PEIN Notice of Court Hearing a @ Elder or Dependent Adult in Need of Protection a. Full Name: Stan Lee {3} Person requesting protection forthe elder oF dependent adult, if different (person named in item(3) of Form EA-100): Full Name: Tom Lallas Lawyer for person niamed above (i/any for this case), Name: Self ___ Stale Bar No. 66512 b. Firm Name: Levy, Small & Lallas ‘Address for person named above (if you have a lawyer, give your Lawyer's information. If you do not have a lawyer, give information for the person requesting the order. If you want to keep your home ‘address private, you may give a differen! mailing addvess instead, You do not have to give telephone, fax, or e-mail ‘Address: 815 Moraga Dr City; Los Angeles State: CA zip: 90049 Telephone: (310) 471-3000 gy E-Mail Address: @ Person You Want Protection From Full Name: KeyaMorgan © Notice of Hearing A court hearing is scheduled on the request for restraining orders against the person ir [Clerk stamps date here when forms fied. FILED Superlor Cowet of Californiz County at For Aneten UN 13-2018 Sherri Carte waygare yuacerCler, By an + Deputy| ‘Susai Ghnifer Filia court name and seal adres [Superior Court of Californta, County of JLos Angeles 111 N. Hill Street Los Angeles, CA 90012 Central (Court isn case nambar when form is ibe [Case Number: L__1kSTROQATI 5 | The court will complete the rest of this form. (i DUO ime: re 5 Date: Dept.: Name and address of court if different from above @ Temporary Restraining Orders (an oners granted are om Form E110, served with notice.) & Temporary Restraining Orders fr personal eonuct and siay-away orders as requested in Form EA-100, (PER ANGRANTED until the court hearing, neat Elder on Dependent Adult Abuse Restraining Orders ae (check any one box below) @ C AUDENTED until the court hearing. (Specify reasons for dental in 6, below.) G) O Parly GRANTED and partly DENIED until the court hearing. (Specify 5, below.) reasons for denial in iw ray 122 Many Pry Ve awison aoe Fe 23 ewe 30) Notice of Court Hearing EAAO8, Pago Tats > {Elder or Dependent Adult Abuse Prevention) Lexie Autonced California Sulla Counel Formsb. Reasons for denial of some or all of those personal conduct and stay away orders as requested in Form EA-100, Request for Elder or Dependent Adult Abuse Restraining Orders, are (@) Temporary Restraining Orders (Continued) (1) Gi The facts as stated in Form EA-100 do not sufficiently show reasonable proof ofa past act or acts of abuse ofthe elder or dependent adult by the person in ©. 2) O Other (specify): C1 As set forth on Attachment 4b. ©) Service of Documents by the Person in @ Attu the ©) aye i ing one ole yn anne we protected—Inust personally give (serve) a court file-stamped copy of this Form EA-109, Notice of Court Hearing, to the person in (2) along with a copy of al the forms indicated below: @, EA-100, Request for Elder or Dependent Adult Abuse Restraining Orders file-stamped) EA-110, Temporary Restraining Order (file-stamped) IF GRANTED. €. EA-120, Response to Request for Elder or Dependent Adult Abuse Restraining Orders (blank form) 4, EA-250, Proof of Service of Response by Mail (blank form) & EA-120-INFO, How Can 1 Respond to a Request for Elder or Dependent Adult Abuse Restraining Orders? £. 1 Other (specify) ae; __JUN 13 2018 aaa Vad Trop a judicial Officer ‘The court cannot make the restraining orders after the court hearing unless the person in(@) has been personally given (served) a copy of your request and any temporary orders, To show thatthe person in(@) has been served, the pecan ‘who served the forms must fill outa proof of service form. Form EA-200, Proof of Personal Service, may be wsed * For information about service, read Form EA-200-INFO, What Is "Proof of Personal Service"? you ae unable to serve the person in@)in time, you may ask for mor time to serve the documents Use Foum EA-115, Request to Continue Court Hearing avd to Reissue Temporary Restraining Onder eae Notice of Court Hearing ERAOS, Page Day (Elder or Dependent Adult Abuse Prevention), > Lesh Aomated Coons atl Cone Fares‘Case Number: Cee) |fyou want to respond to the request for orders in writing, file Form EA-120, Response to Request for Elder or Dependent Adult Abuse Restraining Orders, and have someone age 18 or older—not you or anyone to be protected—mailitto the person in) * The person who mailed the form must fill out a proof of service form. Form EA-250, Proofof Service of Response by Mil, may be used. File the completed form with the court before the hearing and bring a copy with you to the court hearing. * Whether ornot you respond in writing, goto the hearing ifyou want the judge to hear from you before making an order. Youmay tell the judge why you agree or disagree withthe orders requested. * You may bring witnesses and other evidence. At the hearing, the judge may make restraining orders against you that could last up to five years and may order you to sell or turn in any firearms that you own or possess. Request for Accommodations Assistive listening systems, computer-assisted real-time captioning, or sign language interpreter services are available if you ask at least five days before the hearing. Contact the Clerk's office or go to www.courts.ca.goviforms for Request for Accommodations by Persons with Disabilities and Response (Form MC-410). (Civ. Code, § 54.8.) (Clerk will fll ow this part) —Clerk’s Certificate— | certify that this Notice of Court Hearing is a true and correct copy of the original on file in the court. Clerk's Certificate [seal] Date: Clerk, by, Notice of Court Hearing, EAT09, Page aaa (Elder or Dependent Adult Abuse Pr ention) Lexie Antomared California ait Coun FernsEA-110 Temporary Restraining Order Person in D must complete items @), (2) and @) only @ Protected Elder or Dependent Adult a, Full Name: Stan Lee 7 _ Person requesting protcetion for the elder or dependent adult, if different (person named in iten(@) of form EA-100): Full Name; Tom Lallas Lawyer for person named above (ifany, for this case) Name: Self State Bar No.:66512 Firm Name: Levy, Small & Lallas Your Address (you have a lawyer, give your lawyer's information Uf you do not have a lawyer and want to keep your home address private, You may give a different mailing address instead. You do not ‘have to give telephone, fax, or e-mail, Address: §15 Moraga Dr City: Los Angeles State: CA Zip: 90049 Telephone: (310) 471-3000 Fax: E-Mail Address: Restrained Person Full Name: Keya Morgan Clerk stamps date ne hen form is fle. FILED ‘Superlor Ceurt of Californi- Conte att ae! JUN 13-2018 Fin cour oame ond shoot eros: [ Superior Court of California, County of HLos Angeles 11 N. Fill Street ILos Angeles, CA 90012 ICentral Court isn 6ase number when fm is ed ‘Case Number: 18STROO4115 Dessripion: a MF Hair Color: BLK Bye Color: HZ. Home Address (ifforown): 325.N. Maple Dr. City: Beverly Hills Relationship to Protected Person: Age: Height: 601" Weight: 180 a2 Date of Birth: Octobe: Race: White State: CA _ Zip: 90209 Respondent is Mr. Lee's caregiver, C Additional Protected Persons In addition to the elder or dependent adult named in@), the following family or household members or ‘conservator of that person are protected by the temporary orders indicated below: EullName Sex Age Household Member? Relation to Protected Person, __ U Yes [ No © Yes 5 No Oi Check here ifthere are additional protected persons. List them on an attached sheet of paper and write “Attachment 3—-Additional Protected Persons” as a ttle. You may use form MC-025, Atachment @ Expiration Date This Order expires at the end of the hearing scheduled for the date and time below: OTE NE Time: Qi Kom pm | Temporary