Reply
 
LinkBack Thread Tools Display Modes
  #1   Report Post  
Old March 2nd 12, 06:41 PM posted to alt.california,alt.lawyers,misc.legal,rec.games.chess.politics,soc.culture.usa
external usenet poster
 
First recorded activity by ChessBanter: May 2006
Posts: 14,870
Default Petition Filed in Estate of Mike Goodall, chess organizer

Here's the link to this file including exhibits:
http://www.yousendit.com/download/M3...OW5LVlhFdzhUQw

Sam Sloan declares:

1. I am the Administrator with Will Annexed of the Estate of K.
Michael Goodall. I have personal knowledge of the matters set forth
herein and, if called upon to testify, could and would competently
testify thereto. I make this declaration based upon my own personal
knowledge unless otherwise stated.
2. I reside at 461 Peachstone Terrace, San Rafael, CA 94903 and
have resided there since 1998.
3. This estate is concerned with the authenticity of three
documents all purportedly signed on the same date of August 24, 1994.
These three documents consist of “Pour Over” wills purportedly signed
by Kenneth and Rachel Goodall on August 24, 1994 and a trust document
purportedly signed by both of them also bearing the same date.
4. I believe that these documents are all forgeries or are
otherwise not authentic. The basis of my belief is that it was
virtually impossible for Kenneth F. Goodall to have signed these
documents on that date of August 24, 1994, just 17 days before his
death on September 10, 1994. He was extremely ill. He had been ill for
at least two years but his condition had gotten much worse. He had
just survived an operation for esophageal cancer. He had a feeding
tube inserted in his abdomen. A witness who visited him in the
hospital with his son Mike and wife Rachel is prepared to testify that
he was on life support, was unconscious and it was recommended that he
not be awaken. The forger has changed his testimony several times as
to where these documents were signed, first starting that it was in
his office, then in his home, then in San Anselmo. We are prepared to
prove that he was in none of those places. Most importantly, the
witness to both of these wills states vehemently that she never signed
these documents and would never have signed these documents. Her
husband and daughter agree with her that they would have been involved
and that she absolutely would not have signed these documents.
Finally, it is just inconceivable that Col. Kenneth Goodall would have
written his only son out of his will just 17 days before he died,
considering how devoted the father was to his son and how devoted his
son was to his father. There is a handwritten statement in the ring
binder left by Kenneth F. Goodall that states, “I have never
encountered a lawyer who did not leave me feeling poluted afterwards.
I despise them as a class and as individuals”. It is thus
inconceivable that on his death bed he would knowingly sign a document
that virtually took all rights away from his only child and gave them
to a lawyer.
5. As to the motivation of the forger, he was at that time an
employee of Bank of America. These documents took the role of back-up
trustee away from Security Pacific Bank and gave it to Bank of
America, of which he was the manager. This has enabled him to earn
administration and legal fees in the amount of several hundred
thousand dollars since that time. Needless to say, all of these funds
will have to be paid back if these documents are determined to be
forged.
6. The wills are on file at the Marin County Superior Court.
Kenneth Goodall’s will is number W001916 and Rachel Goodall’s will is
number W001919. I have filed a motion in that court for a Forensic
Document Examination of those two wills. I am confident that a
forensic document examination will show that both of those wills are
forged or are otherwise not authentic.
7. I am also seeking forensic examination of the trust
documents. There are three known trust documents. They a
A document entitled “The Goodall Trust” and dated September 12, 1990.
A document entitled “Declaration of the Goodall Trust” and dated
August 24, 1994.
A document entitled “Second Amendment to Goodall Trust” and dated
January 19, 1999.
