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Old November 27th 12, 06:30 PM posted to rec.games.chess.politics,misc.legal,rec.games.chess.misc,alt.lawyers,soc.culture.usa
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Default Goodall Case: Answer to Motion for Summary Judgment in Marin CountySuperior Court

Here's the link to this file:
http://www.yousendit.com/download/WU...b0JEa1hIRHRVag

Samuel H. Sloan
Administrator of Estate
of K. Michael Goodall
with Will Annexed
461 Peachstone Terrace
San Rafael CA 94903
(415) 419-5980
917-659-3397


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


BANK OF AMERICA, N.A., Trustee of the Trust for Michael created under
the Goodall Trust Dated September 12, 1990

Plaintiff,

vs.

SAMUEL H. Sloan, an individual;
ROY HOPPE, an individual; FRANK THORNALLY, an individual; KAYO KIMURA,
an individual; and DOES 1-10, inclusive,

Defendants
)
)
Case No. CIV 1204541


VERIFIED ANSWER TO MOTIONS FOR SUMMARY JUDGMENT IN COMPLAINT FOR
UNLAWFUL DETAINER


Defendant Samuel H. Sloan individually as as Administrator of the
Estate of K. Michael Goodall with Will Annexed alleges as follows:

1. Defendant Samuel H. Sloan is the Administrator of the Estate of K.
Michael Goodall with Will Annexed, Case No. PR 1100596. Samuel H.
Sloan was appointed as administrator by order of the Marin County
Probate Court dated March 11, 2011. A copy of the order of the court
is annexed hereto and marked Exhibit A.

2. In his petition to be appointed Administrator of the Estate
of K. Michael Goodall, Samuel H. Sloan listed among the assets of the
estate the house located at 461 Peachstone Terrace, San Rafael where
he has resided since 1998. Bank of America was served with this
petition. An officer of Bank of America, Jacquel Hutchings in Dallas,
Texas, called Sloan to ask about this. When informed that the property
located at 461 Peachstone Terrace was an asset of the estate and was
referenced in the petition, Jacquel Hutchings stated that she was
hiring Gary Rothstein, an attorney in San Francisco, to represent the
Bank of America in this case.

3. Subsequently, the Marin County Probate Judge adjourned the
hearing on the petition by Samuel H. Sloan to be appointed
administrator of this estate for three weeks in order to give Bank of
America and their attorney Gary Rothstein the opportunity to appear in
this case. In spite of being given an extra three weeks to appear and
in spite of the fact that Bank of America knew that the house at 461
Peachstone Terrace was listed as an asset of the estate, they did not
oppose the petition and still to this day have not opposed nor
objected to the petition.
4. The order of the court dated March 11, 2011 gives Samuel H.
Sloan as Administrator the right and the power to sell the house
located at 461 Peachstone Terrace. However, he has not sold it. He is
living in it with his daughter, Sandra, aged 10.

5. Plaintiff Bank of America N. A. is NOT the Trustee of the
Trust for Michael and indeed no such trust exists or has ever existed.
The claims made by Bank of America in this and other proceedings are
utterly false and without basis. Their claims made in San Francisco
Probate Court are made in a court that does not have jurisdiction over
the property located at 461 Peachstone Terrace, as the property is
located in Marin County. Their claims constitute an improper
collateral attack on the orders of the Marin County Probate Court.
Their claims must be dismissed.

6. Defendant Samuel H. Sloan has persistently demanded that Bank
of America produce the documents upon which they base their claim.
Bank of America has failed and/or refused to produce any such
documentation or any documents at all. It has become obvious that no
such documents exist. In particular, Bank of America has never
produced and refuses to produce the document which they claim is dated
August 24, 1994 and upon which their entire case rests. This 1994
Purported Trust is Essential to the claims made by Bank of America
because the 1990 Trust made Security Pacific Bank the Successor
Trustee. James R. Hastings was the attorney for Bank of America and
thus the beneficiary of the 1994 Purported Trust whereas he had no
such relationship with Security Pacific Bank. The 1994 Purported Trust
added a No-Contest Clause which Bank of America and its attorney James
R. Hastings later used to frighten Kenneth Michael Goodall that he
would be cut out of the estate entirely and left homeless with nothing
if he contested the Purported Trust. The 1990 Trust does not contain a
no-contest clause. In spite of the fact that the Purported 1994 Trust
is so essential to Bank of America's claims, they would have the
courts believe that they have never had a copy of the Purported 1994
Trust and that James R. Hastings who had the only copy has lost his
copy.

