Rodman-Trust

withdrawal is further conditioned upon compliance with Orange County Local Rule 601.21.

Counsel has fully complied with California Rules of Court, rule 3.1362 and does not represent a fiduciary.

On 1/27/26, Susan K. Worthy filed an Objection to this motion. While Ms. Worthy appears to have many grievances with regard to Mr. Shepard's representation of her, such grievances only further support the need to end the attorney-client relationship. Moreover, Ms. Worthy's objections appear to be primarily against the statements made in the moving papers. She does not appear to object to Mr. Shepard being relieved as counsel.

Ms. Worthy further requests that the court order Mr. Shepard to turn over the client file to her in paper format, as opposed to the flash drive she has already received. Pursuant to California Rules of Professional Conduct, rule 1.16(d), Mr. Shepard must return the client file to the client in the format in which it exists. To the extent the client file was maintained in paper format, the physical papers should be handed over to the client. To the extent the client file was maintained electronically, the flash drive is sufficient. Mr. Shepard is not required to print any electronic documents at his own expense for the client's convenience.

Based on the foregoing, the court finds good cause to GRANT the motion to be relieved.

Withdrawal is effective upon filing the proof of service of the signed Order Granting Attorney’s Motion to Be Relieved as Counsel. .

3 Rodman-Trust MOTION TO COMPEL FURTHER RESPONSES TO 30-2025-01499532 REQUESTS FOR PRODUCTION OF DOCUMENTS (ROA 51)

Petitioner Kevin Craige Kruse moves for an order compelling Respondent Kara Kruse Lee to provide further responses to Requests for Production of Documents, Set One, demand nos. 5, 6, and 17.

Respondent has filed a declaration demonstrating that supplemental responses were served on 8/20/26. (ROA 122.) The supplemental responses appear to comply with the Code, rendering the motion to compel moot.

Pursuant to California Rules of Court, rule 3.1348(a), the subsequent service of sufficient discovery responses does not render Petitioner's request for monetary sanctions moot.

The court notes that the instant motion is largely duplicative of the motion heard on 8/19/26 (ROA 39). Thus, the court reduces the award of sanctions requested to $1,272.00 ($424 p/h x 3 hours).

The motion to compel is DENIED as moot.

The request for sanctions is GRANTED. The court imposes reasonable sanctions of $1,272.00 jointly and severally against Respondent and her counsel of record, Jeany Duff, payable to Hamilton & Associations, APC within 30 days of notice of this ruling, extended for method of service, or any later date as agreed upon by the parties in writing.

Counsel for moving party is ordered to serve notice of ruling.

4 Conrecode-Trust DEMURRER (ROA 15) 30-2025-01503820 More than one individual involved in this case share a surname. For clarity, the court is using first names without intending any disrespect. (Morgan v. Superior Court (2018) 23 Cal. App. 5th 1026. fn.1)

Trustee Emmett S. Conrecode (the "Trustee") demurrers to the "Petition Concerning the Internal Affairs of a Trust" (ROA 2) filed by Petitioner Virginia Estate & Trust Law, as successor trustee of the Edward J. Conrecode Revocable Trust, ("Petitioner") in its entirety for lack of standing.

The demurrer is OVERRULED.

The Petition alleges the following pertinent facts:

- Edward J. Conrecode, Sr. ("Edward, Sr.") was the trustor of the Edward J. Conrecode Trust dated 4/10/89 and amended 6/28/90 (the "Subject Trust");

- The Subject Trust owned real property located in Costa Mesa, California (the "Property");

- The Subject Trust provides that upon Edward, Sr.'s death, the assets of the Subject Trust shall be equally distributed to the Trustee, Edward J. Conrecode, Jr. ("Edward, Jr."), and James M. Conrecode ("James").

- The Subject Trust provides that "if all of the Trustor's children and their issue should die prior to the final distribution of the Trust Estate, all the Trust Estate not disposed of" shall be distributed by intestate succession;