20 a 2 23 24 FILED 16 FEB 29 PM250, Ex Parte Depart Noted for March 23, 2044690 Yn. EBIOR COURT CL Wi Ore PelnsnH ‘CASE NUMBER: 16-4-01332} IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING In Re the Estate of: NO. VERIFIED PETITION TO REMOVE, PERSONAL REPRESENTATIVE & TRUSTEE AND TO APPOINTING SUCCESSOR LEE CHARLES RABIE, Deceased. JODIE L. RABIE, Petitioner, v. ELIZABETH CAMPBELL, Respondent. | I. INTRODUCTION AND RELIEF REQUESTED Petitioner, Jodie L. Rabie hereby moves the Court for an Order to remove Elizabeth Campbell as Personal Representative of the Estate of Lee Charles Rabie (“Estate”) and as Trustee of the Lee C, Rabie Revocable Living Trust (“Trust”). Ms. Campbell and Petitioner have had a very tumultuous relationship that pre-dates Lee Charles Rabic’s death, Prior to Mr. Rabie’s death, Ms. Campbell insinuated herself into his life, appointing herself as his attorney in fact pursuant to Durable Power of Attomey dated 3/14/15 (“DPOA”), had Mr. Rabie transfer to her substantial assets (in violation of the DPOA), and took over the management of] PETITION FOR REMOVAL OF PERSONAL B REPRESENTATIVE - Page 1 INSLEE BEST esos Senor oe MDA tlt hm ¥ K 2 SEA10 i 19 20 2 22 23 24 Mr. Rabie’s real property assets. Petitioner removed Ms. Campbell from her position as manager of the real property because of Ms, Camphell’s poor management. Among other things, and as discussed in more detail below, Ms. Campbell withheld taxes from employee paychecks, but apparently failed to submit the withheld amounts to the IRS. The IRS is now very concerned about that issue and will likely seek to hold Mr. Rabie’s Estate at least partially liable for Ms. Campbell’s violations. Petitioner took over as attorney-in-fact for her father in October 2014, after one of Mr. Rabie’s caregivers called Adult Protective Services (“APS”) on Ms. Campbell. Prior to Mr. Rabie’s death, Petitioner used the Durable Power of Attorney she held for her father to replace Ms. Campbell with Wells Fargo, N.A. as manager of Mr. Rabie’s assets. Wells Fargo, N.A. managed the assets for approximately four months before Mr. Rabie died. Petitioner would like Wells Fargo, N.A. to continue managing the assets, instead of Ms. Campbell, as Personal Representative and Trustee. TL PERTINENT FACTS: AL Ms. Campbell’s Self-Dealing On March 24, 2014, nine days after Mr. Rabie named Ms. Campbell as his attorney-in- fact, she had the elderly Mr. Rabie (he was 82 years old in 2014) transfer two pieces of property to her via Quit Claim Deeds for $10 (tax parcel numbers 311080-0040 and 119600- 2100). Declaration of Anneliese Johnson, Exhibit A. Mr. Rabie had owned both of these pieces of property solely in his own name. Id He transferred title to himself and Ms. Campbell on tax parcel number 311080-0040; and entirely and solely to Ms. Campbell on the other (tax parcel number 119600-2100, with a tax assessed value of $264,000). Id. Four months later, they sold the 311080-0040 property to third parties (the Millers) for $269,900. PETITION FOR REMOVAL OF PERSONAL B REPRESENTATIVE - Page 2 eiheesteteler 4810381 [364601 0002 Mia Sakeatinn did soo in ret Sue 60012 13 14 15 16 7 20 2 22 23 4 Id. The proceeds were split 50/50 between Mr. Rabie and Ms. Campbell. Id, Exhibit B. ‘Thus, Respondent self-dealt for the net on 50% of $269,900 (~$134,950) on the 31080-0040 property, and $264,000 on the 119600-2100 property for a total of approximately between $350,000-$400,000. id, Exs. A & B. B. The Personal Representative Intentionally Failed to Provide Notice of the Hearing to Appoint Her On February 5, 2016, this Court admitted the Last Will and Testament of Lee Charles Rabie to probate and appointed Elizabeth Campbell as the Decedent’s Personal Representative. Docket. No. 1, 3. Petitions for Appointment of Special Administrator had previously been filed by Petitioner. King County Cause Nos. 16-4-00662-8 SEA and 16-4-00803-5 SEA; Johnson Deel., 417 and Ex. C. Respondent provided no notice of her filing of