7. Samuel H. Sloan was a close personal “special friend” of K. Michael
Goodall who was the rightful Trustee of the Goodall Trust. Michael
Goodall was made Trustee of the Goodall Trust by the Second Amendment
of the Goodall Trust, a copy of which is Annexed hereto as Exhibit B.

8. The Goodall Trust was a living trust dated September 12, 1990. A
copy of this trust is annexed as Exhibit C. The purpose of this trust
was to insure that the property located at 461 Peachstone Terrace San
Rafael California 94903 not be subject to probate and to avoid estate
taxes. There was no money in the trust; only the house. The trust
documents provided that if Mike died before his parents did the trust
would go to a charity but if Mike died after his patents did the trust
would go to his heirs. Paragraph 7.2 of the 1990 Trust makes Kenneth
Michael Goodall the successor trustee after his parents have died and,
if he is unable to act, makes Security Pacific Bank where the Goodalls
had a long standing relationship the successor trustee.

9. Col Kenneth F. Goodall was born 01 Mar 1916 and died 10 Sep
1994 at age 78. His Social Security Number was 444-40-8884. Rachel A.
Goodall was born 23 May 1916 and died 07 Jun 1999. Her Social Security
Number was 359-07-1738. Kenneth Michael Goodall was born 13 Jan 1946
and died 05 Oct 2010. His Social Security Number was 559-70-3352. All
of them died and are buried in Marin County. All of their property and
assets were located in Marin County. Thus, the Marin County Courts
have exclusive jurisdiction over this case. Since Michael died after
his parents died he and his heirs are the sole beneficiaries of the
trust. In addition, the trust was terminated and ceased to exist by
its terms upon his death nearly two years ago. Bank of America has no
surviving claims. Bank of America does not own the property nor have
any right to it.

10. The relevant documents in this case clearly show that the house
located at 461 Peachstone Terrace is an asset of the Estate. The
relevant documents are the Trust dated September 12, 1990, two “pour
over” wills executed by the Goodalls on August 24, 1994 and the Will
of K. Michael Goodall which is on file with the Marin County Probate
Court. The “pour over” wills are disputed because the witness to the
wills, Nancy Rodgers, states that she did not sign them. Nevertheless,
this does not change the outcome of this case. The wills are marked
Exhibit D and Exhibit E. It is noteworthy that the wills do not
contain the words “as amended”. They refer to the trust dated
September 12, 1990 and not to any purported amendment to the trust.

11. Bank of America has followed a persistent pattern of making claims
in the Marin County Probate Court and when their claims are denied
they make the same claims over in the San Francisco Probate Court
without telling the San Francisco Judge that their claims have been
denied already by another court or even that there is a case pending
on the same subject matter in another court.

12. Bank of America made a claim in the Marin County Probate Court
that objections to a purported 1994 trust are barred by a Statute of
Limitations. This claim was denied by Judge Adams, the probate judge
in Marin County, in a lengthy and reasoned opinion citing relevant
case law. Undaunted, Bank of America went over to San Francisco and
filed exactly the same statute of limitations claim without telling
the San Francisco Judge that this claim had already been denied in
Marin.

13. Similarly, here, Bank of America has filed this Unlawful Detainer
Proceeding without telling this court that Samuel H. Sloan is the
Administrator of the Estate of K. Michael Goodall and that the house
located at 461 Peachstone Terrace is subject to the proceedings in
Marin County Probate Court. In summary, the conduct by Bank of America
in these cases is utterly fraudulent.

