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Old March 16th 12, 04:10 PM posted to alt.california,alt.lawyers,misc.legal,rec.games.chess.politics,rec.games.chess.misc
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First recorded activity by ChessBanter: May 2006
Posts: 14,870
Default Reply Declaration to Guide Dogs for the Blind

Samuel H. Sloan
Administrator with Will Annexed of
Estate of K. Michael Goodall
461 Peachstone Terrace
San Rafael CA 94903
415-419-5980
415-349-6116



SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF MARIN


In the Matter of the Estate of

K. Michael Goodall


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Case No. PR 1100596

REPLY TO GUIDE DOGS OPPOSITION TO MOTION FOR FORENSIC DOCUMENT
EXAMINATION

Hearing Date: March 19, 2012
Time: 8:30 AM
Department: H

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.
2. Guide Dogs for the Blind opposes my motion for a Forensic
Document Examination, but they have no standing to do so. They do not
have the Goodall money yet or, if they do have it, they must give it
back because this court has not decided that they are entitled to
receive the money.

3. At the time of the hearing before this court on March 19,
2012, this court should ask them how much Goodall money they have, how
they got it and on what basis they are holding it. I suspect that they
have it already and are using it to pay their high-powered attorneys
at Reed Smith LLP. I doubt that they would be willing to hire
expensive lawyers to appear in this case if they did not already have
the money.

4. Please note that Bank of America has not filed any opposition
to my motions for a forensic document examination. I have found out
that Bank of America sometimes uses the same forensic document
examiner that I have agreed to retain, James A. Moore. Thus, they
cannot be heard to question his competence and indeed they have not
done so.

5. Guide Dogs for the Blind questions who will pay for the
forensic document examination. The obvious answer is that I will pay
for it. Attached as Exhibit A is correspondence I have received from
the forensic document examiner setting forth his fees. The fees are
substantial and I understand that I will be paying them.
6. Here I should add that I am financing this case with my own
personal money. The two beneficiaries of the will, Frank Thornally and
Roy Hoppe, do not have any money. Mike Goodall when he died had almost
no money and he owed $11,000 to Bank of America on his credit card
bill. Bank of America had cut back on his monthly dole not long before
he died and had refused to pay for his chemotherapy, thereby hastening
his death. As a result, when he died, he was behind in the payment of
his utility bills and all the utilities were were shut off shortly
after his death. After this court appointed me as Administrator of
this Estate, I paid the bills with my own funds, thereby getting the
electricity, water, garbage and telephone restored. There is still an
outstanding water bill in the amount of $1096 which I am trying to
negotiate. Bank of America has refused to pay any of these bills, but
they will have to pay the $1096 water bill if they succeed in taking
over the house and kicking me out.

7. I am paying all of these bills from my own funds I earn
through my book publishing company, Ishi Press. Of course, I expect to
be reimbursed for all these expenses after I win this case. I am
confident that I have a winning case on the merits.

8. Please note that Bank of America has filed no opposition
papers to my 850 motion filed on June 30, 2011 for the recovery of
estate property and demanding an accounting of the funds and a deposit
of the funds with this court, nor does Guide Dogs for the Blind oppose
these motions. Thus, the motions should be granted. However, Bank of
America has filed a demurrer, saying this matter is before the San
Francisco Probate Court. This is not true and I know of no authority
that a demurrer can constitute a proper opposition to a motion to
recover estate property. Bank of America has cited none. Thus, their
motion must be denied.

9. Amazingly, Guides for the Blind includes pages from the
deposition of James R. Hastings taken on November 14, 2011. They
obviously must be hoping that the judge of this court will not read
the deposition and realize what it contains and does not contain. What
it shows is that James R. Hastings cannot remember anything. He has no
specific recollection of anything that the Goodalls said. He has no
notes. He brought nothing with him to the deposition. He cannot find
his files or records. He cannot explain how he was able to write three
declarations filed in these cases without access to any files he made
or notes he took back at the time of the events in question. He cannot
even remember the first name of Kenneth Goodall. He only claims to be
able to recall that the “general gist” of his conversations with the
Goodall parents was that they wanted to give their estate to Guide
Dogs for the Blind regardless of when their son Mike Goodall dies. He
provides no explanation as to why the Trust Documents he drafted does
not say what he claims the Goodall wanted, if indeed that was what
they wanted. Why did he not write the trust documents to say what he
claims they were intended to say?