8. All three of these documents bear the signature and notary
seal of James R. Hastings. I have checked with the California
Department of State in Sacramento and Mr. Hastings is still registered
as a Notary Public in the State of California and has been so
continuously since at least the 1970s. I have demanded of Mr. Hastings
pursuant to California Government Code Section 8206 (c) a photostatic
copy of the line item representing each of the transactions in which
he acted as a Notary Public and notarized the signatures of Kenneth F.
Goodall, Rachel A. Goodall and/or Kenneth Michael Goodall. A copy of
my letter demanding a copy of these line items is annexed hereto and
Marked Exhibit A. Sufficient time has passed and Mr. Hastings has not
responded to my demand.
9. I believe that the documents dated September 12, 1990 and
January 19, 1999 are genuine but that the document dated August 24,
1994 is a forgery. Michael certainly was not going to object to the
trust dated September 12, 1990, because that Trust gives everything to
Michael. Attached hereto as Exhibit B is the relevant page of the
September 12, 1990 trust. As can plainly be seen, that trust gives the
entire Goodall Estate to Michael.
10. Mr. Hastings claims to have lost the Trust Documents. Even
if he has lost the trust documents he cannot legally claim to have
lost the notary public journal because California Government Code
Section 8206 (a)(1) requires, “The journal shall be kept in a locked
and secured area, under the direct and exclusive control of the
notary.”
11. I want all of these documents examined by a Forensic
Document Examiner. The problem is that these documents are not in the
files of the court. They are in the possession of James R. Hastings
and/or Bank of America and/or Guide Dogs for the Blind, Inc. who
refuse to let us see them. I want this court to order these documents
to be turned over to the same Forensic Document Examiner.
12. In order to determine whether these documents are forged or
altered or that they are mere copies, I have agreed to retain a
Forensic Document Examiner who is vastly and eminently qualified in
this field, having worked with the FBI and other governmental agencies
to determine forgeries. He is David S. Moore. He has a laboratory
located at 9010 Barrhill Way, Fair Oaks, California 95628. This
laboratory contains highly sophisticated devices such as microscopes
that easily enable him to determine if a document is forged or not.
These devices cannot be effectively transported out of the laboratory
environment. Therefore, I am asking this court to order the release of
these documents directly to him as the Forensic Document Examiner. I
will of course not handle the documents myself.
13. I am specifically objecting to the validity of the August
24, 1994 Trust document. I am certain that this document is a forgery
and that the perpetrator of this crime is none other than James R.
Hastings. Facts that recently came to my attention demonstrate that
this is a forgery.
14. The first fact is the declarations by James Hastings filed
in San Francisco Probate Court. They state among other things that
Kenneth Goodall had come to him in 1997 and said that he wanted to
change his will because he was unhappy that Michael had quit his job
and moved back into the family home. It is remarkable that Kenneth
Goodall said this in 1997, since he died in 1994. Next, Hastings says
that in August 1994, Kenneth and Rachel Goodall came to his office and
asked him to prepare new trust documents for them to sign taking all
powers out of the hands of their only son, Michael, and giving them to
Bank of America, of which Hastings was the manager of the Trust
Department. However, it is impossible for this to have happened
because Kenneth Goodall was on his death bed at the time and his wife
Rachel had always had difficulty walking and could not climb stairs
and was not capable of going anywhere without her husband's
assistance. The Death Certificate of Kenneth Goodall which is annexed
hereto and marked Exhibit C states on line 113.
“Was Operation performed for any condition in item 107 or
112? If yes, list type of operation and date.
“Feeding Jejunostomy 07/25/1994”