14. The proceedings cited in the Amended Complaint filed by Bank of
America in San Francisco have not been finally decided. No Final
Judgment has been Entered. The Estate has filed two notices of Appeal.
Thus the matter is now pending before the California Court of Appeal.
Regardless of the Outcome of the Appeal, Bank of America will still
not own the house. The Trust was terminated more two years ago by the
Death of Mike Goodall. Thus, there is no trust and under no
circumstances does Bank of America have a claim on the house. Samuel
H. Sloan has objected to the jurisdiction of the San Francisco court
from the first pleading for the same reason in that the San Francisco
Courts have no jurisdiction over real property located in Marin
County. Defendants are confident of the success of this appeal which
will result in the entire proceedings in San Francisco being thrown
out. This case should be stayed until that appeal is decided.

15. Bank of America has committed fraud upon the courts by constantly
calling the trust by the name of “The Trust for Michael” as though the
Goodall parents regarded their son Michael as incompetent and unable
to handle his finances. There is no such thing as the Trust for
Michael. There is only the Goodall Trust. The Goodall parents had full
confidence in their son Michael as evidenced by the 1990 Trust that
made him the Successor Trustee and by a Power of Attorney they gave
their son Michael on August 24, 1994, essentially on the death bed of
Col. Kenneth Goodall, who died 17 days later. This power of attorney
was prepared by the attorney for Bank of America, James R. Hastings,
and therefore Bank of America has known about it all along. However,
it was concealed from K. Michael Goodall and from the Defendants in
this case until recently when it was discovered in a locked box. A
copy of this power of Attorney is annexed hereto and marked Exhibit F.

16. In the same locked box was found an unsigned copy of the purported
August 24, 1994 Amendment to the Goodall trust. This is the amendment
which James R. Hastings unsuccessfully attempted to induce the
Goodalls to sign. It was the custom of James R. Hastings to bring two
copies of any document he wanted the Goodalls to sign. The Goodalls
would sign both documents and Hastings would notarize and witness
them. He would keep one of the documents and leave the other with the
Goodalls. The presence of an unsigned copy of the purported 1994 trust
in the same lockbox with a bunch of other signed documents bearing the
same date proves that the Goodalls never signed and refused to sign
the purported 1994 Trust.

17. In the last stage of his life, Col. Kenneth F. Goodall was
terminally ill with Cancer of the Esophagus. On July 25, 1994, an
operation was preformed for a Feeding Jejunostomy in which a feeding
tube was inserted in his abdomen. From that point until his death on
September 10, 1994, he could not process food or talk in the normal
way. Yet, James R. Hastings has claimed that Col. Goodall came to his
office in San Anselmo in August 1994 and asked for changes in his will
and trusts to be made. Defendants are prepared to prove that this
could not be true because Col. Goodall was bedridden and hospitalized
at the time and was incapable of going anywhere. The doctor who
performed the operation for a Feeding Jejunostomy still is practicing
medicine as a cancer specialist and remembers this case and can be
called to testify that Col. Goodall was incapable of doing the things
that James R. Hastings claims that he did.

18. Defendants have repeatedly demanded that Bank of America and their
attorney at the time James R. Hastings produce the 1994 Trust which
they claim governs this case. First Defendants subpoenaed this
document and when Hastings failed to produce it Defendants obtained a
court order requiring that he produce it. Hastings then claimed that
he had lost the document. A copy of the declaration by James R.
Hastings stating that he has lost this vitally important document is
annexed hereto and marked Exhibit G.

19. Subsequently, the attorney for Guide Dogs for the Blind, Alicia A.
Adornato, has admitted in open court that James R. Hastings has had
the document all along. Now they claim that they are not required to
produce this document under a statue of limitations. This is an
entirely bogus claim and has already been dismissed by the Marin
County Probate Judge.