the Decedent’s Will nor did she provide advanced notice of her effort to be appointed Personal Representative, despite Petitioner making her objection to Respondent’s appointment well known C. ‘The Personal Representative’s Relationship With the Primary Beneficiary Petitioner, Jodie L. Rabie, who is one of Mr. Rabie’s three daughters, is designated in the Will to receive a 98% interest in the Estate. Attached to the Declaration of Jodie Rabie (“Rabie Decl.”) as Exhibit A is the Last Will and Testament of Lee Charles Rabie. Petitioner is also designated in the Trust to receive a 100% interest. Attached as Exhibit B to Ms. Rabie’s declaration is the Trust. ‘The Personal Representative (“PR”) has made clear her contempt for Petitioner. Collectively attached as Exhibit C to the Declaration of Jodie Rabie are text messages sent to a third party (Richard Walther) from Ms. Campbell detailing her contempt for Petitioner, PETITION FOR REMOVAL OF PERSONAL a REPRESENTATIVE - Page 3 INSLEE, B 481038, | 364601 | 0002, A Ee 10000 we a Sut 0920 21 22 23 24 including Respondent's statement that Petitioner should be "damned to hell" for questioning her judgment and recommended expenditures of the Decedent's funds, id at p. 2. Mr. ‘Walther also submitted a declaration for Ms. Campbell to use as needed. Rabie Decl., Ex. D, Since the declaration of Mr. Walther was shared with Ms, Campbell’s prior counsel, Ms. Campbell has sued Mr. Walther for defamation in an attempt to harass and intimidate the witness from helping Ms. Rabie remove Ms. Campbell from her fiduciary roles over her father’s assets. Attached to the Declaration of Michael Moceri is a copy of the defamation complaint Ms. Campbell filed against Mr. and Mrs. Walther. D. Ms. Rabie Does Not Know How to Manage Assets and Should Not be PR This is a large estate, estimated to be worth over $2 Million. Declaration of Jodie Rabie, { 12. Respondent has personally filed for bankruptcy 6 times and has 3 civil judgments against her. Declaration of Karolyn Hicks, at Exhibit A. Petitioner has grave concerns that Respondent does not have the qualifications or financial expertise to handle this Estate. Rabie Deel., 4 12. In addition to her bankruptcies and judgments, she demonstrated as much when she was managing Enerco Property Management Inc. (“EPMI”), a company formed by Ms. Campbell and the Decedent. While managing EPMI, Respondent prepared incorrect W-2s (original and revised) for employees of EPMI. Attached to Petitioner’s Declaration as Exhibit E are copies of her W-2s that show no and/or inadequate withholding despite withholding from the employee’s paycheck. Revised W2s were later issued to some of the company’s ‘employees once this mistake was pointed out to Respondent, but Petitioner believes that the amount of withholding noted on the revised W2s is still incorrect. Id, $6. The Internal Revenue Service (“IRS”) is now requesting information from Petitioner. Jd Ms. Campbell PETITION FOR REMOVAL OF PERSONAL SB REPRESENTATIVE - Page 4 INS LEE BEST 4810381 | 364601 [0002 me anlin10 u 12 13 14 15 16 20 21 22 23 24 must immediately be replaced by a competent personal representative that can promptly and effectively respond to the IRS’s inquiries. Another example of why Ms. Campbell is unfit to serve as Personal Representative is the way she interacts and deals with other professionals. At one point last year, the parties were trying to lease a piece of Mr. Rabie’s commercial real estate that he owned (and that is now in his Estate). The real estate broker terminated the relationship because he was unable to work with Ms. Campbell. Rabie Decl., Exhibit F (correspondence with Bill Condon at Colliers). ‘The assets in this Estate need to be properly managed and/or liquidated in the best interests of the beneficiaries, and Ms. Campbell is in no position to do so. Petitioner, as the 98% beneficiary of the Estate, does not have any faith in Ms. Campbell’s abilities to negotiate any deals in the best interest of