Restraining Order (CLETS-TEA or TEF) (Elder or Dependent Adult Abuse Prevention) LexiNeis® Automated Calor util Cone Fons Date: EA-110, Page 1016 >[Case Numbers | econ) The court has issued the temporary orders checked as granted below. If you do not obey these orders, arrested you ean be «i charged with a crime. You may have to go to jail for up to one year, pay a fine of up to $1,000, or Personal Conduct Orders © NotRequested [) Denied Until the Hearing 3 Granted as Follows: You must nat do the following things t the elder or dependent adult named in @) C)_and to the other protected persons listed in@) : COR Peysically abuse, financially abuse, intimidate, molest, tac, strike, stalk, theesten, assault (Sexually or ‘otherwise, hit, harass, destroy personal property of, or disturb the peace of the person @) J Contact the person, cither directly or indirectly, in any way, including, but not limited to, in person, by telephone, in writing, by public or private mail, by interoffice mail, by e-mail, by text messages, by far, or by other electronic means, ©) $M Take any action to obtain the person's address or location, If this item @) is not checked, the court has found good cause not to make this order. 4) D Other (specify: O Other personal conduct orders are attached atthe end of this Order on Attachment Sa(4), 5, Peaceful writen contac through alwyer ora process sever or other person fr sevice of legal papers related t© cour eas allowed and does not violate tis order. However, you may have your papers served by ra on the person in). Stay-Away Orders (j Not Requested —() Denied Until the Hearing 2X Granted as Follows: & You must stay at least JC) yards away from (check all that apply) (1) BA The elke or dependent aduk in) (5) BRTHe vehicle ofthe person in @) 2) C1 Bach person in @ © Oi Other (specifi GK The home of the elder or we dependent adult (AX The job or workplace of the elder OO or dependent adult 5. This stay-away order does not prevent you from going to or from your home or place of employment Move-Out Order JK Not Requested £5) Denied Until the Hearing ©) Granted as Follows: ‘You must immediately move out from and not return to (address). Temporary Restraining Order (CLETS-TEA or TEF) EA-110, Page? 016 (Elder or Dependent Adult Abuse Prevention) > LexiNeris® dutomaied Colformia. dial Counc Forms(Case Number: No Guns or Other Firearms and Ammunition 1 Not Issued (financial abuse only) X Granted as Follows: This order must be granted unless only financial abuse is alleged, % You cannot own, possess, have, by or try to buy, receive or try to receive o in any other way get guns other fireatis, or ammunition. ‘b. You must: (1) Sell to oF store witha licensed gun dealer, or tur into a law enforcement agency. any guns or other firearms in your immediate possession or control. This must be done within 24 hours of being served with this Order. (2) File a receipt with the cour within 48 hours of receiving this Order that proves that your guns or firearms have been turned in, sold, or stored. (You may ‘use form EA-800, Proof of Firearms Tumed In, Sold, or Stored, for the receipt) © C] The court has received information that you own or possess a firearm. Financial Abuse This cose Daf does not (does involve solely financial abuse unaccompanied by force, threat, harassmertt, intimidation, or any other form of abuse. in and Protection of Animals Posses: Dx Not Requested (Denied Until the Hearing [] Granted as Follows (specify) a The person in @is given the sole possession, care, and control ofthe animals listed below, which are owned, possessed, leased, kept, or held by him oF her. or reside in his or her household (Identify animals by, e.g. txpe, breed, name, color, sex.) © The person in @must stay at least__yards away from, and not take, sel, transfer, encumber, conceal, roles, attack, strike, threaten, ham, or otherwise dispose of, the animals listed above. @) Other Orders NotRequested [] Denied Until the Hearing [1 Granted as Follows (specify): © Additional orders are attached at the end of this Order on Attachment 11 DELeewor usec Temporary Restraining Order (CLETS-TEA or TEF) EAA10, Page 3016 (Elder or Dependent Adult Abuse Prevention) > Lexisesf® Atomated Colforma Judicial Council FormsTo the Person in@ @ Mandatory Entry of Order Into CARPOS Through CLETS This Order must be entered into the California Restraining and Protective Order System (CARPOS) through the California Law Enforcement Telecommunications System (CLETS). (Check one): 8. O) The clerk will enter this Order and its proof-of-service form into CARPOS. ». J Me clerk wil transmit this Order and ite proof-of-service form to 2 law enforcement agency to be entered into CARPOS. ¢. C1 By the close of business onthe date that this Order is made, the petitioner or the petitioners lawyer shoud deliver a copy ofthe Order and its proof-of-service form tothe l enter into CARPOS: NameofLawEnforcementAgency Address (Cipy. State. Zip) law enforcement agencies listed below 1 © Additional law enforcement agencies are listed at the end of this Order on Attachment 12 No Fee to Serve (Notify) Restrained Person Ifthe sheriff or marshal serves this Order, he or she will do it for free. GB Number of pages atached to this Order, any Date: JUN 13 2018 Judicial Officer This is a Court Order. Reve 27 Temporary Restraining Order (CLETS-TEA or TEF), EAA10, Page sore (Elder or Dependent Adult Abuse Prevention) > lena 10% Auomaned afore dod CoundCase Number: PEER ue een nnn 2) Possession of Guns or Firearms Uf the court grants the orders in item @), you cannot own, have, possess, buy or try to buy, receive or ty to receive, ot cthenwise get guns, other firearms, or ammunition while this Orders in effect. Ifyou do, you ean go to jail and pay a £1,000 fine. You must sell to or store witha licensed gun dealer, or tum in to a law enforcement agency, any gums or other firearms that you have or control as stated in item @). The court will require you to prove that you did so, Notice Regarding Nonappearance at Hearing and Service of Order Ifyou have been personally served with this Temporary Restraining Order and form EA-109, Notice of Court Hearing, but you do not appear a the hearing either in person or by a lawyer, anda restraining order that does not differ from ths order except forthe expiration dat is issued atthe hearing, a copy of the order will be served on you by mail at the address in item@), Hf this address is not corrector you wish to verify thatthe Temporary Restraining Order was converted into a retraining ‘order at the hearing without substantive change, orto find out the duration of the order. contact the clerk of the een After You Have Been Served With a Restrail ing Order + Obey all the orders + Rend form EA-120-INFO, How Can J Respond to a Request for Elder or Dependent Adult Abuse Retraining Orders?, to learn how to respond to this Order. * Ifyou want to respond, fill out form EA-120, Response fo Request for Elder or Dependent Adult Abuse Restraining Orders, and file it with the court clerk, You do not have to pay any fee to file your response * You must have form EA-120 served on the person in (@)(the person asking the court for protection of the elder or dependent adult or the elder or dependent adult ifn other person is named in thet item), or that person's attorney, by mal. You cannot do this yourself. The person who does the mailing should complete and sign form EA-250, Proof af Service of Response by Mail. File the completed proof of service withthe court clerk before the hearing date or bring t with you to the hearing. + In addition to the response, you may file and have declarations served signed