20. Rather than produce the original document, they have produced a
2008 dated FAX that purports to depict the original. However, FAX
documents are not admissible in court for good reason. A FAX is
created by horizontal black lines across a page. The FAX machine
sprinkles black dots and distorts the image. A Fax document does not
show the kind of paper used, the kind of pen or writing instrument
used, or the kind of ink used. It can also conceal missing or changed
pages. It also distorts the size and shape of the signature. In short,
a FAX is ideal for concealing a forgery.

21. Defendants have submitted a dozen known and authentic
original signatures of Col. Kenneth F. Goodall including the known
original signature on the power of attorney dated August 24, 1994
along with a copy of the FAX submitted by Bank of America bearing the
same date to a Forensic Document Examiner, David S. Moore, who has
previously worked with the FBI. This Forensic Document Examiner
immediately noticed a number of significant differences between the
all the known signatures of Col. Goodall and the purported signature
on the FAX, especially in the creation of the FG in the signature of
Kenneth F. Goodall. The key point according to the forensic document
examiner is that in the known signatures of Kenneth Goodall he signs
the FG with one stroke of the pen. However, in the trust document, the
top of the F is a different stroke right to left. A blowup of these
two signatures is annexed as Exhibits H and I.

22. A close look at where the different strokes meet shows that they
are not together. The questions about the signatures can be better
understood using a blowup of the two signatures. Here using Adobe
Photoshop blowing up the key letters F and G in the signature of
Kenneth F. Goodall, look especially at the letters F and G in the
known signature of Kenneth F. Goodall. This is the first thing the
forensic document examiner David S. Moore noticed. The signature on
the F followed by the G is made in one continuous non-stopping
movement. First the top of the F is formed and then the pen loops
around to make the G. The pen never leaves the paper.

23. In the purported trust document, the movement of the hand is
shaky. The bottom of the F and then the G is formed and then the pen
leaves the paper and comes back to make the top of the F as a straight
line from right to left. There is also a break in the bottom of the F
and a difference in the loops in the bottom of the Gs.

24. In the various documents and records signed over a period of years
that we have, Kenneth F. Goodall signed his name as in the top
signature every time. He never signed his name in the shaky halting
way he supposedly signed the bottom signature here. Several additional
differences between the top and bottom signatures are plainly obvious.
You do not have to be a forensic document examiner or any kind of
expert to see them. It also appears that the documents were signed
with a different pen, which is odd since they were both supposedly
signed at the same time on the same date and place. After examining
these documents to the extent that they are available, the Forensic
Document examiner David S. Moore has concluded that he cannot
determine if the signatures on the 1994 Trust are legitimate or a
forgery without seeing the original actual documents. Bank of America
and their attorney James R. Hastings nevertheless has refused to allow
the Defendants here or the Forensic Document Examiner to see the
original. The Declaration by the Forensic Document Examiner stating
this is annexed hereto as Exhibit J.

25. The notary signatures and seals on the purported 1994 Trust
document are improper and invalid. It is a legal requirement that
Trust documents of this sort must be notarized by a notary public.
Here the notary public was James R. Hastings, who was also according
to his own declaration the attorney for Michael Goodall, Col. Kenneth
Goodall, the Goodall Trust and Bank of America all at the same time,
in an obvious conflict of interest. In addition, we know that Kenneth
F. Goodall was not at his home on that date of August 24, 1994. He was
hospitalized recovering from an operation for esophageal cancer on
that date. In order to sign these documents, his wife Rachel must have
brought them to the hospital. It was utterly impossible for Kenneth F.
Goodall to have gone to the office of James Hastings to sign them on
that date as Mr. Hastings claims he did.

26. The notary signatures of James R. Hastings are improper.
Defendant Samuel H. Sloan has passed the notary public test in
Sacramento and knows that under California notary public law if a
Loose Acknowledge is used to complete a notarization it must be
stapled to the back of the signature page of the document.*It must be
stapled in the left upper most corner.*The words “see attached
certificate” or “see attached Notary certificate” should be placed on
the signature page.*Loose notarial certificates are generally used
because there is no notary language on the document or the language is
not based on the then current law OR the language is there but there
is not enough room to place your Notary seal.*In the case of incorrect
notarial language you use one line to strike out the unapproved
notarial language.

