1 Antranick Harrentsian

8065 Dorian Way

2 Fair Oaks, CA 95628
(916) 225-0061
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4 Antranick Harrentsian, IN PROPIA PERSONA

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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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8 FOR THE COUNTY OF SACRAMENTO

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) Case No.: 05PR00456
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) Renewed Petition to Compel Accounting
Antranick Harrentsian, )
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) Date:
14 Petitioner ) Time:
) Dept: 129
15 vs. )
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Richard Hoffman,
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Defendant
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California Probate Code Section 17200 states that a beneficiary may petition the court to
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20 compel the Trustee to:

21 (B) Provide information about the trust under Section 16061 if the trustee has
failed to provide the requested information within 60 days after the
22 beneficiary's reasonable written request, and the beneficiary has not received
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the requested information from the trustee within the six months preceding the
request.
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(C) Account to the beneficiary, subject to the provisions of Section 16064, if
25 the trustee has failed to submit a requested account within 60 days after written
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request of the beneficiary and no account has been made within six months
preceding the request.
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- 1 –
Petition to Compel Accounting
1 Petitioner Harrentsian sent a request for a trust accounting (see Attachment A) to Trustee

2 Richard Hoffman’s attorney on September 12, 2018. It has been over 60 days since the request, and
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Mr. Hoffman and his attorney Daniel Hunt have not responded to Plaintiff’s reasonable request.
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Mr. Hoffman’s last accounting, titled “Second Account of and Report of Richard Hoffman as
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Trustee”, (filed on January 4, 2013) covering the period August 9, 2011 to November 8, 2012, was
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7 denied by this Court on February 11, 2014. Mr. Hoffman, therefore, has not accounted to the

8 beneficiaries of the Kaive Harrentsian Revocable Living Trust for a period of more than seven (7)
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years. Indeed, since becoming Trustee of the Kaive Harrentsian Revocable Living Trust on
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September 25, 2007, Mr. Hoffman has accounted to the beneficiaries only once, covering the period
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September 25, 2007 to August 8, 2011.
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13 Petitioner’s request to Compel Accounting was denied with prejudice on January 23, 2019.

14 However, the Court had previously ordered Mr. Hoffman to file an accounting on December 14,
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2012. The Trustee did not object to the Court’s order. Mr. Hoffman filed an account on January 4,
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2013. However, this accounting was denied by the Court on February 11, 2014. Because his
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accounting was denied, Mr. Hoffman has not complied with the Court’s order. Furthermore,
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19 Therefore, Petitioner prays for an order requiring Mr. Hoffman to provide to Petitioner:

20 1) An accounting of the Kaive Harrentsian Revocable Living Trust encompassing the

period 8/09/11 to present;
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22 2) All documents evidencing the disposition of the Kaive Harrentsian Revocable Living
Trust property 2002 Mercedes Benz MLK automobile;
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3) Copies of any/all of the “promissory notes” from Richard Hoffman to the Kaive
24 Harrentsian Revocable Living Trust;
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4) Copies of all bank statements for the JPMorgan Chase Bank, N.A. account number
26 000003954760267.
27 VERIFICATION
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- 2 –
Petition to Compel Accounting
1 I, Antranick Harrentsian, am the Petitioner in the above-entitled proceeding. I have read the
foregoing petition and know the contents thereof. The same is true of my own knowledge, except as
2 to those matters which are therein stated on information and belief, and as to those matters, I believe
it to be true.
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4 I declare under penalty of perjury under the laws of the State of California that the foregoing is true
and correct.
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Date: January 23, 2019 __________________________
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Antranick Harrentsian
7 In Propia Persona

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- 3 –
Petition to Compel Accounting