Ruby Jean Stevens - Page 6




                                        - 6 -                                         

               First Claim for Relief--Cancellation, Revocation and                   
          Recision of the Trust;                                                      
               Second Claim for Relief--Conversion/Fraud;                             
               Third Claim for Relief--Tortious Interference with                     
          Expectancy;                                                                 
               Fourth Claim for Relief--Constructive Trust; and                       
               Fifth Claim for Relief--Punitive Damages.                              
               Each of the claims for relief contained or incorporated                
          allegations (1) that Mr. Stevens "was mentally incompetent and/or           
          did not possess sufficient mental comprehension to understand his           
          actions in signing the Trust documents"; (2) petitioner and Sedra           
          "caused, induced, deluded, misled, forced, and/or unduly                    
          influenced [Mr. Stevens] into signing" the Trust documents; and             
          (3) the Trust documents "are invalid testamentary documents and             
          void as a matter of law".  None of the claims for relief in the             
          lawsuit contained any allegation that petitioner improperly                 
          distributed Trust income, failed to carry out a provision of the            
          Trust Agreement, failed to render an accounting to Trust                    
          beneficiaries, or otherwise failed to administer the Trust                  
          properly.                                                                   
               Petitioner was advised by her attorneys that it was her                
          duty, as Trustee, to defend against the lawsuit and to take a               
          position in support of the validity of the Trust Agreement.                 







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Last modified: May 25, 2011