27. The law on thumbprints is that you MUST obtain a right
thumbprint in your Notary journal for all Deeds (quitclaim deed, grant
deed, warranty deed, deed of trust, security agreement, mortgages
etc.) and on all Power of Attorney documents.*The exceptions for the
deeds are Foreclosure Deeds and Reconveyance Deeds.

28. As will be seen when and if the Bank of America ever
produces the document, the words “see attached certificate” or “see
attached Notary certificate” do not appear on the signature page and
the acknowledgments page does not refer back to the signature page
either.*In addition, the Notary Journal maintained by James R.
Hastings does not have any thumbprints of Kenneth F. or Rachel A.
Goodall and it does not show what photo ID Kenneth and Rachel
provided. “Personal knowledge” is not allowed for notary signatures in
California. There have been no changes in the notary public law
between 1994 and the present on these points.

29. Bank of America claims that Mike Goodall did not contest the
trust within 120 days of the death of his mother and thus is barred by
statute of limitations. This claim is utterly false and without basis.
There is no such statute of limitations. In 1994, Mike Goodall was
living in his apartment at 2420 Atherton Street in Berkeley CA.
Defendant Samuel H. Sloan was living there too in that same apartment
and thus is familiar with these events. Mike Goodall would probably
not have known what his parents did or did not sign in San Rafael and
on what dates. Bank of America has produced no evidence that Mike
Goodall ever received or saw the 1994 purported trust during the
relevant time period. Their documents only show that Mike knew about
the 1990 Trust of which he was the sole beneficiary and thus unlikely
to challenge it. The claim by Bank of America that Mike Goodall did
not challenge the trust within the 120 day purported time period is
not true either. When that case was filed in 1999, Bank of America
contended that Mike Goodall was challenging the trust. That issue was
never decided. In three different documents dated in 2000, Bank of
America stated that his petition WAS a challenge to the trust.

30. Almost every time this case has to court, Gary Rothstein,
attorney for Bank of America, has lied to the court. This time, on
July 19, 2012, he said that the 1999 case was “for declaratory
relief”. That was not true. The 1999 case was to remove Bank of
America as Trustee. Here as Exhibits K, L and M are three documents by
Bank of America and its attorney stating that this action is to
contest the trust.

31. Exhibit K is a Declaration by Susan D. Scribner for Bank of
America as Trustee in Opposition to petition Re Determination of the
Particular Action does not constitute a contest dated February 2,
2000. In the last sentence of this declaration she “asks the court to
confirm that such action is a contest to the trust”.

32. Exhibit L is Points and Authorities by James R. Hastings,
Attorney for Bank of America, in Opposition to petition Re
Determination of the Particular Action does not constitute a contest
dated February 2, 2000.

33. Exhibit M is Proof of Service of Points and Authorities in
Opposition to petition Re Determination of the Particular Action does
not constitute a contest and Declaration by Susan D. Scribner for Bank
of America as Trustee in Opposition to petition Re Determination of
the Particular Action does not constitute a contest.

34. Each of these documents states that Mike Goodall was
contesting the trust and, in view of the no contest clause, Mike
Goodall should be dis-inherited and left with nothing. This case was
still pending before the courts in 2010 when Mike Goodall died and
thus was never finally decided. In an improper action, Bank of America
bootstrapped themselves into the San Francisco Court after they had
lost the case over here in Marin County by filing a pleading under
Case Number: PTR-99-273030 Title: IN THE GOODALL TRUST for an
entirely different cause of action.

35. Bank of America has reversed positions on this case. Now
that Mike Goodall is dead they are making the opposite claims from the
claims they made while he was alive. None of these documents were
disclosed by Bank of America and their attorneys to the San Francisco
judge.