15. Kenneth Goodall died on September 10, 1994. During the time
between the operation on July 25, 1994 in which a feeding tube was
inserted into his abdomen and his death on September 10, 1994, he was
entirely bedridden. He was either in the hospital or in his home in a
hospital bed. He never went to the office of James R. Hastings or
anywhere else for that matter. Thus, the claim by Hastings that he
came to the office of James R. Hastings and asked for his will and his
trust documents to be changed only 17 days before his death is simply
a lie.
16. In addition to the purported Trust document dated August
24, 1994, there are two other documents bearing the same date. These
are new wills signed by Kenneth and his wife Rachel Goodall. These are
“pour over wills”. They provide that the assets of Kenneth and Rachel
be poured into the Trust. Without these wills, the trust has no money.
However, both wills bear the purported signature of Nancy Rodgers, who
was a close friend of Rachel Goodall and lived across the street at
470 Peachstone Terrace. Nancy Rodgers states that although the
signatures look like hers, they are not hers and she never signed
these documents. She says that she never witnessed any wills signed by
either Kenneth or Rachel Goodall. She is certain of this. However, she
does remember signing quite a different document after Kenneth had
died. She states that after the death of Kenneth, Rachel, who was her
best friend, called her and another neighbor, Barbara Dagitz, who
lived next door at 455 Peachstone Terrace, to come over and sign a
health directive. She states that when she and Barbara Dagitz arrived
in the house of Rachel Goodall, only a lawyer plus Rachel were
present. Michael was not there and Kenneth had already died. She says
that she was surprised that she was being asked to witness a health
directive as she did not see any need for a witness to sign such a
document. Nevertheless, she signed it. Attached hereto as Exhibit D is
a declaration by Nancy Rodgers stating these facts.
17. Nancy Rodgers and her husband William Rodgers state that
shortly before the death of Kenneth Goodall, they received a call from
Rachel Goodall, asking them to come over, stating that if they wanted
to see Kenneth they should come over now as Kenneth would not be with
us much longer. At first, her husband, William Rodgers, did not want
to go, but finally he agreed to go, as they had not seen Kenneth in a
long time. They found Kenneth Goodall sitting up in bed with his arms
folded trying to look as normal as possible. He was being fed through
a feeding tube. The Rodgers expressed surprise that Rachel Goodall was
able to handle this situation.
18. That was the last time they ever saw Kenneth. Both Nancy
Rodgers and her husband William Rodgers are certain that neither of
them signed any documents as witnesses for Kenneth Goodall on that
date or at any other time.
19. Compare their statements with the statements made by James
Hastings at a deposition we took of him on November 14, 2011. The
transcript of the Deposition is annexed as Exhibit E. On page 49, he
is asked if he can recall anything with regard to Mr. Goodall's health
at the time. He answers “No”. He is asked several other questions
about the health or physical condition of Mr. or Mrs. Goodall at that
time. In each case, Hastings says he can recall nothing about their
health condition or what they specifically said to him at this or at
any other time.
20. Surely any lawyer when asking a client to sign a will and
other documents drastically changing and revoking his prior estate
plans would inquire and would notice that the man signing the will was
in a hospital bed and was being fed through a feeding tube, especially
when he died only 17 days later.
21. From this we can infer what really happened: James Hastings
never really saw Kenneth or Rachel Goodall in the months before the
death of Kenneth Goodall in September 1994. However, after Kenneth
Goodall had died and been buried, Hastings had Rachel Goodall ask her
two best friends, Nancy Rodgers and Barbara Dagitz, witness a Health
Care Directive. In the Goodall Estate Planning binder, there is a
document entitled “Durable Power of Attorney for Health Care” signed
by Kenneth and a space for a similar document signed by Rachel, except
that the document signed by Rachel is missing. This document signed by
Kenneth checks the box for “I have obtained the signatures of two
witnesses who personally know me”. This explains why Nancy Rodgers and
Barbara Dagitz were called.
22. What clearly happened is that this missing document is the
document signed by Rachel Goodall and witnessed by Nancy Rodgers and
Barbara Dagitz after Kenneth had died. James R. Hastings then took
this document and, by using Adobe Photoshop or similar means,
transposed the signatures of Rachel Goodall and Nancy Rodgers onto
other documents including the two wills and the 1994 Trust. Thus, the
Health Care Directive gave him all the signatures he needed to create
the other documents, except for the signature of Kenneth Goodall, and
that was readily available on numerous documents in the possession of
Mr. Hastings. Hastings had plenty of signatures of Kenneth Goodall on