the Estate’s beneficiaries. Rabie Decl., { 12; see also Ex. F Likewise, as the 100% beneficiary of the Trust, Petitioner would like Ms. Campbell removed as Trustee. Id. E. Ms. Campbell is Only Looking Out For Herself ‘The Decedent died on December 30, 2015. Respondent had custody of the Will when the Decedent died. She had 40 days to file it. RCW 11.20.010. Despite numerous requests by Petitioner for Respondent to turn over the Will and allow probate of the Decedent's Estate to be commenced, Respondent refused. Rabie Decl., 9. Instead, she spent most of those 40 days with the assistance of two separate attorneys attempting to extort a settlement out of the Petitioner designed to absolve her from any and all liability for past dealings with the Decedent and his property before turning it over. Id. PETITION FOR REMOVAL OF PERSONAL REPRESENTATIVE - Page 5 “481058. | 364601 |000210 12 13 4 15 16 7 18 20 2 2 23 24 Ms, Campbell has also already put the Estate in jeopardy by risking the loss of a tenant on an industrial park owned by the Estate. Rabie Decl., 410. Petitioner started working with Wells Fargo Bank, N.A. in August 2015 to assist her in the management of her father’s financial and personal affairs in an effort to undo the damage that Respondent had caused and to remediate the estate and put its assets to work for the Decedent while he was still alive. Id. One of the main objectives for months has been to get the property located at 1541 South 96th Street, Seattle WA leased out so that this valuable asset could become a source of positive cash flow for Mr. Rabie. 1d., L1. A potential tenant was found and lease negotiations began near the time of the Decedent's death. Jd ‘The terms of the proposed lease are extremely favorable, netting over $9,200 per month to the Estate for the first six months and a higher amount thereafter. Jd. Respondent had known about this lease opportunity for over a month, yet refused to allow the appointment of any fiduciary during the month of January to execute the lease, preferring to drag out settlement negotiations while she sought indemnity for her pre~ death self-dealings with Mr. Rabie. [d. She clearly holds her own interests well above those of the beneficiaries. F. The PR Speaks Ill of the Beneficiary Ms. Campbell has been on a campaign to discredit the Petitioner for some time, ea 1 Petitioner's mother, her aunt and her cousin. See Declaration of Patricia Lozier, Declaration of | Mary Jane Bault, and Declaration of Lois Rabie. These calls and comments were made in addition to the awful text messages she sent to Mr. Walther. Rabie Decl., Ex. C, Respondent's 1 More recently, one of Petitioner’s sisters, a 1% beneficiary, has caused added delay to the execution of the lease by declining to sign a stipulation that would permit the PR to sign the lease, PETITION FOR REMOVAL OF PERSONAL. B REPRESENTATIVE - Page 6 481038. 364601 | 0002 ‘emo 4 St St 020 2 2 23 4 actions clearly demonstrate an inability to work with and in the best interest of Petitioner and the other beneficiaries of the Estate. I. STATEMENT OF THE ISSUES 1. Whether the Court should remove Elizabeth Campbell as personal representative of the Estate; 2. Whether the Court should appoint Wells Fargo Bank, N.A. as successor Personal Representative when the suecessor named in the Will has declined to serve; 3. Whether the Court should remove Elizabeth Campbell as Trustee; 4. Whether the Court should appoint Wells Fargo Bank, N.A. as successor Trustee when successor Lorelei Stevens has declined to serve and Ms. Campbell is unfit to serve; 5. Whether the Court should award the costs of bringing this motion to Petitioner against Ms. Campbell personally, as permitted by RCW 11.96A.150. IL, EVIDENCE RELIED UPON This Petition relies upon the following declarations: 1. Declaration of Jodie Rabie, with Exhibits A-G; 2. Declaration of Anneliese Johnson, with Exhibits A-D; 3. Declaration of Michael Moceri, with Exhibit A; 4. Declaration of Patricia