36. In a hearing before Retired Judge John Dearman when the
regular San Francisco Probate Judges were not willing to hear this
case, Bank of America demanded that Defendants be evicted from the
house located at 461 Peachstone Terrace in San Rafael. Defendant
Samuel H. Sloan objected on the ground that the San Francisco Probate
Court lacks jurisdiction over real property located in Marin County.
Judge Dearman decided that Defendant Samuel H. Sloan pay rent to be
deposited in a neutral bank account such that whomever wins this case
would get the money. The parties subsequently agreed to a rent amount
of $1650 in spite of the dilapidated condition of the house. However,
Bank of America has since insisted that the rent checks be made
payable to “Bank of America as Trustee of the Trust for Michael”.
Since Defendants contend that the Trust for Michael does not exist and
also that Bank of America was never the lawful trustee of that or any
other trust, Samuel H. Sloan made checks payable to “Trustee of the
Goodall Trust” even though the Goodall Trust no longer exists.
However, Bank of America refused and returned these checks. Another
judge then told them to take the checks. Bank of America then took the
checks but did not timely deposit them. However, they did deposit the
check for the July Rent on August 1, 2012. They are holding the other
checks.

37. Defendant Samuel H. Sloan stands ready to give more checks but
demands to know what Bank of America is doing with those checks as the
order of Judge Dearman was to put them into a neutral bank account.
The endorsement on the one check that has cleared the bank does not
reveal what has happened to the money or if the court order is being
complied with. A copy of that check is annexed hereto as Exhibit N.
Defendant Sloan stands ready to pay more checks provided it is
established what Bank of America is doing with the money in compliance
with the decision of Judge Dearman.

38. The other defendants, Frank Thornally and Roy Hoppe, were “special
friends” of the deceased Mike Goodall and were not paying rent at the
time of his death. They should be allowed to continue to live in the
house on the same basis. However, Roy Hoppe was threatened with arrest
by James R. Hastings back in January 2011 unless he moved out. Fearful
of being arrested, Hoppe moved out and has resided in a homeless
shelter at the Former Hamilton Air Force Base awaiting the outcome of
this case but comes to the house daily to pick up his mail.

39. According to pleadings in the 1999 case and to documents left in
the house, at the time of the death of Rachel A. Goodall on June 7,
1999 she had between $900,000 and one million dollars in cash and
securities including mutual funds and the like. The Goodall Trust had
no money as the only asset of the trust was the house. However, James
R. Hastings, pretending to be the attorney for both the Goodalls and
Bank of America and having acquired knowledge of where all the Goodall
assets were as a result of being their estate planner, contacted all
the bank and brokerage companies holding Goodall assets and had them
transfer the funds to Bank of America. Prior to that time, the
Goodalls had no banking relationship with Bank of America at all, not
even a simple checking account.

40. Since then, Bank of America and James R. Hastings have completely
stonewalled. They refused to reveal anything about how much money they
have, where they got it from or what they have done with it.

41. The Defendants believe that the total value of the Estate of K.
Michael Goodall to be in the estimated amount of $2.5 million.
However, with Bank of America and James R. Hastings charging
administration, trustee and legal fees for the past 13 years since
1999 it is likely that these funds are substantially depleted.
Defendant Samuel H. Sloan, as administrator of the Estate of K.
Michael Goodall, is demanding that the entire amount of $2.5 million
be reinstated to the trust plus interest since 1999. This explains why
Bank of America and their allies in this case have nine attorneys
working on their side of this case. They have probably already spent
the money.

42. Plaintiff Bank of America through its attorney Gary Rothstein has
repeatedly threatened Defendant Samuel H. Sloan with personal
sanctions and his attorney with sanctions plus disciplinary proceeding
before the bar for defending the rights and claims of the Estate of K.
Michael Goodall of which Samuel H. Sloan is the administrator with
will annexed. This has caused defendant and his counsel to become more
cautious and milk-toast and less assertive than they could and should
be considering the circumstances of this case.