by you and other persons who have Personal knowledge of the facts. You may use form MC-030, Declaration, for this purpose. Its available from the clerk's office at the court shown on page 1 of this form or at wwrw.cowris.ca.gov/forms. If you do not know how to Prepare a declaration, you should see a lawyer. * Whether or not you file @ response, you should attend the hearing, Ifyou have any witnesses, they must also go tothe hearing. + At the hearing, the judge can make restraining orders against you that last For upto five years. Tell the judge why you disagree with the orders requested. Seen Enforcing the Restraining Order This order is enforceable by any law enforcement agency that has received the order, is shown 8 copy of the order, or has verified its existence on the California Restraining and Protective Orders System (CARPOS). Ifthe law enforcement ‘gency has not received proof of service on the restrained person, the agency must advise the restrained person of the terms of the order and then must enforce it. Violations ofthis order are subject to criminal penalties [This is a Court Ord Temporary Restraining Order (CLETS-TEA or TEF) EAAI0, Page 518 (Elder or Dependent Adult Abuse Prevention) Leiexsh AuemetedCalfrna deal Cound FermStart Date and End Date of Orders This order starts on the date next tothe judge’s signature on page 4. The order ends on the expiration date in item @) on age 1 Arrest Required if Order Is Violated {fan officer has probable cause to believe that the restrained person had notice of the order and has disobeyed the order, the officer must arrest the restrained person. (Pen. Code, §§ 836(6)(1), 13701(b).) A violation ofthe order may be 8 Violation of Penal Code section 166 or 273.6. Agencies are encouraged to enter Violation messuges into CAROS. Notice/Proof of Service The law enforcement agency must first determine if the restrained person had notice of the order. Consider the restrained person “served” (given notice) if (Pen. Code, § 836(c)(2)) + The officer sees a copy of the Proof of Service or confirms that the Proof of Service is on file; or * The restrained person was informed of the order by an officer. An officer can obtain information about the contents ofthe order and proof of service in CARPOS. If proof of service on the restrained person cannot be verified. the agency must advise the restrained person of the terms of the order and then enforce it If the Protected Person Contacts the Restrained Person Even if the protected person invites or consents to contact with the restrained person, this order remains in effect and must be enforced. The protected person cannot be arrested for inviting or consenting to contact with the restrained person. The ‘order can be changed only by another court order. (Pen. Code, § 13710(b),) Conflicting Orders—Priorities of Enforcement tf more than one restraining order has been issued, the orders must be enforced according to the following priorities: (See Pen. Code, § 136.2; Fam. Code, §§ 6383(h)(2), 6405(b),) 1. EPO: Ifone of the orders isan Emergency Protective Order (form EPO-001) and is more restrictive than other restraining or protective orders, it has precedence in enforcement over all other orders 2. No-Contaet Order: If there is no EPO, a no-contact order that is included in a restraining or protective order has precedence over any other restraining ot protective order. 3. Criminal Order: If none of the orders includes a no-contact order, a domestic violence protective order issued in a criminal case takes precedence in enforcement over any conflicting civil court order. Any nonconflicting terms of the civil restraining order remain in effect and enforceable. 4. Family, Jvenile, or Civil Order: If more than one family, juvenile, or other civil restraining or protective order has been issued, the one that was issued last must be enforced (Clerk will fill ow this part) —Clerk's Certificate— Clerk's Certificate {certify that this Temporary Resiraining Orcler is a true and correct copy of the Leal] original on file in the court __ Clerk, by » Deputy Seer ing Order (CLETS-TEA or TEF) FAO, Page bof (Elder or Dependent Adult Abuse Prevention) LesiNeis® Automaved Calforni ail Coun! FosEy aT RTT aT ST E18 Morag eastz tos Anges, Ca 0049 — (310)471-3000 FILED ‘Superior Ccwrt of Calitor County nt hee acest reser Self SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES JUN 13-2018 eSeemousenoas EOF LOS ANGELES __| 141 N. Hill Sreet Los Angeles CA 90012 fom tates, GAL for Stan Lee By. a Sussiy Chm eye en 13 M i 3ESLAATN RE OIE OF EX ARTE REGUES Wo NOTEE CHET jrmonBSTR OOK (Temporary Restraining Order) |, Tom Latias declare that: Be 1) did not give notice to the other party in this action because: | was afraid that the violence would reoccur when I gave notice that | was asking for these orders, C7 was afta that the other party would take the children out ofthe area before the order could be granted and served C1 Hbetieve that giving notice would make the orders useless because the other party would 2) attempted and was unable to inform or his/her attorney. ‘that | would be seeking a temporary restraining order. My attempts included. 3) Other reason: | declare that the above is true and correct, and that | executed this declaration at Log A California snar016 a Del Famrore TER OTe DECLARATION OF Ex PARTE NOTICE 04/08Request for Elder or Dependent Adult Abuse Restraining Orders 00 Read Can an Elder or Dependent Adult Abuse Restraining Order Help Me? (form EA-100-INFO) before completing this form. Also fill out Confidential CLETS Information (form CLETS-001) with as much information as you know. @) Elder or Dependent Adult in Need of Protection FullName: Stan Lee Sex GM OF Age: 95 Person From Whom Protection Is Sought Full Name: Keya Morgan Address (if mown): 325 N. Maple Dr. City: Beverly Hills ____ State: CA Zip: 90209 _ Person Requesting Order ‘Who is asking the court for protection? (Check a,b, or ¢): ® (The elder or dependent adult named in @) b. 0 Name: conservator of the [] person [] estate [) person end estate of the person named in(2), appointed by (name of cour) Case No, ¢. Bl Other (name) fom tals —attherney —__ Clerk stomps dlete hora when fr is fled. FILED Supericr Court of Californis Counts nf Vat Aarntan JUN 13 2018 She Ip Lsteny magoone wuceriClerh By HA. Deputy Sean anette Fin court name and street eaarose [Superior Court of Callfornia, County oF ILos Angeles 11 N. Hill Street ILos Angeles. CA 90012 [Central (Cou fits in case number when ora a fed. (Case Number: 18STROO4115 Ghow this person’s legal authority to make this requbst on an attached sheet of paper. Write “Attachment 3e— Information About Person Requesting Protective Order’ for a ttle. You muy use form MCAS, Attachment.) Contact Information Contact information for the person asking the court for protection a. Your Lawyer (if you have one for this case) Name: Self. State Bar No, Finn Name: Levy, Small & Lalas b. Your Address (Ifyou have a lawyer, 66512 sive your lawyer's information. If you do not have a lawyer and want to [eep your home adtress private, ou may give adifferem mailing address instead. The person in CD) does not have 10 give telephone, fax, or e-mail) Address: 815 Moraga Dr —_ City: Los Angeles State: CA Zip: 90049 _ ‘Telephone: (310) 471-3000 Fax: E-Mail Address: Tt GER acc Restraining Orders Request for Elder or Dependent Adult Abuse EA-100, Poge 1 0f8 > (Elder or Dependent Adult Abuse Prevention) LenaNesi® Automated Califrmta Judicial Cure! FormsDescription of Protected Person The person named in(@) (check. or b) 8. (Is age 65 or older and a resident of California >. Is aresidemt of California