other documents, so the fact that Kenneth was dead created no barrier
to his creating a document signed by Kenneth.
23. Until January 2012, the Will of Kenneth Goodall was
reported to be lost or missing by the Clerk's Office. The Marin County
Clerk's Office including Stacy in the record room spent months in a
frantic search for this missing will. Finally, a few days ago, the
will was “found”. It is highly irregular and unusual for any document
and especially for a will to go missing in the court files like that.
Hastings of course knew that the Clerk's Office was searching for the
will and that the entire case depended on that will, so he most likely
slipped it back in, which is an easy thing to do for someone such as
Mr. Hastings who has been working for years with documents in this
Clerk's Office.
24. James R. Hastings has failed and refused to provide any
documents from his files, although these files are the subject of a
subpoena and court order. Hastings states that he has lost the entire
Estate Planning File for the Goodalls and his other files pertaining
to the Goodalls are not relevant and therefore he refuses to produce
them. Among the files that Mr. Hastings claims are not relevant are
presumably the Health Care Directive witnessed by Nancy Rodgers and
Barbara Dagitz. If we had that document we could see if the signatures
on that document are identical to the signatures on the wills.
25. I have examined at the Marin County Superior Court the
recently discovered purported original of the purported Last Will of
Kenneth F. Goodall, a copy of which is attached hereto as Exhibit F,
and the purported Last Will of Rachel A Goodall, copy of which is
attached hereto as Exhibit G. These documents are on file at the Marin
County Superior Court. Kenneth Goodall’s will is number W001916 and
Rachel Goodall’s will is number W001919.
26. What is remarkable about these documents on file with the
Court is that they do not appear to be original documents; that is,
that the three signatures and the two dates which appear on each of
these documents at page 7 of each of these documents are not in blue
ink, and I can feel no depression on the back or front of these pages
to indicate that a pen was pressed on the paper to otherwise indicate
an original signature. The total of six signatures do not show any
variation in pressure or indentation in the paper. Thus, the documents
appear to be copies and are not originals. As to how they were created
I do not know but if I were creating them I would use Adobe Photoshop.
27. Attached hereto as Exhibit H is the Declaration filed by
James R. Hastings in San Francisco Probate Court after he was ordered
by that court to search for the files and produce them if he could
find them. As you can see from his declaration, he is not able to find
any of the Goodall files. It is at a minimum professional misconduct
for a lawyer to lose or misplace files vitally important to such an
important case involving millions of dollars.
28. Another document Hastings is unable or unwilling to produce
is the original power of attorney that Rachel Goodall gave to her son
Michael Goodall. We have been able to obtain a copy of this power of
attorney from USAA Management, where the Goodalls kept substantially
all of their money up until the death of Rachel Goodall in 1999.
However, their copy is not signed. Michael Goodall tried to obtain the
original signed document from Mr. Hastings but Hastings refused to
give it to him, just as Hastings is now refusing to give me any
documents from the Michael Goodall Files, although I am legally
entitled to them as I am the personal representative of K. Michael
Goodall and thus am entitled to my own files back.
29. As can be seen, this Power of Attorney gave Michael Goodall
the power to modify or vacate the Goodall Family Trust. Michael
Goodall tried to do exactly that and wrote numerous letters to USAA
Investment Management demanding changes in the accounts. These letters
were ineffective because Michael did not have the original signed
power of attorney. James Hastings had the original power of attorney
presumably in the same files that he now refuses to give us. A copy of
the unsigned Power of Attorney as provided to us by USAA Investment
Management is annexed hereto and marked Exhibit I.
30. It could be argued and no doubt will be argued that Michael
could have taken other and further steps to obtain that Power of
Attorney, but it is clear that his efforts would have been futile
especially since we have been trying to obtain these same documents
from Hastings and have gotten nowhere.
31. Kenneth Goodall left two notebooks in Round Ring Binders.
One has a green cover. The other has a blue cover. When Bank of
America broke into the Goodall Mansion on or about February 28, 2011
and took all the contents, they took these two binders. However, they
were returned by the bank on June 10, 2011 under threat of court
order. I do not know if any changes were made during the period when
Bank of America had them.
32. One page found in the green covered binder is marked
Exhibit J. It includes hand written notes regarding Kenneth's plans
for his estate. It says the following:

"General Terms of the wills leave all property to the survivor of Ken
or Rachel, and then to Mike, our son."

Below that, it says:

"It is best that you have some time to think about the subjects
discussed at the first meeting, so try to defer any commitments until
the next meeting. I have never encountered a lawyer who did not leave
me feeling poluted afterwards. I despise them as a class and as
individuals."

33. In view of the above statement by Kenneth Goodall, “I have
never encountered a lawyer who did not leave me feeling poluted
afterwards. I despise them as a class and as individuals”, it is
inconceivable that on his death bed he would knowingly sign a document
that virtually took all rights away from his only child and gave them
to a lawyer, James R. Hastings.
34. The major differences between the 1990 Trust and the 1994
Trust is that the 1994 Trust names Bank of America as the back up
trustee whereas the 1990 Trust names Security Pacific Bank as the
backup trustee. James R. Hastings was the manager of the Trust
Department of Bank of America and this establishes his motivation for
this change. Secondly, and most importantly, the 1990 Trust gives the
estate directly to Michael Goodall and his heirs whereas Section 6.3
on Page 18 of the 1994 Trust consists of a convoluted and circular
paragraph which makes no sense at all but basically gives the estate
to the by-pass trust that in turn gives it to Michael. Thus, read
logically, Michael still gets the estate. That is the reason why
Hastings has filed statements that the intent of the trust was to give
the estate to Guide Dogs to the Blind regardless of whether Michael
died before or after his parents did. Hastings has not offered any
explanation as to why he did not draft the trust so as to do exactly
what he says was the intent of the trust. The standard Nolo Press book
on Living Trusts, available at almost any bookstore, provides a fill-
in-the-blanks form to do exactly what Hastings says was the intent of
the convoluted trust he drew up. Why did he not use the Nolo Press
form? Why does he have the right to say that the intent of the Trust
he drew up was different from what the trust actually says? Even
assuming that in Kenneth's weakened condition after just having
undergone surgery and having a feeding tube inserted in his abdomen
and awaiting his death that he knew would come soon, and even assuming
that Kenneth Goodall read and signed the documents, how does Hastings
and the Courts have the right to decide that the intent of the trust
is different from what is actually says, which is Guide Dogs for the
Blind gets the money if and only if Michael dies before his parents
do.
35. A third difference between the 1990 Trust and the 1994
purported Trust is that the 1994 Trust contains a no-contest clause.
This is in section 8.3 on page 33 of the 1994 document. There is no
“no-contest clause” in the 1990 document. James Hastings used this no
contest clause to frighten Mike into believing that he would lose
everything. In a pleading or paper filed in San Francisco Probate
Court in 2000, Hastings stated that the objection by Michael Goodall
to having Bank of America serve as Trustee constituted a challenge to
the trust and therefore Michael should lose everything including the
house and the money. However, now in this court Hastings reverses
himself saying that Goodall did not challenge the Trust and therefore
is time barred from doing so.
36. A fourth difference between the 1990 document and the 1994
document is the 1990 Trust shows only the house as being in the trust.
There was no money in the trust. This is in accordance to the
statement in Exhibit J that says “No Trust Fund is Established”.
However, the 1994 purported trust says there is $10 plus the house in
this trust. While the ten dollars seems a trivial matter, it does
establish a trust fund.
37. Everything about this case tells us that Hastings is a
fraud, a liar and a scammer. He starts off by saying that Kenneth
Goodall told him something in 1997 when Kenneth Goodall actually died
in 1994. He has changed his story many times. He says that the
Goodalls came to his office in August 1994 when in reality Kenneth
Goodall was in bed being fed by a feeding tube and could not walk or
go anywhere at that time. James Hastings refuses to produce any files
on this matter including the original trust documents and says that he
lost or misplaced them. He cannot remember anything that either
Kenneth or Rachel Goodall said, yet he provides a declaration saying
what their intent was. On December 27, 2011, he stated to Commissioner
Randolph E. Heubach, in open court, “This matter has nothing to do
with me. I am not involved in it at all”. This was a lie. Hastings
completely stonewalls at every step of the way.
38. At the time of the death of Rachel Goodall in 1999 there
was no Goodall money in Bank of America. They did not even have a
regular checking account there. Substantially all their money was with
USAA Investment Management in Texas. Right after Rachel Goodall died,
Hastings started writing letters to the USAA Investment Management
demanding that the funds be transferred to Bank of America. As far as
we can determine, there was at least $610,000 in the USAA Investment
Management account at that time. There was no right and no legal basis
to this request by Hastings to transfer this money to Bank of America.
If the Goodalls wanted the money transferred, they would have done it
while they were alive. Hastings states on pages 58-59 of the
transcript that it is normal not to transfer the cash assets from one
financial institution to another until after the person has died. This
is obviously nonsense. I have been informed by the Probate Examiner
that the transfer of such a large amount of money as over $600,000
should have been done under the supervision of the Probate Court.
Instead, no probate proceeding was filed. As a result, we still do not
know how much money was transferred or where it came from. The estate
documents show other Goodall accounts including a trading account with
Charles Schwab, a stock brokerage firm. We do not know what happened