Lozier; Declaration of Mary Jane Bault; 6. Declaration of Lois Rabie; and 7. Declaration of Karolyn Hicks, with Exhibit A. PETITION FOR REMOVAL OF PERSONAL = REPRESENTATIVE - Page 7 INSLEE BEST 431038.1| 364601 | 0002 pe oe2 10 u 12 15 16 7 20 2 2 23 24 I. LEGAL AUTHORITY ts A. ‘The Initial Hearing Should Be a Hearing on the Mei Pursuant to RCW 11.96A.100, Petitioner respectfully request that the initial hearing be a hearing on the merits to remove Elizabeth Campbell as Personal Representative and Trustee and to replace her with Wells Fargo. To delay removal of the current Personal Representative and Trustee would only invite further waste, mismanagement, potential embezzlement and litigation, which all put the assets held by the Estate and Trust at risk of being further depleted. B. _ Petitioner Should Not Even Be Serving as PR, Having Failed to Give Notice As a preliminary matter, Respondent sought appointment as Personal Representative without first giving Petitioner notice and an opportunity to object. RCW 11.28.020 provides: any person interested in a will may file objections in writing to the granting of letters testamentary to the persons named as executors, or any of them, and the objection shall be heard and determined by the court Respondent was aware, by virtue of Petitioner's two previously filed Petitions for Appointment of Special Administrator (King County Cause Nos. 16-4-00662-8 SEA and 16-4- 00803-5 SEA; Johnson Decl., 7 and Ex. D) that Petitioner objected to her serving as Personal Representative of the Estate, yet she failed to give Petitioner notice and an opportunity to be heard to object to the appointment. Upon information and belief, she did so because she knew Petitioner would object. C. Removal of the Current PR is In the Best Interest of the Estate and Ail Its Beneficiaries If a personal representative fails to execute his trust faithfully or is subject to removal for any reason specified in RCW 11.28.250, upon petition of any heir, devise, or legatee, such petition being supported by affidavit which makes a prima facie showing of cause for removal PETITION FOR REMOVAL OF PERSONAL BS REPRESENTATIVE - Page 8 INSLEE BEST asics jaeee joo ADL Sateeidina Eat xo Ss Sit 1019 20 2 22 23 24 or restriction of powers, the court shall cite such personal representative to appear before it, and if, upon hearing of the petition it appears the personal representative has not faithfully discharged his trust or is subject to removal, then, in the discretion of the court, the personal representative's powers may be restricted or he may be removed. RCW 11.68.070. ‘Ms. Campbell is not fit to serve as Personal Representative. RCW 11.28.250 provides as follows: Whenever the court has reason to believe that any personal representative has wasted, embezzled, or mismanaged, or is about to waste, or embezzle the property of the estate committed to his or her charge, or has committed, or is about to commit a fraud upon the estate, or is incompetent to act, or is permanently removed from the state, or has wrongfully neglected the estate, or has neglected to perform any acts as such personal representative or for any other cause or reason which to the court appears necessary, it shall have power and authority, after notice and hearing to revoke such letters. ‘The manner of the notice and of the service of the same and the time of hearing shall be wholly in the discretion of the court, and if the court for any Such reasons revokes such letters the power of such personal representative shall at once cease, and it shall be the duty of the court to immediately appoint some other personal representative, as in this title provided. (Emphasis added.) Several of these bases for removal apply here. Ms. Campbell already wasted, embezzled and/or mismanaged Mr. Rabie’s assets when she was his attomey-in-fact, transferring to herself somewhere between $350,000-$400,000. Moreover, even had she not already breached her fiduciary duties to Mr. Rabie when he was alive, one of the bases for removal is “any other cause or reason which to the court appears necessary [to remove]” the personal representative.” Here, as detailed above, there is ample cause to remove Ms. Campbell including but not limited to her mismanagement of the EPMI assets and resulting tax issues, her slander of Ms. Rabie (the 98% beneficiary of Estate), her inability to work with PETITION FOR REMOVAL OF PERSONAL BS REPRESENTATIVE - Page 9 INSLEE REST 481038. 