and an adult under age 65. This person has physical or mental limitations that Testrict his or er ability to carry out normal activities oto protec his or her rights. (Briefly describe Hinitations on the tached sheet of paper or form MC-25. Write “Autachnent SbDescription of Protected Person” for a title.) Additional Protected Persons % Are you asking for protection for any other family or houschold members or for the conservator ofthe elder or dependent adult listed in@? [] Yes [3] No (Ufyes, list them) Full Name Sex Age Lives with you? How are they related to vou? Yes (No - Yes (No Yes G) No ~ C1 Yes 5 No 0 Check here if there are more persons. Auach a sheet of paper and write “Aitachneni 6aAddilonal Protected Persons” for a title. You may use form MC-025, Attachment. . Why do these people need protection? (Explain below) © Check here if there is not enough space for your answer. Put your complete answer onthe attached sheet of ‘Paper or form MC-025 and write “Atachment 6+—Why Others Need Protection” for alle Relationship of Parties How does the person in) know the person in @)? (Explain below): GF Check here there isnot enough space for your answer. Pu your complete answer on the attacked sheet of paper or form MMC-025 and write “Attachment 7—Relationship of Parties" for ate, Respondent is Mr, Lee's caregiver. Venue Why are you fling inthis county? (Checkall that apply: 2, Bl The person in @) lives inthis county ‘The person in A) was abused by the person in@)in this county ©. 1 Other (specify) LeSeren ners ‘Ravin Jamu 1, 2018 Request for Elder or Dependent Adult Abuse EA-100, Page 2 of 8 Restraining Orders > (Eider or Dependent Adult Abuse Prevention) ‘LesaNe® Auomted Cofrni Judit Coun! Forms@) Other Court Cases 4. Has the person in(@) or any of the persons named in@)been involved in another court case with the person in @? BW No Ly Yes fves, specify he kind of each case and indicate where and when each wae fled): Kind of Case Filed in (Counew/State) Year Filed Case Number (ifknown) (1) © Elder or Dependent Adult Abuse @) O Civil Harassment G) 0 Domestic Violence @ Divorce, Nullity, Legal Separation (3) Ol Patemity, Parentage, Child Custody (©) © Eviction ) Oi Guardianship 8) Cl Workplace Violence (©) © Smalt Claims (10) Criminal (1) OF Other (specify) brs there ow any protective or restraining orders in effect relating tthe person in @)or any ofthe persons named in@ and the person in@)? [] No GH Yes (ifyes, atach a copy if vow have one, Description of Abuse a. Abuse means either: (1) Physical abuse, neglect, financial abuse, abandonment, isolation, abduction, or other treatment with resulting physical harm or pain or mental suffering; or (2) The withbolding bya caretaker of goods or services that are necessary to avoid physical harm or mental suffering. 8. Tete court about the last time the person in @) abused the pessonin(®) (1) When did it happen? (Provide dave or estimated date): une 12. 2018 2) Who cise was toere? See attachment. (3) Describe what happened below, GF Check here if there isnot enough space for your answer. Put your complete answer on the attached sheet of paper or form MC-025 and write “Auachment 10b(3)—Describe Abuse” for «title See attachment. (Was the abuse solely nancial abuse unaccompanied By Fore, threat, harassment, intimidation, or any other form of abuse? Oi Yes, only financial abuse. [X] No, the abuse included other forms of abuse described above. DSS eco eve bce 208 Request for Elder or Dependent Adult Abuse EA-100, Page 3018 Restraining Orders > (Elder or Dependent Adult Abuse Prevention) LexiNera Automated Calfrnia Judicial Council Forms(Case Number: ». (5) Did the person in @use or threaten to use @ gun or any other weapon? © Yes i] No (yes, explain below): O Check here if there is not enough space for your answer. Put your complete answer on the attached sheet of paper or form MC-025 and write “Auachment 10b(5)--Use of Weapons" for a ttle © Was the person in @ harmed or injured as a result of the acts of abuse described above? Yes (J No (ifves, explain below) D1 Check here if there is not enough space for your answer. Pur your complete answer on the atuuchedt sheet of paper or form MC-025 and write “Attachment 10(6) -Harm or Injurs” for atte, See attachment. (7) Did the police come? [Yes [J No I'yes, did they give the person in @)or the person in (2) an Emergency Protective Order? Tyes, the order protects (check all that apply) GH theperson in @ —( theperson in @ CI the persons in ®. Attach a copy of the order if you have one.) Is the person in @) a care custodian who deprived the person in (A)of (kept from him or her, did not allow him ‘or her to have or receive, or did not provide him or her with) goods or services that the person needed to avoid physical harm or mental suffering? © Yes Bl No (yes, describe below what the person was deprived of and how that affected him or her): i Check here if there isnot enough space for your answer. Put your. complete answer on the attached sheet of paper or form MC-025 and write “Attachment 10c—Deprivation by Care Custodian” for atte. Yes 0) No . Has the person in@) abused the person in A) at other times? & Yes (No (ifyes, describe prior incidents and provide dates below). GF Check here i there isnot enough space for your answer. Put your complete answer on the attached sheet of Paper or form MC-025 and write “Attachment I0d--Previous Abuse" fora tile See attached. _ PSSSEne cos ert my 3.208 Request for Elder or Dependent Adult Abuse EAA00, Page 4af8 Restraining Orders > (Elder or Dependent Adult Abuse Prevention) Lesa Nexil Autometed Calfrnia. Inala BinnsCheck the orders you want. 7 @)) © Personal Conduct Orders Has the court to ader the person in @) nat to do any ofthe following things tothe person in @ oto any person to be protected listed in @) ® GG Physically abuse, financially abuse, intimidate, molest, atac, strike, stalk, threaten, assault (sexually or otherwise), hit,harass, destroy the personal property of, or disturb the peace ofthe person Contact the person, cither directly or indirectly, in any way, including, but not limited to, in person, by telephone, in writing, by public or private mail, by ineroffice mail, by e-mail, by text message, by fax, or by other electronic means. © FF Other (specify) Oi Check here if there is not enough space or your answer. Put your complete answer on the attached sheet of paper oF form MC-025 and write “Auachnent I Je—Otter Personal Conduct Orders," fora tite The person in @ willbe ordered not take any action to get the addresses or locations of any protected person unless the court finds good cause not to make the order. @® & Stay-Away Orders 4% Task the court to order the person in@ to stay atleast _100_yards away from check al that upp (1) (8) The elder or dependent adult in @). 