to that money. We only know that it disappeared and that Hastings was
aggressively writing to everybody who had had dealings with the
Goodalls demanding that all Goodall funds be handed over to Bank of
America. Examples of some of the letters Hastings wrote is annexed as
Exhibit K.
39. We have received about 500 pages of documents from USAA
Investment Management. They have been co-operating fully as opposed to
Bank of America which has been completely stonewalling. Although some
of these USAA documents do refer to a Trust account, none of the
documents show how that account was set up. Neither the 1990 Trust nor
the 1994 Trust is included in the documents provided by USAA
Investment Management. We know that before Mr. Hastings arrived on the
scene, the Goodalls had an attorney named Robert W. Pendergrass. He
practiced law in Marin County for more than 50 years and died on March
24, 2009 at age 91 years. It is possible and indeed likely that he too
set up a trust account for the Goodalls that preceded the 1990 and
1994 documents. With both Bank of America and James R. Hastings
completely stonewalling and refusing to provide any documents or
information and with Hastings saying that he has lost or misplaced all
the files, there is no way for us to determine the truth of the
matter. I am calling for the arrest and criminal prosecution of Mr.
Hastings, not to mention disbarment.
40. For these reasons I want all of these documents examined by
David S. Moore, forensic document examiner, at his laboratory located
at 9010 Barrhill Way, Fair Oaks, California 95628. He has more than
thirty years of document and investigative experience, including
assignments with the Crime Laboratories of the United States Army, the
United States Postal Inspection Service, the Las Vegas Metropolitan
Police, and the California Department of Justice. He has received
extensive training regarding handwriting identification, ink and
document analysis, and examination, reflected in courses from the
United States Army, the United States Secret Service, the Federal
Bureau of Investigation, the American Academy of Forensic Sciences,
and the California Criminalistics Institute. He has been certified as
a "Diplomate" of the American Board of Forensic Document Examiners
since 1978. From 1999 to 2002, He served as one of the Directors on
that Board. He has published numerous articles in the field of
forensic document examination in the Journal of Forensic Sciences,
including “lie Electrostatic Detection Apparatus (ESDA) and its Effect
on Latent Prints on Paper", March 1988; "The Importance of Shading
Habits in Handwriting Identification: A Case Study", January 1983; the
"Evaluation of a Method to Detect the Site of Rubber Erasures by
Powder", October 1981. In addition, he has presented numerous papers
at meetings and conferences of the American Academy of Forensic
Sciences, the American Society of Questioned Document Examiners, the
International Association of Identification, the Southwestern
Association of Forensic Document Examiners, and the Southeastern
Association of Forensic Scientists.
41. He has presented numerous classes on questioned document
subjects to federal, state and local law enforcement officials, both
government and private attorneys, as well as to bank and insurance
personnel.
42. He has testified as an expert in the field of questioned
documents in justice, municipal, and superior, federal and military
courts and administrative hearings in excess of 700 times in more than
20 states throughout the United States, including California.
43. In order to conduct a proper forensic document examination
of the original questioned wills and trusts in this instant case, it
is his professional opinion that the following tests may be necessary.
a. Visual examination;
b. Microscopic examination;
c. Photographic examination;
d. Ink examination;
e. Handwriting examination;
f. Indentation examination; and
g. Any other non-destructive examination necessary to determine the
authenticity of the questioned documents.
44. All proposed examination will be entirely non-destructive
to the document and will be conducted in a manner so as not to
compromise future additional or confirmatory examinations or testing.
Additionally, the original document will not be altered or changed by
any of the proposed examinations.
45. These types of examinations are necessary to evaluate the
genuineness of questioned documents. An ink examination allows him to
analyze the inks used in the documents and draw conclusions about the
use of different inks and to detect whether alternations and/or
interlineations have been made. Indentation examination permits him to
draw conclusions about whether certain documents were together when
they were originally created and also to ascertain whether there is
other information contained on the documents in the form of
indentations that may provide insight into when the document was
created and under what conditions. The other examinations requested
may enable him to draw conclusions about the time frame in which the
document was created and about the genuineness of the document.
46. It is important that he conduct the examination of the
questioned documents at his laboratory using specialized equipment.
The indentation examination, the ink examination, the fluorescence and
luminescence examinations require the use of laboratory equipment. For
example, the microscope that he uses is a stereoscopic trinocular
microscope that is not readily portable. The video spectral comparator
(VSC) that he uses for ink evaluation is also not readily portable.
Furthermore, it is often imperative to strictly control lighting
conditions during an examination; this can be done in a laboratory
setting, but often cannot be done elsewhere.
47. The various examinations that I have listed and the
equipment that he proposes to employ during the examination of the
questioned documents are routine in cases of this nature. Failure to
examine the questioned document in a laboratory setting, with proper
instrumentation, may result in loss of valuable evidence that would
directly address the issue of the document's authenticity.


