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7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
9
17
DATE: October 13, 2017
18 TIME: 8:30 a.m.
DEPT.: 67
19 JUDGE: Hon. William P. Barry
21 1. I am personal friend of David Valentine. The facts contained in the following declaration
22 are known to me of my own personal knowledge and if called upon to testify, I could and would
23 competently do so.
24 2. On August 12, 2017, at the request of David Valentine, I signed in to the Los Angeles
26 and I performed a Civil Party Name Search on Cheryl Templeton, of which I paid $2.00 for the cost
27 of the search.
28 ///
2 Superior Court for the cost of the Civil Party Name search I performed at David’s request on August
3 12, 2017.
4 4. Attached hereto as Exhibit B, are true and correct copies of the results of the Civil Party
5 Name Search on the Los Angeles Superior Court’s website for “Cheryl Templeton”.
18 “Third, I do know Marlene Seltzer, as I do many attorneys in this field, due to similar
practice areas of trusts/probate/conservatorships.”
19
13. At David’s request, I printed these two emails and saved them as PDF files and emailed
20
them to his nephew, Ryan Adams at ryanchaseadams@gmail.com before signing out of his email
21
account.
22
14. I would have provided this declaration and the supporting evidence earlier in the week,
23
however I live in Northern California and was forced to evacuate my home due to the fires. This
24
caused serious delays in my ability to provide Ryan with this information in a timely fashion.
25
15. I have attached the following exhibits to this Declaration:
26
Exhibit A: True and correct copy of receipt for purchase of party name search of
27 “Cheryl Templeton” on the Los Angeles Superior Court’s website, performed
on August 12, 2017.
28
7 Exhibif E: True and correct copy of email dated August 31r2017, sent from
Cheryl Templeton to David Valentine failing to disclose her attorney-client
8 relationship with Marlene Seltzer.
9 I declare under penalty of perjury under the laws of the California that the foregoing is true
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COLINTY OF SONOMA )
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6 I am aDeclarant and not aparty in the above-entitled action. I have read the foregoing and
7 know the contents thereof and I certi$r that the same is true of my own knowledge, except as to those
8 matters which are therein stated upon my information or belief, and as to those matters I believe
9 them to be true.
10 I declare under penalty of perjury under the laws of the State of Califomia that the foregoing
11 is true and correct and that this verification was executed in Sonoma, California on October 12,
t2 2017.
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CHERYL TEMPLETON GEN Other Real Property Rights Case 12/12/2013 Stanley Mosk 33
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EXHIBIT C
REPORT OF ONLINE CIVIL PARTY NAME SEARCH RESULTS ON LA SUPERIOR COURT WEBSITE PORTAL
Date of Query: 8/12/17 # RESULTS: 15 TOTAL CASES Search Criteria: 1) Name: TEMPLETON, CHERYL and 2) Name: MARLENE SELTZER
URL: https://www.lacourt.org/paonlineservices/civilindex/CISearchByName.asp
PARTY FILING ATTORNEY OF
NAME CASE TYPE CASE # DATE RECORD COURT CASE NAME
CASE IN Trust BP132521 1/12/2012 Marlene Seltzer, Esq.) Stanley Mosk STRAHM, SHIRLEE - TRUST DTD
CONFLICT: Courthouse DECEMBER 4, 1974 TRUST
SUCCESSOR NOTE: David valentine is a named beneficiary.
TRUSTEE, Successor trustee, Frumeh Labow is represented By
FRUMEH Marlene Seltzer.