2) © The persons in) (3) Bi The home ofthe elder or dependent adult, (4) GH The job or workplace of the elder or. ‘dependent adult, (5) Bi The vehicle ofthe elder or dependent adult (6) O Other (specify) : >. Ifthe court orders the person in (2) to stay away from all the places listed above, will he or she sill be able to gettohis or herhome, school, or job? [i] Yes [] No (fo, explain below) 11 Check here fthere is not enough space for your answer. Pat your complete answer on the atached sheet of Paper or form MC-025 and write "Attachment 12b—Stay-Away Orders,” for a title i Cees fered 8 Request for Elder or Dependent Adult Abuse EA-100, Page 508 Restraining Orders > (Elder or Dependent Adult Abuse Prevention) etext tomate California til Counet FormsTask the court to order the person in(@) to move out from and nt return to the residence at (address) ‘The person in @ will suffer physical or emotional harm ifthe person in (2)does not leave the residence, The person in(@)is not named inthe ttle or lease of the residence, either alone or with others beside the person in® © Lask for this move-out order right away to last until the hearing, because: 2. The person in @ assaulted or threatened the person in @); and 5. The person in Des the right to live atthe above residence. (Explain below) OF Check here ifthereis not enough space for your answer. Put your complete answer on the attached sheet of ‘Paper or form MC-025 and write “Attachment 13b-—My Right to Residence,” for a ttt Guns or Other Firearms and Ammunition Does the person in(@) own or possess any guns or ther ireatms? ) Yes) No I don't know Unless the abuse is only financial, ifthe judge grams a protective order, the person in(B) will he prohibited from owning, possessing, purchasing, receiving, or aitempting to purchase or receive uzun, wher firearm, und ainunmnition while the protective order is in effect. The person in 2) will also be ardercel ta turn in to he enforcement, or sel oor store with a gun dealer, any guns or firearms within his or her immediate possession or control. @ Temporary Restraining Order TTrequest that a Temporary Restraining Order (TRO) be issued ageinst the person in(2) to last until the hearing. Tam Presenting form EA-110, Temporary Restraining Order, for the courts signature together with this Request Has the person in@)been told that you were going to go to court o seek a TRO against hiner? Cl Yes [&] No (you answered no, explain why below) GF Check here f there isnot enough space for your answer. Put you: complete answer‘on the attacked sheet of Paper or form MC-025 and write “Attachment 15—Temporary Restraining Order" for a title. ‘See attachment, C) Request to Give Less Than Five-Days' Notice of Hearing You must have your papers personally served on the person in @)at least five days before the hearing, unless the court orders a shorter time for service, (Form EA-200-INFO explains What Is “Proof of Personal Service"? Ferny 4-200, Proof of Personal Service, may he used to show the court that the papers have Been serves ‘Ifyou want there to be fewer than five days between service and the hearing, explain why on the next page: SESiecencecc Rieter ca Request for Elder or Dependent Adult Abuse EA-100, Pope 6018 Restraining Orders > (Elder or Dependent Adult Abuse Prevention) erie AuorciedCalforna tal Come Fors(Case Number: CO Check here ifthere is not enough space for your answer. Put your complete answer on the attached sheet of Paper or form MC-025 and write “Attachment 16—Request to Give Less Than Five-Day's’ Notice” for atte (@ No Fee to Serve Orders Ifyou want the sher ff or marshal to serve (notifer the person in (B) about the orders ‘Jor free, ask the court clerk what you need to do CD Lawyer's Fees and Costs Task the court to order payment ofmy —[] lawyer's fees. court costs, The amounts requested are ikem Amount tem Amount s s _§ Ss 5 s OO Check here if there are more items. Put the items and amounts (on the attached sheet of paper or form MC-025 and write “Attachment 18—Lawyer's Fees and Costs " for a ttle. C Possession and Protection of Animals Task the court to order the following: a. C) That the person in (4) be given the sole possession, care, and control of the animals listed below, which he/ she owns, possesses, leases, keeps, or holds, or which reside in his/her household. (Adentify animals by, €.g.. type, breed, name, color, sex.) {request sole possession of the animals because (specify good cause for granting order): 5 Check here if there is not enough space for your answer. Pul your complete answer on the attached sheet of paper or form MC-025 and write “Attachment 19a—Possession of Animals” for a tte & C) That the person in@)must stay at east__ yards away from, and not take, sell, transfer, encumber, conceal, molest, attack, strike, threaten, hafta or otherwise dispose of, the animals listed above. Meee Request for Elder or Dependent Adult Abuse EA-100, Page Tote Restraining Orders > {Elder or Dependent Adult Abuse Prevention) LexisNeis® Automated Clfornia Judea Coane FormsO Additional Orders Requested ask the court to make the following additional orders (specify): 5 Check here ifthere isnot enough space for your answer. Put your complete ansiter on the attocked sheet of Paper or form MC-025 and write “Attachment 20—ddditional Orders Requested," for a ttle. @) Number of pages attached to this form, ifany: QU Date: Tanyer's name (Fan) ‘Taser 5 signature I declare under penalty of perjury under the laws of the State of Califomia that the information above and on all attachments is true and correct. Date: G \ ex Tom Peter Lallas Type or print your name jon filling Out Ths request Request for Elder or Dependent Adult Abuse A100, Page 808 Restraining Orders (Elder or Dependent Adult Abuse Prevention) ent Nesie8 ed alr Jd Aan oo» a 2 23 4 2 6 2 28 STATEMENT OF FACTS Mr. Stan Lee is 95 years old and has severe hearing and vision impairments. He uses 24- hour nursing care to assist with his activities of daily living. Mr. Lee has recently exhibited short term memory impairment, impaired judgment, and an inability to resist undue influence. Given that there are multiple allegations of financial elder abuse, no one has clear legal authority to act ‘on Mr. Lee's behalf. Mr. Lee has a large estate worth over $50 milli ‘vulnerable to financial predators, There are multiple ongoing criminal and therefore is vestigations regarding these allegations. LAPD and Adult Protective Services have observed that Mr. Lee has short- term memory impairment and is heavily influenced by the Respondent Keya Morgan (see attached police report). Petitioner, Mr. Tom Peter Lallas, was Mr. Lee's attorney from late 2017 until February 2018. Mr. Lee hired Mr. Lallas to assist with various legal matters, including estate planning issues, disputes with persons who misused powers of attorney to Mr. Lee's detriment or otherwise purported to act on behalf of Mr. Lee without Mr. Lee’s authorization, efforts to ftecover documents and personal property that had been removed from Mr. Lee’s home without Mr. Lee's authorization, and various litigation and corporate matters, POW! Entertainment and a class action with respect thereto, including matters involving In February 2018, Mr. Lallas was terminated as Mr. Lee’s attorney and prevented from. contacting Mr. Lee by phone or email. The Respondent Keya Morgan n, a memorabilia collector ‘who inserted himself into Mr. Lee’s life as his caregiver following the passing of Mr. Lee's wife in July 2017, took control of Mr. Lee’s home on February 15, 2018. He hired a security team and made household decisions. On February 16, 2018, Mr. Lallas was informed by a new attorney that Mr. Lee had fired him. After Mr. Lallas made many failed attempts to contact Mr, Lee directly, he reached out to law enforcement to conduct a welfare check on behalf of Mr. Lee, Petitioner, along with law enforcement and Adult Protective Services, believes that Mr. Morgan is unduly influencing Mr. Lee and isolating him, 1 Statement of Facts and Points and Authorities0 a 2 Ea 25 % n 2 ‘The LAPD became involved with Mr. Lee when Mr. Morgan made a financial elder abuse report against Lee’s former business partner in December 2017, Since then, Mr. Morgan has instructed security to deny family members or others who have helped Mr. Lee in the past ‘access to Mr. Lee, Family members have been unable to contact Mr. Lee by telephone. Additionally, Mr. Morgan has forced all of Mr. Lee's staff, including nurses and security personnel, to sign