WHEREFORE, for all of the reasons set forth above, this court should
order that the trust documents of Kenneth and Rachel Goodall and the
Goodall Family Trust be turned over to David S. Moore, Forensic
Document examiner and including the originals of Goodall Family Trust
Documents dated September 12, 1990, August 24, 1994 and January 19,
1999 be handed over to David S. Moore for Forensic Examination.

I declare under penalty of perjury under the laws of the State
of California and the contents thereof are true and correct to the
best of my knowledge and belief.

DATED: March 1, 2012

_______________________


Verification:

Sam Sloan declares:
I have read the Petition and Declaration for an order to turn over
documents to a Forensic Document Examiner filed in this matter, and I
declare under penalty of perjury under the laws of the State of
California and the contents thereof are true and correct to the best
of my knowledge and belief.



DATED: March 1, 2012


Sam Sloan






Exhibit A

Letter demanding pursuant to California Government Code Section 8206
(c) that Mr. James Hastings provide a photostatic copy of the line
item representing each of the transactions in which he acted as a
Notary Public and notarized the signatures of Kenneth F. Goodall,
Rachel A. Goodall and/or Kenneth Michael Goodall.



Exhibit B

Relevant page of the Trust dated September 12, 1990



Exhibit C

Death Certificate of Kenneth Goodall


Exhibit D

Declaration by Nancy Rodgers

Exhibit E

Transcript of the Deposition of James R. Hastings



Exhibit F

Purported Last Will of Kenneth F. Goodall


Exhibit G


Purported Last Will of Rachel Goodall


Exhibit H

Declaration filed by James R. Hastings in San Francisco Probate Court


Exhibit I

Power of Attorney by Rachel Goodall given to Michael Goodall



Exhibit J


Hand written notes regarding Kenneth's plans for his estate












Exhibit K


Letters by James Hastings written after the death of Rachel Goodall in
1999 demanding that funds be transferred to Bank of America









AFFIDAVIT OF SERVICE
I hereby state that I am not a party, I am over 18 years of age and I
served a copy of this motion and the exhibits attached thereto to the
following:

James R. Hastings
1003 3rd Street
San Rafael, CA 94901

Bank of America
1000 4th St.
San Rafael, CA 94901

Gary D. Rothstein
Manatt, Phelps & Phillips, LLP
One Embarcadero Center, 30th Floor
San Francisco CA 94111

Roy Hoppe
461 Peachstone Terrace
San Rafael CA 94903

Frank Thornally
461 Peachstone Terrace
San Rafael CA 94903

Julia Bentley Lemons
12800 Marion Lane W, Apt. 308
Minnetonka, MN 55305-1368
Surviving Sibling of Rachel Goodall

Robert Bentley
Bradford Village #504
906 N Boulevard Street
Edmond, OK 73030

Helen Beth Bentley Perry
7926 Praver Drive W
Jacksonville,FL 32217

Clenda Fern Bentley Zinar
4536 Chatman Street
The Colony, TX 75056

Beverly Gale Bentley Young
2316 Trenton
McKinney, TX 75070

Vickie Bentley Hankins
14580 NE 6th
Choctaw, OK 73020

Jeffrey Bentley
4701 N Douglas Boulevard
Spencer, OK 73084

Chad Everett Bentley
1609 Teepee Trail
Kingsland, TX 78639

Jeanette Goodall Phillips
152 S llth Street
Salina, Kansas 67401

Kristin Kane
University of California
Berkeley College of Engineering
College Relations
208 Mclaughlin Hall #1722
Berkeley, CA 9472A-1722