43. Because of the outrageous and indeed fraudulent conduct by the
plaintiffs and their attorneys in this case, defendant Samuel H. Sloan
has taken several actions. Defendant has filed a complaint against
James R. Hastings with the Secretary of State of the State of
California, Notary Public Licensing Division. A copy of the receipt
acknowledgment to this complaint is annexed hereto and marked exhibit
O.

44. Defendant Samuel H. Sloan has filed a complaint with the Internal
Revenue Service (of which his father is a retired career employee)
against Guide Dogs for the Blind for running a bogus charity
pretending to benefit the poor blind people whereas it is actually a
scam operation run for the benefit of the directors who pay themselves
over a million dollars a year. Defendant is seeking to have the tax
exempt status as a 501c3 revoked and is seeking to be paid a bounty of
as much as 10% for being a whistle-blower exposing this $300 million
tax fraud by Guide Dogs for the Blind. Samuel H. Sloan charges Guide
Dogs for the Blind with running a “scam operation” benefiting few if
any blind people but rather providing “service dogs” to perfectly
healthy people with full vision who want to take their pets into
restaurants, buses and BART and with using tactics to coerce wealthy
elderly people to leave their houses to Guide Dogs for the Blind
rather than to their children. He alleges that through these schemes
Guide Dogs for the Blind has become one of the richest charities in
the USA and the biggest property owner in Marin County, owning more
than one hundred houses and a campus with more than 40 buildings and
39 vans, all tax free under 501(c)(3). They are successful in their
scams because all of the people who know the truth of these matters
are dead. According to the petitions, Guide Dogs for the Blind has
accumulated more than $300 million in net assets and the directors pay
themselves more than $1 million annually in salaries. A copy of the
receipt acknowledgment from the Internal Revenue Service is attached
hereto and marked Exhibit P.

45. Defendant Samuel H. Sloan is in the process of filing complaints
with the California state Bar against attorneys James R. Hastings,
Gary Rothstein, Donald Lesser and Alicia A. Adornato for their
obvious misconduct in these cases and is seeking to have these four
lawyers disbarred from the practice of law for their obvious
misconduct in this case and also because they have threatened to file
disciplinary proceedings against Defendant's attorney who has done
nothing more than represent the defendant. Defendant Samuel H. Sloan
will also be seeking the arrest and criminal prosecution of Estate
Planning Attorney James R. Hastings for forgery of the purported 1994
Trust that put Hastings in control of the $2.5 million in the estate
and will seek the arrest and criminal prosecution of “Planned Giving
Director” Thomas Horton who has been involved in this case since 1999
for bilking elderly people of their life savings on the pretext of
helping the blind people. Defendant is seeking to close down and put
out of business Guide Dogs for the Blind so they will not be
successful in stealing the Goodall property and so that the more than
$300 million they have accumulated through their scams will be used by
President Romney and Vice-President Ryan to pay off the National Debt.

WHEREFORE, for all of the reasons set forth above, this Unlawful
Detainer Proceeding must be dismissed.

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: November 21, 2012




Samuel H. Sloan



Verification:

Samuel H. Sloan declares:
I have read the Answer to the Complaint in the Unlawful Detainer
Proceeding Opposition 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: November 21, 2012




Samuel H. Sloan

Here's the link to this file:
http://www.yousendit.com/download/WU...b0JEa1hIRHRVag
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Old November 28th 12, 04:12 PM posted to rec.games.chess.politics,misc.legal,rec.games.chess.misc,alt.lawyers,soc.culture.usa
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Posts: 134
Default Goodall Case: Answer to Motion for Summary Judgment in MarinCounty Superior Court

On Nov 27, 1:30*pm, samsloan wrote:


33. Exhibit M is Proof of Service of Points and Authorities in
Opposition to petition Re Determination of the Particular Action does
not constitute a contest and Declaration by Susan D. Scribner for Bank
of America as Trustee in Opposition to petition Re Determination of
the Particular Action does not constitute a contest.


Good one.

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The End Draws Near Mr.Vidmar[_2_] rec.games.chess.politics (Chess Politics) 0 March 25th 09 01:10 AM


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