non-disclosure agreements. These agreements have prevented staff from sharing their concems on behalf of Mr. Lee. Mr, Morgan also moved Mr. Lee from his long-time family home to a condominium on June 8, 2018. (On May 30, 2018, law enforcement and Adult Protective Services performed a welfare check on Mr. Lee. Upon their arrival, they advised the security guards who they were, that they needed a private interview with Mr. Lee, and to refuse entry by anyone until they concluded the interview. During the interview, Mr. Morgan arrived at Mr. Lee’s home. The security guards told Mr. Morgan that Mr. Lee was with detectives. Mr. Morgan then made a false 911 call, claiming that there were three unidentified burglary suspects in his 95-year-old friend's home }who had locked everyone out of the house. Additional law enforcement were dispatched to Mr. Lee's home. Later on May 30, 2018, after a security guard refused to sign the non-disclosure Jegrcement, Mr. Morgan made a second 911 call falsely accusing that security guard of assault /with a deadly weapon (ADW) against himself and Mr. Lee. LAPD determined that the allegations contained in these two 911 calls were fabricated, On June 11, 2018, Mr. Morgan was arrested for the crime of False Report of an Emergency at the condominium where he relocated Mr. Lee, That same day, LA County Superior Court issued an emergency protective order protecting Stan Lee against Mr. Morgan. (See attached). Mr. Morgan was released on bond the night of June 11, 2018, The emergency protective order will expire June 13" at 5:00 pm. Mr. Lee was taken back to his home. Petitioner seeks a temporary elder abuse restraining order to continue to protect Mr. Lee ace the emergency protective order expires. Petitioner is concerned that Mr. Morgan will again remove Mr. Lee from his home, using his influence to isolate and unduly influence Mr, Lee. Statement of Facts and Points and Authorities . ®2» 2 2 2B ™ 2s 26 2 28 MEMORANDUM OF POINTS AND AUTHORITIES Elder abuse restraining orders are created by and are part of the remedies under Elder Abuse and Dependent Adult Protection Act (W&I Code section15600 et seq) (“EADACPA”). In EADACPA, the legislature explicitly recognized the unique vilnerabilities of elders and dependent adults. To this end, the Legislature created a definition of elder abuse that was both broad in scope and required a lower standard of proof than both domestic violence and civil harassment restraining orders. EADACPA defines abuse of an elder or a dependent adult as either (a) physical abuse, neglect, financial abuse, abandonment, isolation, abduction, or other treatment with resulting Physical harm or pain or mental suffering, or (b) the deprivation by a care custodian of goods or services that are necessary to avoid physical harm or mental suffering. W&I 15610.07. "Goods and services necessary to avoid physical harm or mental suffering" include, but are not limited ‘0, the provision of medical care for physical and mental health needs, assistance in personal hygiene, adequate clothing, adequately heated and ventilated shelter, protection from health and safety hazards, protection from malnutrition, and transportation and assistance necessary to secure any basic needs. W&I §15610.35 Welfare & Institutions Code section 15657.03 allows the court to restrain any person for the purpose of preventing ¢ recurrence of abuse if'a declaration shows reasonable proof of @ past act or acts of abuse of the petitioning elder or dependent adult. Unlike the civil harassment statute which requires the court to find clear and convineing evidence that unlawful harassment exists (CCP 527.6(d)), the court may grant an elder abuse restraining order on a preponderance ofthe evidence. Bookout v, Nielsen (2007) 155 Cal.Appp.4th 1131. Additionally, the court in Gdowski v. Gdowski (2009) 175 Cal.App.4th 128 held that a protective order under EADACPA Iay be issued based on evidence of past abuse without any particularized showing that wrongtiul acts will continue or be repeated. ANALYSIS Here, Mr. Morgan’s behavior, including, but not limited to, isolation and undue influence, places Mr. Lee's wellbeing at risk. He has been denied contact with family members and other individuals that he has known and trusted over the years, Mr. Morgan relocated Mr. Lee from his family home into an unfamiliar environment without notifying relatives of his 3 Statement of Facts and Points and Authorities2» a 2 23 4 2s 2 28 whereabouts, Mr. Morgan has an upcoming hearing on July 2, 2018 in criminal court. Protective orders are necessary in the interim to prevent further abuse by Mr. Morgan. 4 Statement of Facts and Points and Authorities ®10 " 2 18 4 15 6 7 8 19 20 a 2 2 Pa 2% 26 2 2 DECLARATION OF TOM PETER LALLAS; DECLARATION OF TELEPHONIC NOTICE 1, Tom Peter Lallas, declare as follows: | am the Petitioner in this action. I know of my wn knowledge that the facts set forth in this declaration are true, If called to testify as to these facts, could end would testify about them, This declaration is provided in support of my tition for an elder abuse restraining order on behalf of Stan Lee. Lama Senior Partner at Levy, Small, & Lallas, and have been a member of the California SStateBar in good standing for over 40 years. Given that there are multiple allegations of financial elder abuse, no one has clear legal authority to act on Mr. Lee's behalf. As Mr, Lee's formerattomey before the alleged abuser took over Mr. Lee's affairs, I request permission to erveas Mr, Lee’s Guardian Ad Litem for the sole purpose of obtaining this elder abuse restraining order on Mr, Lee’s behalf against the Respondent Mr. Morgan. On June 12, 2018, at approximately 4:40 p.m., I called Mr, Lee's home residence to give hhim telephonic notice that I would be requesting permission from the court to serve as his {Guardian Ad Litem to seek a restraining order against on his behalf against Mr. Morgan, and to jinform him that 1 would be submitting the paperwork in Room 245 at 111 N. Hill Street at 8:30 zm. After many rings, my call was not answered and I was unable to leave a message, I was retained by Mr. Lee in late 2017. Mr. Lee hired me to assist with various legal fnatters, including estate planning issues, disputes with persons who misused powers of attomey to Mr. Lec’s detriment or otherwise purported to act on behalf of Mr. Lee without Mr. Lee's fputhorization, efforts to recover documents and personal property that had been removed from [Mr. Lee’s home without Mr. Lee's authorization, and various litigation and corporate matters, including matters involving POW! Entertainment and a class action with respect thereto. In February 2018, I was terminated as Mr, Lee’s attomey and prevented from contacting fr. Lee by phone or email. The Respondent Keya Morgan, a memorabilia collector who inserted ‘mself into Mr, Lee’s life as his caregiver following the passing of Mr. Lee's wife in July 2017, (ook control of Mr. Lee's home on February 15, 2018, He hired a security team and made © DECLARATION OF TOM LALLASCe Banke Ke BxRBpern P&esgene eee eee eS SRPEBRES SSG RG ESS ES household decisions. On February 16, 2018, I was informed by a new attorney that Mr. Lee had fired me. After] made many failed attempts to contact Mr. Lee directly, I reached out to law enforcement to conduct a welfare check on behalf of Mr. Lee, Executed this 12" day of June, 2018 at Los Angeles, Califor iia,a ro TPE. 0 ue wre, £2. eBxx cARpOS myrey aus FCN/2741816200516 NO: ont/caoisazee fe 2S [62 051 0cR/100621333, PP ey LAT ‘** SERVED EMERGENCY PROTECTION ORDER +++ *DO NOT ARREST OR DETAIN BASED SOLELY ON THIS RESPONSE* THIS RESTRAINING ORDER