10. His attorney, Don Lesser, goes to lengths to state that his
client James R. Hastings has not lost the files. Rather, after a
thorough search, he simply cannot find them. The difference might seem
trivial but it leaves open the possibility that Mr. Hastings will
suddenly “find” his files at an opportune moment. A similar thing
happened when the Clerk's Office could not find the will of Kenneth
Goodall for many months but then suddenly found the will in January
2012. I personally do not believe that Mr. Hastings cannot find the
files. I think he has them, knows exactly where they are, and is
holding them in reserve to produce them if he needs them. I also
wonder why he has hired an attorney to represent him, if he truly has
nothing to hide.

11. In their opposition papers, Guide Dogs for the Blind states,
“Sloan is litigating in two separate courts, hoping that somebody will
buy his arguments. Enough already.” The truth is exactly the opposite.
I filed this case in this court as a probate case in January 2011. The
initial hearing was scheduled for March 7 but this court continued
this case for three weeks in order to give Bank of America more time
to respond. Bank of America still did not respond and I was appointed
administrator of the estate. However, some unknown entity (later shown
to be Bank of America) had broken into the residence at 461 Peachstone
Terrace, San Rafael CA and had taken all the contents. By amazing
coincidence, my ex-girlfriend Shanti, who lives in Alameda and who had
visited the Goodall Mansion, went to Michaans Auction House in Alameda
where an auction was taking place and recognized the furniture that
had been taken from Mike Goodall's house. I went there and found the
same furniture and I photographed it. I then went to the Marin County
Courthouse with these photographs as evidence and filed a motion for a
time shortening order because Michaans Actions had marked all of the
Goodall property and had scheduled for sale at auction. A hearing was
held on my motion for a time shortening order by Commissioner Harvey
E. Goldfine. Bank of America did not appear for that hearing even
though the attorney for Bank of America, Gary Rothstein, had discussed
the case with the Probate Examiner in a three-way call that included
me. In view of the non-appearance of Bank of America at the hearing,
Commissioner Goldfine called Gary Rothstein, the attorney for Bank of
America, and got him on the telephone. The Commissioner then granted
my motion and set a hearing date.

12. Even after the hearing had been scheduled, Bank of America
took a hard line. In a series of email exchanges which I have
preserved and can produce, they claimed that the furniture and
fixtures inside the house were estate property and belonged to them.
There was no basis to this claim. They did offer to let us go to the
auction house and recover any purely personal property such as
personal clothing. I refused to agree and demanded that everything be
returned to the place from which it was taken. Finally, on the eve of
the hearing on my scheduled 850 Motion, I received a call at 6:00 AM
from Gary Rothstein, offering to return the property provided that
certain conditions were met. We negotiated over those conditions over
several telephone calls over the next several hours. Meanwhile, I
called my ex-girlfriend Shanti who lives in Alameda and asked her to
go over to Michaans Auction House and find out what was going on. She
did and called back to report that the Goodall stuff was not there any
more because it had been loaded onto two trucks that morning and was
in the process of being transported back to the Goodall Mansion. Thus,
I found out that all of these conditions and negotiations for the
return for the property were nonsense, as Michaans on their own had
decided to return the Goodall stuff. As I was in New York at the time,
I called Frank Thornally to whom I had given the house keys and he was
able to make it to the Goodall Mansion in time to open the house, so
that all the furniture could be returned and placed mostly in the
garage.