3646010002 Meth Sinan tats sexo Soe Sa 800 eid1 Jother professionals, her own 6 bankruptcies and 3 civil judgment, and her demonstrated 2. | inability to put the beneficiaries’ best interests above her own self-interest. 3 ‘The right of beneficiaries to have an estate distributed by law is a primary right and if @ interfere with this right, that person 4. | particular person serving as a personal representative ma} should not serve. In re Estate of Jones, 152 Wn.2d 1, 19 & n.J4, 93 P.3d 147 (2004) 5 6 | Moreover, if ill will exists, which will result in more litigation, “the court may appoint any 7 suitable person” as successor. In re Estate of Thomas, 167 Wn. 127, 133-34, 8 P.2d 963 g [193 5 As detailed above, Ms. Campbell cannot handle her own finances, let alone an Estate 1o_| ith over 82 Million. Petitioner, the 98% beneficiary ofthe Estate and 100% beneficiary of the Trust, has absolutely no faith in Ms. Campbell's abilities and believes she will waste, " embezzle and mismanage the Estate assets. Ms. Campbell already self-dealt from Decedent's "> soot in 2014 whe she was his DPOA, and Petitioner has every reason to believe she will try | odo.0 again " In Jn re Estate of Ardell, 96 Wn.App. 708, 980 P.2d 771 (1999) the Court determined it 'S | nas the discretion to remove a personal representative if the personal representative fails to 'S | execute his or her trust faithfully or is subject to removal for any reason specified by statue w ‘The court in In re Clawson’s Estate, 3 Wn.2d 509, 101 P.2d 948 (1940) found that it was. 18 | proper to remove a personal representative whose personal interests prevented him from acting '9 Jin a disinterested manner and where his actions had caused him to fail to execute his trust 20 | faithfully and had promoted unnecessary and costly litigation. In re Estate of Thomas, 21 | 167 Wn. 127, 133-34, 8 P.2d 963 (1932). 2 23. | PETITION FOR REMOVAL OF PERSONAL aS REPRESENTATIVE - Page 10 INSLEE BEST 24 | 4810381 | 364601 | 002 fala Sdcauc aeods,14 15 16 7 20 a 2 23 24 As detailed above, trying (o using the production of the Will and then delaying signing the lease on commercial property’ as leverage to extort a settlement out of Petitioner further demonstrates that Respondent is not fit to serve as Personal Representative, and is entirely incapable of acting in the best interests of the Estate beneficiaries. At present, the potential tenant is very anxious to sign, and to commit property and resources to the site starting on March 1, 2016. Rabie Decl., 11 Petitioner respectfully requests the Court appoint Wells Fargo, N.A. to serve as Personal Representative of the Decedent's estate so that the experience, contacts, and professionalism upon which its reputation has been built may be put to use to beneficially administer the Decedent's estate in the best interests of the beneficiaries, Rabie Decl., 13, 14, D. Removing Ms. Campbell as Trustee is Also in the Best Interest of the Trust and Its Beneficiary A fiduciary owes the highest degree of good faith, diligence and undivided loyalty to beneficiaries. In re Estate of Ehlers, 80 Wn. App. 751, 757, 911 P.2d 1017 (1996). A fiduciary’s obligation to comply with her duties is absolute. Good faith is irrelevant when a trustee breaches a duty owed beneficiaries. Restatement (Second) of Trusts § 201, comment b (1959); George T. Bogert, Trusts & Trustees § 543, at 217-18 (2d rev. ed. 1993). Many forms of conduct permissible for those acting at arm’s length are forbidden for fiduciaries. The most fundamental duty owed to the beneficiaries is the duty of loyalty. IA Wm. F. Fratcher, Scott on Trusts, § 170, at 311 (4th ed. 1987). The fiduciary owes a duty to the beneficiaries to administer the affairs solely in the interest of the beneficiaries, and to exclude from ? Again, Petitioner acknowledges and concedes that more recently, it is her 1% beneficiary sister who is causing the delay in the signing of the lease. PETITION FOR REMOVAL OF PERSONAL REPRESENTATIVE - Page 11 83038. 