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VERIFIED PETITION FOR ORDER OF CONVEYANCE
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MICHAEL A. HACKARD (SBN 71067)
HACKARD LAW, A PLC
10630 Mather Boulevard
Mather, CA 95655
Tel.: (916) 313-3030
Fax: (916) 226-5177
Attorneys for Waldo Crabtree
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SACRAMENTO
PROBATE DIVISION
In the matter of:
THE JUNIPER JACKSON TRUST
AGREEMENT OF 2015
----------------------------------------------------------
WALDO CRABTREE,
Petitioner.
Case No.:
VERIFIED PETITION FOR ORDER OF
CONVEYANCE
[Probate Code §§ 850(a)(3)(B), 856]
Petition Filed:
Hearing Date:
Assigned:
Dept:
Time:
Waldo Crabtree ("Petitioner"), as Trustee of the Juniper Jackson Trust Agreement of
2015, presents this Petition for an Order of Conveyance pursuant to Probate Code sections
850(a)(3)(B) and 856.
PURPOSE
This matter involves confirming title of certain real property that comprises a 50 acre
ranch in the City of Maybury, County of Sacramento ("Maybury Ranch"), APN 987-654-
321-000, and more particularly described in the legal description attached as EXHIBIT A.
There are no adverse claims to Maybury Ranch; Petitioner only asks this Court to ratify the
title chain so Petitioner may secure title insurance.
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VERIFIED PETITION FOR ORDER OF CONVEYANCE
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JURISDICTION AND VENUE
1. Probate Code section 17002 (a) defines the principal place of administration of the
trust as the usual place where the day-to-day activity of the trust is carried on by
the trustee or representative primarily responsible for the administration of the
trust.
a. The Trustee resides in Los Angeles County, but the property in question is
located in Sacramento County. The Trustee has hired legal representation
based in Northern California in order to efficiently use Trust resources.
2. The Petitioner, as Trustee, consents to Sacramento County as the proper venue for
this action.
FACTUAL BACKGROUND
3. On October 11, 2015, Juniper Jackson ("Decedent") executed the Juniper
Jackson Trust Agreement of 2015 (“Trust”). A true and correct copy of the Trust
is attached hereto as EXHIBIT B and incorporated by this reference.
4. Per Article J of Exhibit B, Decedent named Waldo Crabtree Successor Trustee.
5. Per Number 10 of the “Schedule of Properties Being Transferred Pursuant to the
Juniper Jackson Trust Agreement of 2015” (Exhibit B), Maybury Ranch was to
be transferred into the Trust.
6. Decedent did not execute any deed transferring Maybury Ranch into the Trust.
7. Decedent passed away on February 29, 2016. A copy of the Death Certificate is
attached hereto as EXHIBIT C.
8. Upon Decedent's passing, Petitioner became Trustee of the Trust.
9. Per Article 5, section 19.80(f) of Exhibit B, the trust estate is to be distributed
free of trust to Waldo Crabtree.
10. On March 15, 2016, Petitioner executed a Grant Deed transferring Maybury
Ranch from the Trust to Petitioner as an individual. A true and correct copy of
the March 15, 2016 Grant Deed is attached hereto as EXHIBIT D and
incorporated by this reference.
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VERIFIED PETITION FOR ORDER OF CONVEYANCE
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11. On April 15, 2016, Petitioner executed a Grant Deed transferring Maybury
Ranch from him an individual to the Waldo Crabtree Living Trust ("WC Living
Trust"). A true and correct copy of the April 15, 2016 Grant Deed is attached
hereto as EXHIBIT E and incorporated by this reference. A true and correct
copy of the WC Living Trust is attached hereto as EXHIBIT F and incorporated
by this reference.
PROBATE CODE SECTIONS 850(a)(3)(B) and 856
12. Probate Code section 850(a)(3)(B) permits a Trustee, who has a claim to real or
personal property in which title is held by another, to file a petition with the
Court.
13. Probate Code section 856 grants the Court the power to issue an order
authorizing and directing the person having title or possession of the property to
execute a conveyance or transfer to the person entitled thereto.
14. When Decedent passed away, title was held in her name as an individual.
15. Petitioner, as Trustee of the Trust and the WC Living Trust, has a claim to real
property.