13. Attorneys for Guide Dogs for the Blind keep complaining that
I am litigating the same facts in two different courts. Yet, they
force me to do so. At a hearing in San Francisco Probate Court on
March 7, 2012 (last week), the attorney for Guide Dogs, Alicia A.
Adornato, repeatedly stated that the court should end the litigation
right now and decide in their favor without any fact hearing and
without any further discovery. This is the same demand they are making
here. That court declined to do so and set the next hearing date for
May 7. I believe that this court in Marin should tell the San
Francisco court that this case belongs in Marin and thus the San
Francisco proceedings should be dismissed. Bank of America and Guide
Dogs for the Blind have essentially unlimited funds, because they have
all the Goodall cash and they can keep going back and forth between
the two different courts until the estate runs out of money, much as
in the case of Jarndyce and Jarndyce. I am the one who has to pay with
my own funds.

14. The Petition in Probate that I filed in this court in
January 2011 lists the Goodall House located at 461 Peachstone Terrace
San Rafael CA as an asset of the estate. Not counting the trust, this
was the only asset the estate had because Mike Goodall had only a tiny
amount of cash in his bank account when he died plus he owed $11,000
credit card debt and all his utility bills. Not long after I filed
this Petition in Probate, I received a call from Jacquel Hutchings,
the Assistant Vice-President and Trust Officer for Bank of America in
Dallas Texas, and she asked me if I was claiming the house as an asset
of the estate. I confirmed that I was. She then informed me that for
that reason Bank of America was retaining counsel to represent the
bank.

15. I later reported this to Dean Ross and he expressed surprise
that a bank would retain counsel to appear in such a small estate
case. The full estimated value of the house was declared in my probate
petition and this raises the question of how much more is in the
estate that we do not know about. These conversations all took place
long before Bank of America filed their initial appearance in this
case.

16. Bank of America finally appeared on April 21, 2011, but not
in this court. Rather than object to my listing the Goodall House as
an asset of the estate in my filings in Marin, Bank of America filed a
new case but in San Francisco under an old dormant case number from
the 1999 case. I believe that this was improper and should not have
been allowed. It is because of their strategic decision not to oppose
me in the Marin Case but rather to institute a collateral attack over
in San Francisco that has created the situation where I have to keep
going back between two different courts to argue the same case.
17. Bank of America finally filed their first substantive
pleading in this court in Marin on March 9, 2012, two days after the
hearing in San Francisco Probate Court on March 7 in which their
motions were denied. Had they won over there, they would not be filing
here. It is thus Bank of America that is playing games with two
different courts.

18. Guide Dogs for the Blind Inc. is essentially a scam
organization disguised as a charity. The name creates this image of a
poor blind man with dark glasses and a cane hobbling down the street
in need of help. Donors think that by giving their houses to Guide
Dogs for the Blind, they are helping these poor blind people.

19. That is not what Guide Dogs is about at all. It is really
about supporting the life styles of extremely wealthy people, none of
whom are blind and all of whom have tax free dogs. Guide Dogs for the
Blind is one of the richest charities in the entire United States of
America. They have acquired their wealth through tax exempt donations
by gullible people who donate their houses and estates to them without
researching the organization.

20. Guide Dogs for the Blind, Inc. has a net worth of
$330,000,000 (three hundred thirty million dollars) as reported on
their 990 Form Filed with the IRS. Their net assets have increased by
more than $30,000,000 (thirty million dollars) during the last one
year that this court case has been going on. Their directors receive
executive compensation of more than one million dollars per year.

21. The website of Guide Dogs for the Blind shows their
President and CEO pictured with a halo and speaking of how “thrilled”
she is to be “helping people achieve maximum mobility and their full
potential”. It does not mention that she is probably also thrilled at
the annual salary of $232,000 she receives for doing this great work.