Guide Dogs for the Blind
Mr. Thomas Horton
Planned Potential Beneficiary Giving Director
350 Los Ranchitos Road
San Rafael, CA 94903

John L. McDonnell, Jr.
Reed Smith LLP
1999 Harrison Street, 24th Floor
Oakland CA 94612

Don A. Lesser
1010 B Street
Suite 350
San Rafael CA 94901
  #2   Report Post  
Old March 2nd 12, 11:38 PM posted to alt.california,alt.lawyers,misc.legal,rec.games.chess.politics,soc.culture.usa
DCI DCI is offline
external usenet poster
 
First recorded activity by ChessBanter: Mar 2012
Posts: 1
Default Petition Filed in Estate of Mike Goodall, chess organizer

On Mar 2, 10:41*am, samsloan wrote:
Here's the link to this file including exhibits:http://www.yousendit.com/download/M3...OW5LVlhFdzhUQw

Sam Sloan declares:

* * * *1. I am the Administrator with Will Annexed of the Estate of K.
Michael Goodall. I have personal knowledge of the matters set forth
herein and, if called upon to testify, could and would competently
testify thereto. I make this declaration based upon my own personal
knowledge unless otherwise stated.
* * * *2. I reside at 461 Peachstone Terrace, San Rafael, CA 94903 and
have resided there since 1998.


cut -

I lay no claim to the estate.

DCI
  #3   Report Post  
Old March 4th 12, 03:50 PM posted to alt.california,alt.lawyers,misc.legal,rec.games.chess.politics,soc.culture.usa
external usenet poster
 
First recorded activity by ChessBanter: May 2006
Posts: 14,870
Default Petition Filed in Estate of Mike Goodall, chess organizer

Roy Hoppe, who is sitting right next to me as I type this, says that
as far as he knows Max Burkett has never been to this house. He met
Max at the Mechanics Institute only. He also does not understand why
Max does a disservice to the memory of Mike Goodall by trying to
undermine our court case against Bank of America and Guide Dogs for
the Blind. Bank of America and Guide Dogs for the Blind tortured Mike
especially during the last months of his life and contributed to his
early death. They refused to pay for his chemotherapy. They cut back
on his monthly allowance for expenses while meanwhile paying
themselves substantial administration fees. He did not have enough to
pay the basic utilities and repairs and maintenance on this house.
Only yesterday I had to pay $1119.00 to repair the plumbing because
the toilets leaked and the drain in the sink was stopped up. It had
been like that for years. Mike had never had the money to repair these
fixtures, even though Bank of America was holding millions of dollars
of his Family Money. They refused even to pay to bury Mike and they
are still refusing to pay for a gravestone or other suitable marker,
although according to Jim Hastings, Guide Dogs for the Blind did pay
him $4700 which was party used to bury Mike in January 2011, more than
three months after he died.

Mike Goodall hated Bank of America and Guide Dogs for the Blind. He
derisively called them the "Blind Dogs". I can bring in a hundred
rated tournament chess players who will testify as to how much Mike
hated these people. Do you really want to help them get Mike's money?

Sam Sloan
Reply
Thread Tools
Display Modes

Posting Rules

Smilies are On
[IMG] code is Off
HTML code is Off
Trackbacks are On
Pingbacks are On
Refbacks are On


Similar Threads
Thread Thread Starter Forum Replies Last Post
Goodall Estate: Motion to Dismiss Claim by Bank of America Samuel Sloan alt.chess (Alternative Chess Group) 7 May 22nd 11 11:43 PM
rec.games.chess.misc FAQ [2/4] [email protected] rec.games.chess.misc (Chess General) 0 May 23rd 06 05:24 AM
rec.games.chess.misc FAQ [2/4] [email protected] rec.games.chess.misc (Chess General) 0 May 8th 06 05:24 AM
rec.games.chess.misc FAQ [2/4] [email protected] rec.games.chess.misc (Chess General) 0 February 19th 06 05:44 AM


All times are GMT +1. The time now is 06:06 AM.

Powered by vBulletin® Copyright ©2000 - 2019, Jelsoft Enterprises Ltd.
Copyright ©2004-2019 ChessBanter.
The comments are property of their posters.
 

About Us

"It's about Chess"

 

Copyright © 2017