1 | 361601 | 000219 20 2 22 23 24 consideration her own advantages and the welfare of third persons. Bogert § 543, at 218; Restatement (Second) of Trusts § 170(1) (1959). A fiduciary must deal fairly and justly with the beneficiary and act solely in the beneficiary’s best interest. Jd; Esmieu v. Schrag, 88 Wn.2d 490, 498-99, 563 P.2d 203 (197). Moreover, [w)here a trustee finds himself in the position where he has, either individually or as trustee for another, an interest which conflicts with that of the beneficiaries of the trust, he should resign from the trust so as not to attempt the impossible task of representing conflicting interests. Tucker v. Brown, 20 Wn.2d 740, 769, 150 P.2d 604 (1944). ‘The animosity between Ms. Campbell and the Trust’s 100% beneficiary is just one reason to remove Ms. Campbell as Trustee. Respondent cannot fulfill her fiduciary duties to Petitioner. Ms. Campbell has been pursuing a campaign to ruin and discredit Petitioner all because Petitioner started looking into transactions between Ms. Campbell and her father. Rabie Decl., 4 3-4, and Ex. C. It is inconceivable that Respondent will be able to fairly and effectively manage Decedent's Estate and Trust while harboring such a level of hatred and disrespect towards Petitioner. As noted above, when Ms. Campbell’s primary focus should be on administering the Decedent’s Estate and Trust assets, she instend commenced a defamation lawsuit against Mr. Walther for providing a statement. Moceri Decl., Ex. A. This kind of intimidation and clear witness tampering is unacceptable and is one more reason that Respondent is clearly disqualified to serve in any fiduciary capacity. Respondent is incapable of acting in a fiduciary capacity to protect and represent the best interests of Decedent’s Estate, Trust and their respective beneficiaries. PETITION FOR REMOVAL OF PERSONAL B REPRESENTATIVE - Page 12 INSLEE, BEST 4810381 | 364601 0002 MAS ated ati somone e20920 21 22 23 24 The Court has the authority to remove the Trustee and appoint a neutral trustee to administer the Trust. RCW 11.98.039(4). The Petitioner respectfully request the Court remove Ms. Campbell and appoint Wells Fargo, N.A. as her successor. E, Nominated Successor Once a successor Personal Representative is appointed, the successor has a right to “the immediate possession of all the real as well as personal estate of the deceased,” RCW 11.48.020, and the removed personal representative: [S]hall account for, pay, and deliver to his successor or to the surviving or remaining personal representatives, all money and property of every kind, and all rights, credits, deeds, evidences of debt, and papers of every kind, of the deceased, at such time and in such manner as the court shall order on final settlement with such personal representative or his legal representatives. RCW 11.28.290. Petitioner respectfully request the Court authorize the successor fiduciary (Wells Fargo, N.A.) to immediately take possession of all money and property of every kind belonging to Mr. Rabie, including but not limited to all bank accounts that had been held, if any, in Ms. Campbell and Mr. Ral names as joint tenants with right of survivorship, and to be ordered to investigate the extent to which Ms. Campbell financially exploited the Decedent. In the Will, the Decedent named Mary Jane Bault to serve as successor Personal Representative/Executor. Ms. Bault has declined to serve but is supportive of the appointment of an independent third party