22. I hope that this court will take a drive through their
campus. It is a bit hard to find so I have included a Google Earth
satellite photograph as Exhibit B. Their campus has more than 30
buildings and I counted 39 vans with Guide Dogs markings. Many major
universities would be thrilled to have such an extensive campus. To
find them, take Las Galinas past the NorthGate Mall and after seeing
Macy's on the right and a cemetery on the left, you will see the
entrance. It does not seem like much from the entrance until you get
inside. The drive through is amazing. It extends all the way to the
101 Freeway. Yet, I did not see one blind person or one dog on the
Guide Dogs campus.

23. Guide Dogs for the Blind are by far the biggest property
owner in Marin County. They have houses all over Marin County, donated
by rich elderly people who thought they were performing a noble act by
leaving their estates to Guide Dogs for the Blind rather than to their
heirs. Guide Dogs has teams of people who go around with their dogs
preying on rich elderly people of which there a large number in Marin
County and convincing them to leave their houses to the Guide Dogs
rather than their children when they die.

24. Not satisfied with already owning more houses than anybody
else in Marin County, they want to add the Goodall Mansion to their
already large collections of houses. That is what this court case is
all about.

25. They are misleading the public by using the same name as a
governmental organization. Guide Dogs for the Blind is also the name
of a California State Governmental Body based in Sacramento. It is
also the name of organizations in several other states. Although the
Guide Dogs in Marin claims to be the national headquarters, I believe
that those other Guide Dogs organizations are not affiliated with the
one we have here in Marin.

26. Guide Dogs for the Blind, Inc. gets their wealth from their
tax free status as an organization under section 501(c)(3) of the
Internal Revenue Code (tax ID #94-1196195). They do not have to pay
any taxes and people who donate their houses to them can write them
off of their income tax. Because of such organizations, the federal
government is sinking deeper into debt. President Romney has promised
to erase the budget deficit by closing down the Planned Parenthood
that keeps aborting my unborn children. Will President Romney also
close down Guide Dogs for the Blind who keeps trying to steal the
Goodall Mansion?

27. Guide Dogs for the Blind is the perfect example of the
corporate greed that the Occupy People sleeping in the parks are
demonstrating against, except that the Occupy People think it is the
big oil and auto companies who are taking the wealth, not a nearly
invisible organization like Guide Dogs for the Blind, Inc.

28. Had the Goodall Family knowingly left their house to Guide
Dogs for the Blind, Inc., we would not be objecting and we would not
be here. But they did not do so. Back in 1990, Guide Dogs for the
Blind was probably not the avaricious organization that it is today.
The Goodall Trust documents, no-matter how you read them, clearly
state in plain English that Guide Dogs for the Blind gets the Goodall
house if and only if Mike Goodall dies and leaves no heirs before his
parents die. It does not state what happens to the property if Mike
dies after his parents die, which is actually what happened. Thus,
Guide Dogs for the Blind has absolutely no right to the property. They
are simply trying to steal something to which they have no right.
Their motions should all be denied.


WHEREFORE, for all of the reasons set forth above, the motions by
Guide Dogs for the Blind should be denied.


March 16, 2012
Respectfully Submitted,

________________________
Samuel H. Sloan
Administrator with Will Annexed
of Estate of K. Michael Goodall


Verification:

Sam Sloan declares:
I have read the above declaration in this matter, and I declare under
penalty of perjury under the laws of the State of California that the
contents thereof are true and correct to the best of my knowledge and
belief.



DATED: March 16, 2012








Exhibit A



Correspondence with the Forensic Document Examiner Setting forth his
fees





Exhibit B



Google Earth Satellite Photo showing the Campus of Guide Dogs for the
Blind. The extent of the campus in circled in Red.