NOTICE
1. The names and last known addresses of the beneficiaries of the Trust and the WC
Living Trust, as well as all other persons who may be entitled to notice under
Probate Code section 17203 are:
a. Wally Brown, 123 FEIGNED STREET, LOS ANGELES, CA
b. Billie Jackson, 321 COUNTERFEIT COURT, LOS ANGELES, CA
c. George Crabtree, 1423 FAUX ROAD, SACRAMENTO, CA
d. Darla DuPont, 3142 PHONY PLACE, SACRAMENTO, CA
PRAYER FOR RELIEF
WHEREFORE, Petitioner prays for:
1. An order ratifying the March 15, 2016, conveyance of the of the real property in
Sacramento County (APN 987-654-321-000), the legal description of which is attached
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VERIFIED PETITION FOR ORDER OF CONVEYANCE
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hereto as EXHIBIT A, from the Juniper Jackson Trust Agreement of 2015 to Waldo
Crabtree as an individual;
2. An order ratifying the April 15, 2016, conveyance of the of the real property in
Sacramento County (APN 987-654-321-000), the legal description of which is attached
hereto as EXHIBIT A, from Waldo Crabtree as an individual to the Waldo Crabtree
Living Trust;
3. An order confirming Waldo Crabtree, Trustee of the Waldo Crabtree Living Trust, as
sole owner of the real property in Sacramento County (APN 987-654-321-000), the legal
description of which is attached hereto as EXHIBIT A; and
4. Any other such relief as this Court deems proper.
DATED: ______________________ Hackard Law, a PLC
By: ____________________
MICHAEL A. HACKARD
Attorney for Petitioner Waldo Crabtree
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VERIFIED PETITION FOR ORDER OF CONVEYANCE
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OUT OF COUNTY VERIFICATION
I am one of the attorneys for Waldo Crabtree, Petitioner in this matter. Such party is
absent from the county of aforesaid where such attorneys have their office and where this action is
pending. I make this verification for and on behalf of that party for that reason, pursuant to California
Probate Code§ 1023. I am informed and believe and on that ground allege that the matters stated in
the foregoing document are true.
I declare under the penalties and pain of Perjury under the laws of the State of
California that the foregoing is true and correct, and that this Verification was signed by me on the
date so indicated herein at Mather, California.
Dated:_____________________
___________________________
MICHAEL A. HACKARD

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California Heggstad 850 Probate Petition Sacramento

  • 1. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 VERIFIED PETITION FOR ORDER OF CONVEYANCE 1 MICHAEL A. HACKARD (SBN 71067) HACKARD LAW, A PLC 10630 Mather Boulevard Mather, CA 95655 Tel.: (916) 313-3030 Fax: (916) 226-5177 Attorneys for Waldo Crabtree IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SACRAMENTO PROBATE DIVISION In the matter of: THE JUNIPER JACKSON TRUST AGREEMENT OF 2015 ---------------------------------------------------------- WALDO CRABTREE, Petitioner. Case No.: VERIFIED PETITION FOR ORDER OF CONVEYANCE [Probate Code §§ 850(a)(3)(B), 856] Petition Filed: Hearing Date: Assigned: Dept: Time: Waldo Crabtree ("Petitioner"), as Trustee of the Juniper Jackson Trust Agreement of 2015, presents this Petition for an Order of Conveyance pursuant to Probate Code sections 850(a)(3)(B) and 856. PURPOSE This matter involves confirming title of certain real property that comprises a 50 acre ranch in the City of Maybury, County of Sacramento ("Maybury Ranch"), APN 987-654- 321-000, and more particularly described in the legal description attached as EXHIBIT A. There are no adverse claims to Maybury Ranch; Petitioner only asks this Court to ratify the title chain so Petitioner may secure title insurance.