RESPONSE MAY BE THE SAME AS: * % s+ + RESTRAINED PERSON INFORMATION * 4 4 4 « NAM/MORGAN, KEYA DOB/19751023 SEX/M RAC/W HGT/602 WGT/160 EYE/HAZ HAT/BLX ‘AKA/MAZHARI, KEYARASH MIS/RP NO ANMO-RP MUST SURRENDER TO LOCAL LAW ENFORCEMENT OR SELL TO ‘DECRNSED GUN DBALER ANY FIREARMS WIN 24HRS OF RECRIVING ORDER AND PILE RECEIPT W COURT W IN 48HRS SHOWING COMPLIANCE-NO CONTACT INCLUDING BUT NOT LIMITED TO PHONE MATL EMATL OR OTHER RLECTRNIC MEANS-PR STAY AWAY FROM 9143 ORIDE WY-RP TAKE NO ACTION TO OBTAIN ADDRESS OR LOC OF PP * * s * * PROTECTED PERSON INFORMATION + 4 + + + PROTECTED PERSON NAME/LEE, STAN PROTECTED PERSON SEX/M 4 © * # COURT INFORMATION + + 4 + « RESTRAINED PERSON PRESENT IN COURT/NO COURT WAME/LOS ANGELES COUNTY SUPERIOR (LOS ANGELES) COURT PHONE NUNBER/(213) 351-7599 COURT CASE NUMBER/T193796 ISSUE. DATE/20180611 EXPIRATION DaTE/20190613 CONTACT PROTECTED PERSON/NO - THE RESTRAINED PERSON MUST NOT CONTACT, MOLEST, ATTACK, STRIKE, THREATEN, SEXUALLY ASSAULT, BATTER, TELEPHON®, OR OTHERWISE HARASS OR DISTURB THE PEACE OF EACH PROTECTED PERSON(S) PIREARM PROVISIONS/CANNOT PURCHASE OR RECEIVE AND MUST SURRENDER ALL FIREARMS STAY AWAY FROM/PROTECTED PERSON, RESIDENCE STAY ANAY/0100 YARDS VACATE ADDRESS/9143 ORIDS WAY * + 4 9 * SERVICE INFORMATION # 4 4 4 4 SERVED DATS/20160611 TIMB/1530 SERVED BY/MUNOZ, DET AGENCY/LAPD IMMEDIATELY CONFIRM WITH CAO194206 LAPD -HOLLYWOOD LoPo TELEPHONE 213 485-4329 IF NO ANSWER CALL TELEPHONE 213 496-8260 *** ENTRY MESSAGE SENT TO NCIC #44 ‘eeees0000 END OF CARPOS MESSAGE t++taussee oureur Msc os2, FROM Hy9ovYYY06/11/2018 15:22PROBABLE CAUSE ARREST WARRANT COUNTY OF LOS ANGELES: (ADULT) STATE OF CALIFORNIA THE PEOPLE OF THE STATE OF CALIFORNIA, TO ANY PEACE OFFICER IN THE COUNTY OF LOS ANGELES 5 Complaint, on oath, having beon made this date before me ty _ Deheotire Gab: [find that here Is probable cause to believe thatthe crime of False Report of an Emergency (14 Was commited on or about May 30,2018 by Keya Morgan, a.ka., Keyrash Mazhar {inatis, the person named or described below and in the allached complaint) WHEREFORE, you ae commanded forthulh to arrest Keya MORGAN, @.k.2,, Keyrash MAZHAR| - Faw ert Patson before any magistral in Los Angles County puruant to Penal Code Sections 621 825, 826, and 648. In or or begin ead person beter a magistrate, you may release, prior tothe ime imitations of Porch cae Section 828, said Person from custody without bail or further appearance belore a pagitate, Defendant isto be admitted to ballin the amount of ‘aL, 2“ 7 ‘This warrant may be executed at anytime during the ten calendar days a1 (thatis, unti_C-/5°~/S. DATED; Judge of the a Ler lye cattana “ PERSON TO BE ARRESTED Sex Mi Race W. 0.0.8, 10/21/1975 Ht. 6-1 _ WL 480 Hair Bk Eyes Bro __DRNo. 18-06-13392 tots fssuance Judicial Distic Vebicle: Year Make Mode, Veh. Lic. No, State _ Res. Add. - Bus. Add, LA.No._ Other No-'s: Cll No, 37283426, FBI No, LEXBNOBTK, CDL No. D4660283 Officer's Name G. Munoz. Officers Serial No. 275; (Print or Type) AFFIDAVIT IN SUPPORT OF A PROBABLE CAUSE ARREST WARRANT Your affentis currenty employed as a potce oficer forthe Los Angeles Police Department and further declares as follows: offense(s), whose reports are attached ty aco and corporate by reference. He/She has reviewed each of these writen reports on iets se They were prepared reports and statements consist of ments contain information from victim(s), witnesses, end others concerning the commission ich a warrant of arrastie being sought. Each ofthese documents is presently aneficel eey oa ages. These reports and {the criminal offense(s) for law enforcement agency. pop on te forgoing, your affentbeleves thet thee exes probable causo to arest_Keya MORGAN.ALK A, Keyrash MAZHAR} forthe cme of False Report of an Emergency (148.3 PC) WE Ree ORE, your affent prays that a waranto arrest be issued forthe arrest and eelzure ofthe person of Keye MORGAN, Adeatimiceyrach MAZHARL DATED: of Magistrate Detective Position of Atfiant - GRACE hogkerrorm om €-S KS uige ofthe Dpemr~ court of the im war, Judicial District © ese. -,0uLT 35) ‘Sworn to beforAttachment Attachment 3e—Information About Person Requesting Protective Order Guardian Ad Litem/AttomeyLOS ANGELES POLICE DEPARTMENT [=ORenER CREE RONEN | ‘CASE NUMBER FOLLOW-UP INVESTIGATION DX murme [exter nesoRT ‘SATE ORG RATTOFETTFTC WHE OF ORG HAT OTA ST RESTORED 3 TURKS. ‘6/4208 . 18-0621333 ET BOOKED TOT ARREST GS ST TE [RETR ma PASE STATUS 7 [jccenebaramceT 2 [ysmamenien 3 ppreronrenrounacn 1B SNR TEN BORE aca cab a or Ie 0 alpen Wom rong eeepiOe Crapis Vl WRpRH ine TeeUTAT aperie DATE PIS SN TRE] | vo ow vein me | NUNC ETE ee JoccunkeD [i PROPERTY aENSoo een Sa ° a (SRC RP aeRO [a=] [aes [aan [eve [TaN [went | —ooE nae TET ms *{m [ow |aix}ro] 61 | 180 fiozingrs| 42 TERE Contmued Lclah lad s- [5 [BEBE aR | Eves HIGHT [erat | Goa] Rae Wa x ROMER TERT + RTI ETO 2 TOTO Ta OTTER TR fs) [BEE | Ra PaaS PHeraRT [wera | — poe | aa RAE ROORESS To aT OTE TOT 3 ETON TARE TROTTER NARRATIVE (USE BELOW COLUWNS FOR MULTIPLE REPORTS ONLY ‘prt | MULTIPLE RPT: DR WOS, “TYPE OF CRIME ao] Viste NAME DATE ORG._RPT_ | VALUE INVESTIGATION CONTINUED: 18 06 13332 False Report ofan Emergency 0631 City of Los Angeles 05 30 2018 18 06 13333, False Report ofan Emergency 0631 City of Los Angeles 05 31 2018 CRIME SUMMARY: DR No. 18 06 13332 ‘Suspect-K, Morgan is an associate of Elder S. Lee (age 95) who resides at 9143 Oriole Way, Los Angeles 90069. Morgan is the Person Reporting (PR) of another crime report (Grand The by Trick/Device, DI No- 18 06 07330) where he alleges financial elder abuse of S. Lee by one of Lee’s former business associates, “As the investigating officer in that case, 1, Detective G, Munoz, Serial No. 27527, have interviewed Lee at hie retidenes £7 02 23 2018 and 05 18 2018, Lee has shown to relay and be infuenced by Morgen, During those interviews, Morgan was removed from the room during the actual interviews af Te At the time, Lee acknowledged how Morgan has helped him, but would forget Moran's naine when speaking of him, “Morgan purports to be an associate and acts as a manager for S. Lee where he has assumed responsibility for handling 8. Lee's personal and financial matters. With authorization from 8. Lee, Morgan biren 24-hour, round-the-clock security persoanel for S. Lee who also has 24-hour nursing care. On 05 30 2018, 1, Detective G. Munoz, Serial No. 27527, received a request from LA County Adult Protective Services (APS) Social Worker, Armen Adzhemyan, to conduct a welfare check for § Lee, At approximately 1315 hrs, 1, along with Detective T, conduct the check at Lee’s residence. Upon arrival, we Xoungblood), and advised them that we did not want any interruption during the interview by anyone (including K Morgan) and to refuse entry by anyone until the interview was concluded. The purpose wes acsiee that ne one had any influence over S. Lee while being interviewed by APS Social Worker, Adzhemyan we eangroeeee™ “no Uyes wwe as ummnandooncen Tyo yes = REPORT OFFICEReT TERTCRDT aT DET. G, MUNOZ 27827 goy CCDICRCE Jones, Serial No, 30894, accompanied Adzhemyan to met with security personnel (Richard Shepp end Leon FICER(S) BERTAL RG DwsianPAGE 2 oF 4 FOLLOW-UP INVESTIGATION Dre 18-0621333 At approximately 1345 hrs, K. Morgan arrived to Lee’s residence and is refused entry by L. Youngblood who is charged with securing the exterior of the Lee residence (R. Shepp seoures the interior). Youngblood advised caver and advised Youngblood that he was going to consult with his attomey. ‘He then lef the location tiie ehicle in which he arrived. According to Youngblood’s cell phone call log, Morgan called hin twee