Exhibit C



Form 990 for Guide Dogs for the Blind filed with the IRS showing among
other things a net worth of $330,000,000 (three hundred thirty
million) and Executive Compensation of more than one million including
$232,000 annually for the CEO
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


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

Alicia A. Adornato
Attorney for Guide Dogs for the Blind
Reed Smith LLP
101 Second Street, Suite 1800
San Francisco CA 94105

Don A. Lesser
Attorney for James R. Hastings
1010 B Street
Suite 350
San Rafael CA 94901

Sam Ware
700 Larkspur Landing Circle, #199
Larkspur, CA 94939
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Old March 17th 12, 04:42 AM 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 Reply Declaration to Guide Dogs for the Blind

https://www.yousendit.com/download/M...cGtiV3hESjhUQw

Samuel H. Sloan
Administrator with Will Annexed of
Estate of K. Michael Goodall
461 Peachstone Terrace
San Rafael CA 94903
415-419-5980
415-349-6116



SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF MARIN


In the Matter of the Estate of

K. Michael Goodall


Case No. PR 1100596

REPLY TO GUIDE DOGS OPPOSITION TO MOTION FOR FORENSIC DOCUMENT
EXAMINATION

Hearing Date: March 19, 2012
Time: 8:30 AM
Department: H

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.

2. Guide Dogs for the Blind opposes my motion for a Forensic
Document Examination, but they have no standing to do so. They do not
have the Goodall money yet or, if they do have it, they must give it
back because this court has not decided that they are entitled to
receive the money.

3. At the time of the hearing before this court on March 19,
2012, this court should ask them how much Goodall money they have, how
they got it and on what basis they are holding it. I suspect that they
have it already and are using it to pay their high-powered attorneys
at Reed Smith LLP. I doubt that they would be willing to hire
expensive lawyers to appear in this case if they did not already have
the money.

4. Please note that Bank of America has not filed any opposition
to my motions for a forensic document examination. I have found out
that Bank of America sometimes uses the same forensic document
examiner that I have agreed to retain, David S. Moore. Thus, they
cannot be heard to question his competence and indeed they have not
done so.

5. Guide Dogs for the Blind questions who will pay for the
forensic document examination. The obvious answer is that I will pay
for it. Attached as Exhibit A is correspondence I have received from
the forensic document examiner setting forth his fees. The fees are
substantial and I understand that I will be paying them.

6. Here I should add that I am financing this case with my own
personal money. The two beneficiaries of the will, Frank Thornally and
Roy Hoppe, do not have any money. Mike Goodall when he died had almost
no money and he owed $11,000 to Bank of America on his credit card
bill. Bank of America had cut back on his monthly dole not long before
he died and had refused to pay for his chemotherapy, thereby hastening
his death. As a result, when he died, he was behind in the payment of
his utility bills and all the utilities were were shut off shortly
after his death. After this court appointed me as Administrator of
this Estate, I paid the bills with my own funds, thereby getting the
electricity, water, garbage and telephone restored. There is still an
outstanding water bill in the amount of $1096 which I am trying to
negotiate. Bank of America has refused to pay any of these bills, but
they will have to pay the $1096 water bill if they succeed in taking
over the house and kicking me out.

7. I am paying all of these bills from my own funds I earn
through my book publishing company, Ishi Press. Of course, I expect to
be reimbursed for all these expenses after I win this case. I am
confident that I have a winning case on the merits.

8. Please note that Bank of America has filed no opposition
papers to my 850 motion filed on June 30, 2011 for the recovery of
estate property and demanding an accounting of the funds and a deposit
of the funds with this court, nor does Guide Dogs for the Blind oppose
these motions. Thus, the motions should be granted. However, Bank of
America has filed a demurrer, saying this matter is before the San
Francisco Probate Court. This is not true and I know of no authority
that a demurrer can constitute a proper opposition to a motion to
recover estate property. Bank of America has cited none. Thus, their
motion must be denied.