  • 2. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 VERIFIED PETITION FOR ORDER OF CONVEYANCE 2 JURISDICTION AND VENUE 1. Probate Code section 17002 (a) defines the principal place of administration of the trust as the usual place where the day-to-day activity of the trust is carried on by the trustee or representative primarily responsible for the administration of the trust. a. The Trustee resides in Los Angeles County, but the property in question is located in Sacramento County. The Trustee has hired legal representation based in Northern California in order to efficiently use Trust resources. 2. The Petitioner, as Trustee, consents to Sacramento County as the proper venue for this action. FACTUAL BACKGROUND 3. On October 11, 2015, Juniper Jackson ("Decedent") executed the Juniper Jackson Trust Agreement of 2015 (“Trust”). A true and correct copy of the Trust is attached hereto as EXHIBIT B and incorporated by this reference. 4. Per Article J of Exhibit B, Decedent named Waldo Crabtree Successor Trustee. 5. Per Number 10 of the “Schedule of Properties Being Transferred Pursuant to the Juniper Jackson Trust Agreement of 2015” (Exhibit B), Maybury Ranch was to be transferred into the Trust. 6. Decedent did not execute any deed transferring Maybury Ranch into the Trust. 7. Decedent passed away on February 29, 2016. A copy of the Death Certificate is attached hereto as EXHIBIT C. 8. Upon Decedent's passing, Petitioner became Trustee of the Trust. 9. Per Article 5, section 19.80(f) of Exhibit B, the trust estate is to be distributed free of trust to Waldo Crabtree. 10. On March 15, 2016, Petitioner executed a Grant Deed transferring Maybury Ranch from the Trust to Petitioner as an individual. A true and correct copy of the March 15, 2016 Grant Deed is attached hereto as EXHIBIT D and incorporated by this reference.
  • 3. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 VERIFIED PETITION FOR ORDER OF CONVEYANCE 3 11. On April 15, 2016, Petitioner executed a Grant Deed transferring Maybury Ranch from him an individual to the Waldo Crabtree Living Trust ("WC Living Trust"). A true and correct copy of the April 15, 2016 Grant Deed is attached hereto as EXHIBIT E and incorporated by this reference. A true and correct copy of the WC Living Trust is attached hereto as EXHIBIT F and incorporated by this reference. PROBATE CODE SECTIONS 850(a)(3)(B) and 856 12. Probate Code section 850(a)(3)(B) permits a Trustee, who has a claim to real or personal property in which title is held by another, to file a petition with the Court. 13. Probate Code section 856 grants the Court the power to issue an order authorizing and directing the person having title or possession of the property to execute a conveyance or transfer to the person entitled thereto. 14. When Decedent passed away, title was held in her name as an individual. 15. Petitioner, as Trustee of the Trust and the WC Living Trust, has a claim to real property. NOTICE 1. The names and last known addresses of the beneficiaries of the Trust and the WC Living Trust, as well as all other persons who may be entitled to notice under Probate Code section 17203 are: a. Wally Brown, 123 FEIGNED STREET, LOS ANGELES, CA b. Billie Jackson, 321 COUNTERFEIT COURT, LOS ANGELES, CA c. George Crabtree, 1423 FAUX ROAD, SACRAMENTO, CA d. Darla DuPont, 3142 PHONY PLACE, SACRAMENTO, CA PRAYER FOR RELIEF WHEREFORE, Petitioner prays for: 1. An order ratifying the March 15, 2016, conveyance of the of the real property in Sacramento County (APN 987-654-321-000), the legal description of which is attached
  • 4. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 VERIFIED PETITION FOR ORDER OF CONVEYANCE 4 hereto as EXHIBIT A, from the Juniper Jackson Trust Agreement of 2015 to Waldo Crabtree as an individual; 2. An order ratifying the April 15, 2016, conveyance of the of the real property in Sacramento County (APN 987-654-321-000), the legal description of which is attached hereto as EXHIBIT A, from Waldo Crabtree as an individual to the Waldo Crabtree Living Trust; 3. An order confirming Waldo Crabtree, Trustee of the Waldo Crabtree Living Trust, as sole owner of the real property in Sacramento County (APN 987-654-321-000), the legal description of which is attached hereto as EXHIBIT A; and 4. Any other such relief as this Court deems proper. DATED: ______________________ Hackard Law, a PLC By: ____________________ MICHAEL A. HACKARD Attorney for Petitioner Waldo Crabtree
  • 5. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 VERIFIED PETITION FOR ORDER OF CONVEYANCE 5 OUT OF COUNTY VERIFICATION I am one of the attorneys for Waldo Crabtree, Petitioner in this matter. Such party is absent from the county of aforesaid where such attorneys have their office and where this action is pending. I make this verification for and on behalf of that party for that reason, pursuant to California Probate Code§ 1023. I am informed and believe and on that ground allege that the matters stated in the foregoing document are true. I declare under the penalties and pain of Perjury under the laws of the State of California that the foregoing is true and correct, and that this Verification was signed by me on the date so indicated herein at Mather, California. Dated:_____________________ ___________________________ MICHAEL A. HACKARD