 sister and I served as the mediators between them . They came to a consensus on the terms of the 10 agreement early in the evening of March 17, 2021 , and my father drove to Paradise that evening 11 to finalize and sign the agreement with my grandfather. 12 21. Given all of this, I believe my father isbest suited to have Power of Attorney over my 13 grandmother in the event something happens to my grandfather. When the family home burned 14 down in Paradise, it was my father who rescued my grandparents from one of the largest and 15 deadliest wildfires in the state' shistory. When my grandparents lost nearly everything they 16 owned, including their home of 61 years, my father took them in to his own home and cared for 17 them . When my grandfather needed help with processing allthe insurance claims from the fire 18 and getting all the permits to clean up the lot and rebuild the home in Paradise, it was my father 19 who helped him navigate that process and complete the paperwork. When the pandemic hit, it 20 was my mother that retired from her job to care for my grandmother, along with my father. When 21 my grandfather refused to cover the full financial cost to care for my grandmother's medical and 22 caregiving expenses, my father was there to pay the bills. At no point have any other members of 23 our family cared for or looked after my grandparents to anything close to how my parents did 24 between November 2018 and June 2021. The sacrifices they made added to stress to their own 25 lives at times, like how I described in texts to my Uncle Gerald in 2019, but my 26 27 28 6 DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE 1 parents deserve to be applauded for everything they have done to help my grandparents when 2 they needed it most. Nobody, including my father, should be punished for being a good son and 3 protector of his mother. 4 I declare under penalty of perjury under the las of the State of California that the foregoing is 5 true and correct. 6 Executed at Folsom, California on January j:1_, 2022. Miij~ 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 7 DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE PROOF OF SERVICE 1 I am employed in the County of Butte, State of California. I am over the age of eightee 2 years and not a party to the within above-entitled action; my business address is: 660 Ohio Street, 3 P.O. Box 908, Gridley, CA 95948. 4 On January 21 , 2022, I served the following documents: 5 6 DECLARATION OF MICHAEL A. MAGUIRE IN SUPPORT OF OBJECTIONS AND RESPONSE OF JOHN I. MAGUIRE 7 8 in the following manner: 9 (BY MAIL) By placing a true copy thereof enclosed in a sealed envelope, postage prepaid, 10 with the U. S. Postal Service at Gridley, California 95948, addressed as follows : 11 Gerald E. Maguire Gerald A. Maguire 12 c/o Todd A. Murray 30381 Via Festivo Law Offices of Todd A. Murray, Inc. San Juan Capistrano, CA 92675 13 1050 Fulton Avenue, Suite 218 Sacramento, CA 95825 14 tmurray@tamurraylaw.com 15 Michael E . Maguire Louise Maguire 16 260 Dove Song Court 43 Murata Avenue Paradise, CA 95969 Sacramento, CA 95823 17 18 Marie A. Maguire 1710 Ryan Road 19 Paradise, CA 95969 20 21 I, Sara Mull, declare under penalty of perjury under the laws of the State of California tha 22 the foregoing is true and correct. 23 Executed on January 21 , 2022, at Gridley, California. 24 25 26 Sara Mull 27 28 PROOF OF SER VICE