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Old July 29th 11, 09:20 AM posted to,,,alt.chess,soc.culture.usa
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Default Goodall Estate: Further Objection to Motion by Bank of America

Samuel H. Sloan
Administrator with Will Attached of
Estate of K. Michael Goodall
461 Peachstone Terrace
San Rafael CA 94903



Case No.: PTR-99-273030


The undersigned, the court appointed Administrator of the Estate of K.
Michael Goodall with will attached, further objects to the Motion of
Bank of America to steal the property of the Estate of K. Michael
Goodall. Bank of America has conducted this case on an entire
fraudulent basis.

1. I intend to seek criminal indictments of Bank of America and their
attorneys for their using false documents to bamboozle the courts into
believing that this case is entirely different from what it is. In
addition, on the afternoon of July 28, 2011 (yesterday) I came home
and found a real estate agent rummaging around in the back yard my
house at 461 Peachstone Terrace, San Rafael, California 94903. There
were two real estate agents trespassing on Estate Property. They said
they had been sent by Guide Dogs for the Blind who, they said, owned
the property.

2. One of the real estate agents gave her name as Carol Chapman of CRC
Partners, San Anselmo CA 94979. The other, a man, who had opened the
gate and whom I found in the back yard and who seemed to be trying to
open the windows to get into the house, did not give his name. I told
them both in no uncertain terms that Guide Dogs for the Blind does not
own the property and has nothing to do with this property. I told them
to get out and to tell Guide Dogs that they had better not send
anybody again.

3. Bank of America and their attorneys are committing a fraud upon
this court by submitting the wrong documents to the courts. They claim
that the Goodall Family Trust of 1990 is a “Trust for Michael”. They
have apparently bamboozled a judge of a court into believing that. The
document they submitted to the court is NOT the real 1990 trust. I
have the real 1990 trust and here it is. It is marked Exhibit A. I
found it in the court file of this case, PTR-99-273030 where it is
also marked Exhibit A.

4. The key provision of this trust is on page 13, section 6.3, which

6.3. Disposition of Credit Shelter Trust Upon Death of Surviving

Upon the death of the surviving spouse, the property in the Credit
Shelter Trust shall be disposed of as follows:

(a) To KENNETH MICHAEL GOODALL, by right of representation, those
issue to take that share in the manner provided in California Probate
Code section 240.

(b) If the property is not completely disposed of by the preceding
provisions, twenty thousand dollars ($20,000) to each of the living
brothers and sisters of the trustors and the remainder to GUIDE DOGS
FOR THE BLIND OF MARIN, INC., of San Rafael, California.

(c) If the property is not completely disposed of by the preceding
provisions, the trustee sha11 pay over and deliver the undisposed
portion outright as follows: One-half (1/2) to the heirs of the
deceased spouse and one-ha1f (1/2) to the heirs of the surviving

5. Furthermore, the amendment to the Goodall Family Trust dated 1999,
a document which opposing counsel failed to include in their motion
papers, clearly states that K. Michael Goodall is the trustee of the
trust, substituting in the place of his father, Kenneth F. Goodall,
who had died. Thus, when his mother, Rachel A. Goodall, subsequently
died, Michael became the surviving trustee.

6. This document shows that Mike Goodall inherited the property. Thus,
the entire assets of the trust is in the Estate of Mike Goodall. The
only way that Guide Dogs for the Blind could have gotten their hands
on the house and the money would have been for Mike Goodall to have
died before his parents did. However, that did not happen, as his
father died in 1994 and his mother died in 1999. Mike died on October
5, 2010.

7. This relationship is confirmed by the drafting attorney, whose
affidavit is included as Exhibit B. This affidavit states in paragraph
2: “Under the terms of the trust, a copy of which is attached hereto
as Exhibit A, their son Michael was made their outright beneficiary
after the death of the survivor of them (page 13, paragraph 6.3(a))
and Michael was their successor trustee.”

8. The affidavit goes further to state in paragraph 8: “In January
1999 Rachel executed a second amendment to the Goodall Trust in which
she named Michael to act with her as co-trustee of the survivors

9. The documents filed in this case further show that at the time of
the death of Rachel Goodall on June 7, 1999, there was no money in the
trust. However, the bank used strong-arm tactics to contact other
financial institutions including USAA Investment Management of San
Antonio Texas and demanded that they transfer the funds held by Rachel
Goodall there, which amounted to $1.6 million, to Bank of America. In
reality, Bank of America had no right to those funds.

10. Counsel for Bank of America stated in open court on May 25, 2011
that they plan to donate the entire Goodall Family Trust to Guide Dogs
for the Blind of Marin County, which would leave the legitimate heirs
of Mike Goodall with nothing, zero. Guide Dogs for the Blind is
basically a scam operation which has amassed a huge fortune by
aggressively soliciting vulnerable old people to leave their houses to
them on the pretext of helping the poor blind people. Guide Dogs is
the richest charity in Marin County. They have houses and property all
over the county, which they have acquired by aggressively soliciting
elderly people to leave their houses to them. The latest Form 990
filed by Guide Dogs for the Blind Inc. shows that donations to them
for the prior year was $23,806,307 and their net assets are
$269,714,615. That is two hundred sixty nine million dollars! A copy
of that Form 990 is attached hereto as Exhibit C.

11. Their business consists of giving lessons to animal-loving
volunteers, teaching them how train guide dogs. There is no way they
could possibly need two hundred sixty nine million dollars in tax
exempt money just to give a few lessons to a few dogs. Clearly, nobody
in their right mind would leave their estate to Guide Dogs for the
Blind if they knew this true situation. I shall be contacting the
Attorney General's office asking for an investigation of the obviously
illegal practices of Guide Dogs for the Blind.

12. I have found out the reason that James R. Hastings advised Kenneth
and Rachel to leave their money to Guide Dogs for the Blind if Michael
Goodall died before they did, which was that Guide Dogs for the Blind
pays a substantial commission or finders fee to estate planners of
around 10%. Thus, according to the estimated value of this estate at
$2.5 million, James R. Hastings stands to receive $250,000 for
bringing in this donation, which he may have to split with the
attorneys for the Bank of America, who are fighting this case now.

13. For these reasons, the motion by Bank of America should be denied.
In addition, the San Francisco case is duplicative of a case going on
in Marin County Probate Court, PR1100596. That case was filed in
January 2011, three months before the case in this court was filed,
and concerns the same estate. The Bank of America is not doing well up
there and therefore is engaging in forum shopping by filing this case

13. They obviously feel they will get a better break from a San
Francisco judge than a Marin County judge. They even challenged me in
this. “Try that on Judge Wiss and see what happens” one of the
attorney's for Manatt, Phelps and Phillips said to me.

14. This sort of thing brings the courts into disrepute and therefore
this case in San Francisco should be dismissed and Bank of America
should be told to file in Marin County where this case belongs.

July 29, 2011

Samuel H. Sloan
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