9. Amazingly, Guides for the Blind includes as evidence pages
from the deposition of James R. Hastings taken on November 14, 2011.
They obviously must be hoping that the judge of this court will not
read the deposition and not realize what it contains and does not
contain. What it shows is that James R. Hastings cannot remember
anything. He has no specific recollection of anything that the
Goodalls said. He has no notes. He brought nothing with him to the
deposition. He cannot find his files or records. He cannot explain how
he was able to write three declarations filed in these cases without
access to any files he made or notes he took back at the time of the
events in question. He cannot even remember the first name of Kenneth
Goodall. He only claims to be able to recall that the “general gist”
of his conversations with the Goodall parents was that they wanted to
give their estate to Guide Dogs for the Blind regardless of when their
son Mike Goodall dies. He provides no explanation as to why the Trust
Documents he drafted does not say what he claims the Goodall wanted,
if indeed that was what they wanted. Why did he not write the trust
documents to say what he claims they were intended to say?

10. His attorney, Don Lesser, goes to lengths to state that his
client James R. Hastings has not lost the files. Rather, after a
thorough search, he simply cannot find them. The difference might seem
trivial but it leaves open the possibility that Mr. Hastings will
suddenly “find” his files at an opportune moment. A similar thing
happened when the Clerk's Office could not find the will of Kenneth
Goodall for many months but then suddenly found the will in January
2012. I personally do not believe that Mr. Hastings cannot find the
files. I think he has them, knows exactly where they are, and is
holding them in reserve to produce them if he needs them. I also
wonder why he has hired an attorney to represent him, if he truly has
nothing to hide.

11. In their opposition papers, Guide Dogs for the Blind states,
“Sloan is litigating in two separate courts, hoping that somebody will
buy his arguments. Enough already.” The truth is exactly the opposite.
I filed this case in this court as a probate case in January 2011. The
initial hearing was scheduled for March 7 but this court continued
this case for three weeks in order to give Bank of America more time
to respond. Bank of America still did not respond and I was appointed
administrator of the estate. However, some unknown entity (later shown
to be Bank of America) had broken into the residence at 461 Peachstone
Terrace, San Rafael CA and had taken all the contents. By amazing
coincidence, my ex-girlfriend Shanti, who lives in Alameda and who had
visited the Goodall Mansion, went to Michaans Auction House in Alameda
where an auction was taking place and recognized the furniture that
had been taken from Mike Goodall's house. I went there and found the
same furniture and I photographed it. I then went to the Marin County
Courthouse with these photographs as evidence and filed a motion for a
time shortening order because Michaans Actions had marked all of the
Goodall property and had scheduled it for sale at auction. A hearing
was held on my motion for a time shortening order by Commissioner
Harvey E. Goldfine. Bank of America did not appear for that hearing
even though the attorney for Bank of America, Gary Rothstein, had
discussed the case with the Probate Examiner in a three-way call that
included me. In view of the non-appearance of Bank of America at the
hearing, Commissioner Goldfine called Gary Rothstein, the attorney for
Bank of America, and got him on the telephone. The Commissioner then
granted my motion and set a hearing date.

12. Even after the hearing had been scheduled, Bank of America
took a hard line. In a series of email exchanges which I have
preserved and can produce, they claimed that the furniture and
fixtures inside the house were estate property and belonged to them.
There was no basis to this claim. They did offer to let us go to the
auction house and recover any purely personal property such as
personal clothing. I refused to agree and demanded that everything be
returned to the place from which it was taken. Finally, on the eve of
the hearing on my scheduled 850 Motion, I received a call at 6:00 AM
from Gary Rothstein, offering to return the property provided that
certain conditions were met. We negotiated over those conditions over
several telephone calls over the next several hours. Meanwhile, I
called my ex-girlfriend Shanti who lives in Alameda and asked her to
go over to Michaans Auction House and find out what was going on. She
did and called back to report that the Goodall stuff was not there any
more because it had been loaded onto two trucks that morning and was
in the process of being transported back to the Goodall Mansion. Thus,
I found out that all of these conditions and negotiations for the
return for the property were nonsense, as Michaans on their own had
decided to return the Goodall stuff. As I was in New York at the time,
I called Frank Thornally to whom I had given the house keys and he was
able to make it to the Goodall Mansion in time to open the house, so
that all the furniture could be returned and placed mostly in the
garage.