Cheryl Conservatorship BP131867 12/1/2011 Marlene Seltzer, Esq. Stanley Mosk NIPARKO, HELEN MILDRED –
Templeton Courthouse CONSERVATORSHIP
Cheryl Trust BP132781 1/25/2012 Marlene Seltzer, Esq. Stanley Mosk PETERMAN, MILTON J. – TRUST
Templeton Courthouse
Cheryl Trust BP133626 3/15/2012 Marlene Seltzer, Esq. Stanley Mosk NIPARKO, HELEN M. - FAMILY TRUST
Templeton Courthouse AGREEMENT
Cheryl Decedent's Estate LP016722 7/3/2012 Marlene Seltzer, Esq. Stanley Mosk DAYAN, MARGOR RACHEL - DECEDENTS
Templeton Courthouse ESTATE
Cheryl Conservatorship BP148151 12/31/2013 Marlene Seltzer, Esq. Stanley Mosk HERRIOTT, DOLORES V. –
Templeton Courthouse CONSERVATORSHIP
Cheryl Trust BP149971 3/5/2014 Marlene Seltzer, Esq. Stanley Mosk THE CHASE THOMAS DITTFELD
Templeton Courthouse TESTAMENTARY TRUST
Cheryl Decedent's Estate BP160697 3/10/2015 Marlene Seltzer, Esq. Stanley Mosk BILEK, KENNETH B. – DECEDENT
Templeton Courthouse
Cheryl Conservatorship BP150274 3/13/2014 Marlene Seltzer, Esq. Stanley Mosk CARUTHERS, BETTY M. -
Templeton Courthouse CONSERVATORSHIP
Cheryl Trust BP150674 3/27/2014 Marlene Seltzer, Esq. Stanley Mosk THE ERMOND JOSEPH NATHANSON
Templeton Courthouse REVOCABLE TRUST DTD: 10/19/09 Related
Case: LP016722
Cheryl Trust BP163277 6/2/2015 Marlene Seltzer, Esq. Stanley Mosk CARUTHERS-KING LIVING TRUST - TRUST
Templeton Courthouse
Cheryl Conservatorship BP170107 1/19/2016 Marlene Seltzer, Esq. Stanley Mosk RAUSCH, BARBARA CONSERVATORSHIP
Templeton Courthouse
Cheryl Conservatorship 16STPB04699 9/30/2016 Marlene Seltzer, Esq. Stanley Mosk MEO-CROYLE, VILMA MARIE –
Templeton Courthouse CONSERVATORSHIP
Cheryl Conservatorship 16STPB04730 10/3/2016 Marlene Seltzer, Esq. Stanley Mosk NAUD, LILLIAN FARMER -
Templeton Courthouse CONSERVATORSHIP
Cheryl Trust 17STPB05069 6/9/2017 Marlene Seltzer, Esq. Stanley Mosk LOUISE P. YBARRA FAMILY TRUST
Templeton Courthouse
Cheryl Conservatorship 17STPB05652 6/23/2017 Marlene Seltzer, Esq. Stanley Mosk GRANT, STEPHEN B. – CONSERVATORSHIP
Templeton Courthouse
EXHIBIT D
David Valentine <dmvalentine1947@gmail.com>
David,
Attached is the agreement you signed which states that you agreed to move from the apartment within 60 days of
Shirley's death. Of course, you didn't do that and now your share of the trust will be diminished by the legal fees and
costs associated with evicting you.
Cheryl Templeton
Probate and Estate Planning Paralegal
Licensed Professional Fiduciary
19725 Sherman Way, Suite 140
Winnetka, California 91306
(818) 707-5261 (private line)
(818) 709-6400
(818) 709-6500 (fax)
(818) 723-9124 (cell)
-----Original Message-----
From: Seltzer, Marlene S. [mailto:mss@wassermanlawgroup.com]
Sent: Thursday, September 7, 2017 1:27 AM
To: Cheryl Templeton <CTempleton@profidsvcs.com>
Subject: Settlement Agreement - David Valentine
This is the same Settlement Agreement I sent you before. David and his attorney negotiated and signed it and the court
approved it.
It clearly states that David must move after Shirley's death. Which he refused to do. I need to go to court to enforce him
moving. When we complete the final Account and distribution, we will ask for surcharges against Victor and David for
them refusing to move.
David will have cash from the Trust and cash from the sale of the apartments. After your fees, you can dump him on the
Public Guardian who will drool at the cash and find a way to take the case. They do have LPS cases and
Conservatorship cases.
-----Original Message-----
From: Xerox9201@wcclaw.com [mailto:Xerox9201@wcclaw.com]
Sent: Thursday, September 07, 2017 1:20 AM
To: Seltzer, Marlene S.
Subject: Scanned from a Xerox multifunction device
Please open the attached document. It was scanned and sent to you using a Xerox multifunction device.
For more information on Xerox products and solutions, please visit http://www.xerox.com
Hi Cheryl,
The day we met at the courthouse I expressed some concerns about Frumeh's interests for the property not alighting with
Davids interests. You told me, "oh, Frumeh would never do that.."
Can you please tell me how you know Frumeh and how you know her attorney Marlene?
Ryan
First, I have no idea what question you asked me that related “to David’s
interests” that I responded “Frumeh would never do that.” I have a vague
recollection that the apartment David and Victor lived in was in the building
next door to the one they were given by the trust, and there was some
agreement between all parties that they had to move, but I have no idea of
the particulars. You will have to ask David and his attorney about this, if that
is what you are referring to.
Second, Frumeh and I are in the same business, both private professional
fiduciaries often appointed by the court, and our paths do cross from time to time.
Third, I do know Marlene Seltzer, as I do many attorneys in this field, due to
similar practice areas of trusts/probate/conservatorships.
Cheryl Templeton