to manage Decedent's estate. Declaration of Mary Jane Bault. In the Trust, Ms. Lorelei Stevens is named together with Ms. Campbell as Trustee, with no additional named successor. Ms. Stevens has declined to serve. Rabie Decl., Ex. G. Thus, Petitioner respectfully requests that the Court appoint Wells Fargo Bank, N.A. to serve as successor Personal Representative and successor Trustee. PETITION FOR REMOVAL OF PERSONAL Ba REPRESENTATIVE - Page 13 INSLEE mest pareene ABSsaalt ata E10 ul 20 21 2 23 24 1V. CONCLUSION WHEREFORE, Petitioner requests this Court Order the following: 1. Order Elizabeth Campbell, Personal Representative, to appear before this Court on March 23, 2016 to show cause as to why the requests in this Petition should not be immediately granted at the initial hearing on the merits pursuant to RCW 11.96A.100; 2. Remove Elizabeth Campbell as Decedent’s Personal Representative; 3. Accept the Declination to serve signed by Mary Jane Bault; 4. Appoint Wells Fargo Bank, N.A. as Decedent’s successor Personal Representative, to serve without Bond and with Nonintervention Powers; 5. Direct the Clerk of the Court to promptly issue Letters Testamentary to Wells Fargo Bank, N.A. upon the filing of its sworn Oath of Personal Representative; 6 Order Elizabeth Campbell as Decedent's prior Personal Representative to deliver to Wells Fargo Bank, N.A. as Decedent's Personal Representative: a, All money and other property of Decedent’s estate in her possession or control within ten (10) days; b. A verified accounting of her administration of Decedent's estate within thirty (30) days of the Order appointing Wells Fargo Bank, N.A. as Decedent's successor Personal Representative; 7. Order Wells Fargo, N.A. to investigate the extent to which Ms. Campbell financially exploited the Decedent; 8 Remove Elizabeth Campbell as Trustee; 9. Accept the Declination to serve signed by Lorelei Stevens; 10. Appoint Wells Fargo Bank, N.A. as Decedent’s successor Trustee; PETITION FOR REMOVAL OF PERSONAL REPRESENTATIVE - Page 14 481038. [364601 c002 BEST15 16 17 18 20 2 2 23 2 2 10. Award Petitioner her fees and costs incurred in seeking the removal of Elizabeth Campbell as against Ms. Campbell pero as permitted by RCW 11,96A,150. RESPECTFULLY SUBMITTED this, 7 day of February, 2016. PETITION FOR REMOVAL OF PERSONAL REPRESENTATIVE - Page 15 481038. | 364601 | 0002 INSLEE, BEST, DOEZIE & RYDER, P.S. Attomeys for Petitioner STOKES LAWRENCE, P.S.. Kafolyn Hicks, WSBA# 30418 Attorneys for Petitioner IN SL 302/26/2016 23:22 FAX oo2/002 2 VERIFICATION ‘The undersigned declares under penalty of perjury under the laws of the State of| Washington that she is the Petitioner named in this Petition, that she has read the Petition, knows the contents thereof, and that the statements made therein are true and correct to the ‘best of her knowledge and belief. DATED: February 264, 2016, a Sedea Abul of Washington, cagplabi flabe 10 i 12 13 14 15 7 18 19 20 a 2 23. | PETITION FOR REMOVAL OF PERSONAL REPRESENTATIVE - Page 16 24 | 481008. | 364601 | 000210 12 1B 4 15 16 7 18 19 20 21 2 24 IN THE SUPERIOR COURT OF WASHINGTON FOR KING COUNTY In Re the Estate of: LEE CHARLES RABIE, Case No.: GR 17 AFFIDAVIT OF KAROLYN Deceased. HICKS JODIE L. RABIE, Petitioner, v ELIZABETH CAMPBELL, Respondent. 1, Karolyn Hicks, am over the age of 18, declare that I have examined the signature of Jodie Rabie on the Verified Petition for Removal of Personal Representative & Trustee and to Appointing Suecessor with her signature appearing on page 16. It is complete and legible. 1 declare under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct. EXECUTED at Seattle, Washington this 29th day of February, 2016. STOKES LAWRENCE, P.S. By: Zarolyn Hicks (WSBA #30418) 1420 Fifth Avenue, Suite 3000 Seattle, WA 98101 Phone: 206-626-6000 Facsimile: 206-464-1496 Attomeys for Jodie Rabie PETITION FOR REMOVAL OF PERSONAL Ba REPRESENTATIVE - Page 17 INSLEE BEST 9058.1 | 6601 | 002 an nese Sone ARTO TS boro