Tass Hours and 1405 hours to check on Lee. Youngblood reassured Morgan that Lee was fine end in tc ca ot detectives (who did identify themselves) during an interview. residence, they detained Youngblood where Shepp notified us of the patrol unit's response, Imet whos patrol Tpit and advised them of the welfare check and the instruction to keep out Morgan who had genovated the soi Upon receipt ofthis information, the Officers Ceja and Incontro cleared ftom the scene as these wee ne endons ofa burglary. Lee was at no point in any danger as indicated by Morgan, INVESTIGATION ‘As indicated by the attached transript ofthis radio call from the 911 recording (obtained from Communications three “unidentified” people who have gone inside On 06 01 2018, I telephonically interviewed Leon Youngblood (security guardexterior of residence) who stated hho was very clear to Morgan that law enforcement detectives were inside with §. Lee and that he was fine, explained that detectives were inside conducting an interview. At that point, APS Social Worker, Adzhemyan, Detective Jones and I were concluding our interview, Shepp notified us of the patrol unit's anival aod detention ofhis partner, Youngblood. We then ¢ame outside and contacted the officers, car es date, 1 also telephonically interviewed Richard Shepp (security guard/interior of residence). He stated ‘hat Youngblood told him that he (Youngblood) was emphatic (to Morgan) that the police deteotives wens inciac With §. Lee and that he was fine. Shepp stated there was no need to call uniformed officers to the sosdevee nad there wns no reason for Morgan to not believe Youngblood in that police detectives were with Lee conducting a welfare checl/investigation. Knowing that there was no need for a uniformed police response, Morgan's was insistent with the 911 operator that his 95 year old friend (Lee) was not safe and that there were three strangers in the house locking everyone out, Feicut operator even acknowledged that there is more information to this incident than the caller (Morgen) is diselosing. In desperation, Morgan goes on to say that he is Lee's caregiver to expedite a rapid uniformes peeol response, ‘mn part of bis communication with the 911 operator, Morgan stated that the security guard does notPAGE 3 oF 4 FOLLOW-UP INVESTIGATION Dre 18-0621333 ‘Very, Scary to me that neither he knows nor I know and neither of any of us know who these people are.” ‘Youngblood’s statement to me and to Shepp refutes Morgan’s claim that Youngblood had no idea who was in the house, Morgan is withholding knowledge (to the 911 operator) that he had been advised that Youngblood ‘old hin that detectives, along with a social worker, who identified themselves had entered the location. At one point in the recording/transcript, Morgan states that an off-duty police officer (possibly referring to Youngblood) is the one locked out. When the operator asked Morgan if it was an off-duty LAPD officer, Morgan stated that the seeutity guard is not off-duty LAPD, but off-duty LASO. Youngblood is not an off-duty LASO, nor is Richard Shepp. ‘Morgan is fabricating the facts to illicit a more high-priority reeponse. Morgan also stated to the 911 operator that “he” (Youngblood) saw them go in and lock the door and lock everyone out. It was never made clear as to whom Morgan is referring. It may be Youngblood in that he wes the security guard he contacted when he came to the residence. Based on the recording/transcript, Morgan has created a scenario that would indicate a volatile situation prompting a uniformed police response which did not exist. ‘CRIME SUMMARY: DR No. 18 06 13333 On 05 31 2018, at approximately 1930 hrs, Suspect-Morgan generated a second call for service ait S. Lee's residence (9143 Oriole Way, LA 90069). This time the call involved the security guards (L. Youngblood and R. Shepp) at the Lee's residence. ‘This was done in an attempt to remove Shepp who refused to sign a non disclosure agreement that Morgan had prepared. Other security and nursing staff members of the Lee honsehold were forced to sign this agreement. ‘The call this time was more serious in nature as it involved an alleged weapon and a threat as articulated by Morgan to the 911 operator. It was generated as an “ADW Suspect There Now.” As evidenced by the 911 audie recording (obtained from Communications Division) and attached transcript of that recording, the police resources dispatched illustrates the severity and inherent danger of this type of police response, A closer review of the Department Incident Call Report documented at least 8 patrol units and one airship/helicopter dispatched to this call. Both security guards (Shepp and Youngblood) were detained without incident and ultimately released as there was no evidence of an ADW. At the request of Lee (and Morgan), Shepp and Youngblood were escorted off the premises. INVESTIGATION: Treviewed the 911 call and recognized Morgan's voice and he also identifies himself to the operator. ‘This 911 call for this incident showed Morgan’s inconsistent description of the incident requiring a swif, effective police response. The 911 operator asks him if he sees a gun, He intially states, “Yes. Of course. But but, but, Imean I think he has a ---yeah, I mean I definitely...” On 06 01 2018, I telephonically interviewed Richard Shepp (security guard/interior of residence) this particular incident, Shepp stated he and Youngblood were not armed during this incident. A subsequent search for weapons confirmed that Shepp and Youngblood were not armed and they possessed the proper permits for the ‘as Note: I recalled our conversation the day before, when the first False Report of an Emergenc’ Suspects There Now-was generated. To summarize, Shepp made it a point to show me and Detective Jones thatpaced oF 4 FOLLOW-UP INVESTIGATION DRY 18-0621333 hhe was not armed and that his weapon and ammunition were separated and secured in his vehicle. He explained that he elected to do that for fear that Morgan would at some point accuse him of thteatening him or S. Lee. Jn one instance, the 917 operator asked Morgen what the suspect (Shepp) said to him that was threatening, Morgan stated that Shepp was “gonna kick my ass and a bunch of other stuff” and that “we have a 93 year old also here who's very, very seared.” The 911 operator also asked where the suspect (Shepp) was located. Morgan stated he was “banging on the door right outside.” When the 911 operator wanted to clarify with Morgan that everyone was inside the residence, safe and away from the suspect (Shepp), Morgan responded thet “they were not safe and he's (Shepp) been threatening... and he's trying to get in” Shepp denied ever threatening Morgan or anyone in the house, banging on any doors or trying to get in. ‘Youngblood was already outside when Shepp was directed to the exterior of the residence, as well. At that point, responding uniformed, officers contacted Shepp and Youngblood and were detained, 1 then telephonically interviewed L. Youngblood and he did not witness any of the things described in this 911 call which depicted Shepp verbally threatening Morgan, Lee, or anyone. Nor did he witness Shepp, banging on Hay doors trying to get back in the residence as Youngblood noted that Shepp was usually in the residence during his seourity assignment, Youngblood also confirmed that he was not armed as evidenced by the officers’ search, for weapons while they he and Shepp were detained. Based on the information obtained the witnesses and the 911 cails, I am submitting a request to obtain a Ramey (Asrest) Werrant for Keya Morgan for violation of 148.3 PC-False Report of en Emergency.