13. Attorneys for Guide Dogs for the Blind keep complaining that
I am litigating the same facts in two different courts. Yet, they
force me to do so. At a hearing in San Francisco Probate Court on
March 7, 2012 (last week), the attorney for Guide Dogs, Alicia A.
Adornato, repeatedly stated that the court should end the litigation
right now and decide in their favor without any fact hearing and
without any further discovery. This is the same demand they are making
here. That court declined to do so and set the next hearing date for
May 7. I believe that this court in Marin should tell the San
Francisco court that this case belongs in Marin and thus the San
Francisco proceedings should be dismissed. Bank of America and Guide
Dogs for the Blind have essentially unlimited funds, because they have
all the Goodall cash and they can keep going back and forth between
the two different courts until the estate runs out of money, much as
in the case of Jarndyce and Jarndyce. I am the one who has to pay with
my own funds.

14. The Petition in Probate that I filed in this court in
January 2011 lists the Goodall House located at 461 Peachstone Terrace
San Rafael CA as an asset of the estate. Not counting the trust, this
was the only asset the estate had because Mike Goodall had only a tiny
amount of cash in his bank account when he died plus he owed $11,000
credit card debt and all his utility bills. Not long after I filed
this Petition in Probate, I received a call from Jacquel Hutchings,
the Assistant Vice-President and Trust Officer for Bank of America in
Dallas Texas, and she asked me if I was claiming the house as an asset
of the estate. I confirmed that I was. She then informed me that for
that reason Bank of America was retaining counsel to represent the
bank.

15. I later reported this to Dean Ross and he expressed surprise
that a bank would retain counsel to appear in such a small estate
case. The full estimated value of the house was declared in my probate
petition and this raises the question of how much more is in the
estate that we do not know about. These conversations all took place
long before Bank of America filed their initial appearance in this
case.

16. Bank of America finally appeared on April 21, 2011, but not
in this court. Rather than object to my listing the Goodall House as
an asset of the estate in my filings in Marin, Bank of America filed a
new case but in San Francisco under an old dormant case number from
the 1999 case. I believe that this was improper and should not have
been allowed. It is because of their strategic decision not to oppose
me in the Marin Case but rather to institute a collateral attack over
in San Francisco that has created the situation where I have to keep
going back between two different courts to argue the same case.

17. Bank of America finally filed their first substantive
pleading in this court in Marin on March 9, 2012, two days after the
hearing in San Francisco Probate Court on March 7 in which their
motions were denied. Had they won over there, they would not be filing
here. It is thus Bank of America that is playing games with two
different courts.

18. Guide Dogs for the Blind Inc. is essentially a scam
organization disguised as a charity. The name creates this image of a
poor blind man with dark glasses and a cane hobbling down the street
in need of help. Donors think that by giving their houses to Guide
Dogs for the Blind, they are helping these poor blind people.

19. That is not what Guide Dogs is about at all. It is really
about supporting the life styles of extremely wealthy people, none of
whom are blind and all of whom have tax free dogs. Guide Dogs for the
Blind is one of the richest charities in the entire United States of
America. They have acquired their wealth through tax exempt donations
by gullible people who donate their houses and estates to them without
researching the organization.

20. Guide Dogs for the Blind, Inc. has a net worth of
$307,000,000 (three hundred thirty million dollars) as reported on
their 990 Form Filed with the IRS. Their net assets have increased by
$30,000,000 (thirty million dollars) during the last one year that
this court case has been going on. Their directors receive executive
compensation of more than one million dollars per year.

21. The website of Guide Dogs for the Blind shows their
President and CEO pictured with a halo and speaking of how “thrilled”
she is to be “helping people achieve maximum mobility and their full
potential”. It does not mention that she is probably also thrilled at
the annual salary of $262,752 she receives for doing this great work.

22. I hope that this court will take a drive through their
campus. It is a bit hard to find so I have included a Google Earth
satellite photograph as Exhibit B. Their campus has more than 30
buildings and I counted 39 vans with Guide Dogs markings. Many major
universities would be thrilled to have such an extensive campus. To
find them, take Las Galinas past the NorthGate Mall and after seeing
Macy's on the right and a cemetery on the left, you will see the
entrance. It does not seem like much from the entrance until you get
inside. The drive through is amazing. It extends all the way to the
101 Freeway. Yet, I did not see one blind person or one dog on the
Guide Dogs campus.

23. Guide Dogs for the Blind are by far the biggest property
owner in Marin County. They have houses all over Marin County, donated
by rich elderly people who thought they were performing a noble act by
leaving their estates to Guide Dogs for the Blind rather than to their
familial heirs. Guide Dogs has teams of people who go around with
their dogs preying on rich elderly people of which there a large
number in Marin County and convincing them to leave their houses to
the Guide Dogs rather than their children when they die.

24. Not satisfied with already owning more houses than anybody
else in Marin County, they want to add the Goodall Mansion to their
already large collections of houses. That is what this court case is
all about.

25. They are misleading the public by using the same name as a
governmental organization. Guide Dogs for the Blind is also the name
of a California State Governmental Body based in Sacramento. It is
also the name of organizations in several other states. Although the
Guide Dogs in Marin claims to be the national headquarters, I believe
that those other Guide Dogs organizations are not affiliated with the
one we have here in Marin.

26. Guide Dogs for the Blind, Inc. gets their wealth from their
tax free status as an organization under section 501(c)(3) of the
Internal Revenue Code (tax ID #94-1196195). They do not have to pay
any taxes and people who donate their houses to them can write them
off of their income tax. Because of such organizations, the federal
government is sinking deeper into debt.

27. Guide Dogs for the Blind is the perfect example of the
corporate greed that the Occupy People sleeping in the parks are
demonstrating against, except that the Occupy People think it is the
big oil and auto companies who are taking the wealth, not a nearly
invisible organization like Guide Dogs for the Blind, Inc.

28. Had the Goodall Family knowingly left their house to Guide
Dogs for the Blind, Inc., we would not be objecting and we would not
be here. But they did not do so. Back in 1990, Guide Dogs for the
Blind was probably not the avaricious organization that it is today.
The Goodall Trust documents, no-matter how you read them, clearly
state in plain English that Guide Dogs for the Blind gets the Goodall
house if and only if Mike Goodall dies and leaves no heirs before his
parents die. It does not state what happens to the property if Mike
dies after his parents die, which is actually what happened. Thus,
Guide Dogs for the Blind has absolutely no right to the property. They
are simply trying to steal something to which they have no right.
Their motions should all be denied.

WHEREFORE, for all of the reasons set forth above, the motions by
Guide Dogs for the Blind should be denied.
March 16, 2012
Respectfully Submitted,

________________________
Samuel H. Sloan
Administrator with Will Annexed
of Estate of K. Michael Goodall


Verification:

Sam Sloan declares:
I have read the above declaration in this matter, and I declare under
penalty of perjury under the laws of the State of California that the
contents thereof are true and correct to the best of my knowledge and
belief.



DATED: March 16, 2012


Sam Sloan





Exhibit A



Correspondence with the Forensic Document Examiner
Setting forth his fees





Exhibit B



Google Earth Satellite Photo showing the Campus of Guide Dogs for the
Blind. The extent of the campus in circled in Red.





Exhibit C



Form 990 for Guide Dogs for the Blind filed with the IRS showing among
other things a net worth of $307,000,000 (three hundred seven million)
and Executive Compensation of more than one million including $262,752
annually for the CEO
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


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

Alicia A. Adornato
Attorney for Guide Dogs for the Blind
Reed Smith LLP
101 Second Street, Suite 1800
San Francisco CA 94105

Don A. Lesser
Attorney for James R. Hastings
1010 B Street
Suite 350
San Rafael CA 94901

Sam Ware
700 Larkspur Landing Circle, #199
Larkspur, CA 94939
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