Electronically FILED by Superior Court of California, County of Los Angeles 7/7/2021 9:38 AM Sherri R.

Carter, Executive Officer/Clerk, By Bella Gasper, Deputy Clerk

Received: 7/7/2021 9:38 AM

1 Lauriann Wright, SBN 172249

Marie Mondia, SBN 297284
2 WRIGHT KIM DOUGLAS, ALC
130 South Jackson Street
3
Glendale, CA 91205
4 Tel. (626) 356-3900
Fax. (626) 298-8600
5 Emails: lauriann@wkdlegal.com
marie@wkdlegal.com
6

7 Attorneys for Jodi Montgomery,

Temporary Conservator of the Person
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10
WRIGHT KIM DOUGLAS

11
A Law Corporation

In re the Conservatorship of the Person and Case No. BP108870

12 Estate of:
EX PARTE PETITION FOR ORDER
13 BRITNEY JEAN SPEARS, AUTHORIZING AND INSTRUCTING
CONSERVATOR(S) OF
14 THE ESTATE TO PAY FOR
Conservatee ADDITIONAL SECURITY EXPENSES;
15 DECLARATION OF LAURIANN
WRIGHT RE: URGENCY AND NOTICE
16
Date: July 8, 2021
17 Time: 8:30 a.m.
Place: Room 260/ Dept.: 4
18 Judge: Hon. Brenda J. Penny

19

20 Jodi Montgomery (“Ms. Montgomery” or “Petitioner”), as Temporary Conservator of the

21 Person of Britney Jean Spears (“Ms. Spears”), hereby brings this Ex Parte Petition for an Order

22 Authorizing the Conservator(s) of the Estate to Pay for Additional Security Expenses and states as

23 follows:

24 I. INTRODUCTION

25 1. Since the June 23, 2021 status hearing, which was illegally broadcasted, streamed,

26 and replayed to an incredibly wide audience, there has been a marked increase in the number and

27 severity of threatening posts about Petitioner on all social media platforms as well as text

28 messages, phone calls, and emails directed to the Petitioner personally. Many of the messages
1
EX PARTE PETITION FOR ORDER AUTHORIZING & INSTRUCTING CONSERVATOR(S) OF THE
ESTATE TO PAY FOR ADDITIONAL SECURITY EXPENSES
 1 threaten violence and even death against Petitioner. Petitioner has forwarded (and continues to

2 forward) these threatening communications to the security company retained by the Conservator

3 of the Estate, Black Box Security, Inc. Security has determined the security risk to be serious

4 enough to recommend that 24/7 physical security be provided to Petitioner on an interim basis in

5 order to protect her from harm and until such time as Petitioner can make certain security

6 improvements at her home office/ residence.

7 2. Physical security has been at Petitioner’s residence since June 30, 2021, being

8 conditionally paid for by the Conservatorship Estate because it is cost-prohibitive for Petitioner to

9 bear the cost of it personally. Jamie Spears, as Conservator of the Estate, has conditioned the

10 providing of security to Petitioner on: (1) Petitioner obtaining court approval for the security, and
WRIGHT KIM DOUGLAS
A Law Corporation

11 (2) Petitioner agreeing that if, for some reason, court approval is not obtained, that Petitioner agree

12 to pay back the cost to the Conservatorship Estate.

13 3. The cost of physical security, although deemed urgent and necessary at this time

14 for Petitioner, is cost-prohibitive for Petitioner to personally bear. Unless and until this Court

15 approves the expense, Petitioner remains personally liable for it. Thus, we are asking this Court to

16 approve the expense as soon as possible via this ex parte petition.

17 II. PROCEDURAL AND FACTUAL BACKGROUND

18 4. Initial Appointments. On February 1, 2008, the Court appointed James P. Spears

19 (“Mr. Spears” or “Conservator of the Estate”) as Temporary Conservator of the Person of his

20 daughter, Britney Jean Spears, and Mr. Spears and Andrew M. Wallet (“Mr. Wallet”) as

21 Temporary Co-Conservators of Ms. Spears’ Estate. Letters of Temporary Conservatorship were

22 issued that day and were extended several times. On October 28, 2008, the Court granted the

23 Petitions for Permanent Conservatorship as to Ms. Spears’ Person and Estate. Permanent Letters

24 were issued on January 9, 2009.

25 5. Conservator of the Estate. On March 5, 2019, the Court accepted the resignation

26 of Mr. Wallet and confirmed Mr. Spears as the sole Conservator of the Estate of Ms. Spears.

27 Amended Letters of Conservatorship were issued on that date. On November 10, 2020, the Court

28 appointed Bessemer Trust as Co-Conservator of Ms. Spears’ Estate, but the Order thereon was not
2
EX PARTE PETITION FOR ORDER AUTHORIZING CONSERVATOR OF THE ESTATE
TO PAY FOR PETITIONER’S NEEDED ADDITIONAL SECURITY EXPENSES
 1 entered until June 30, 2021. On July 1, 2021, Bessemer Trust filed an ex parte application for the

2 Court to accept its Resignation; the Court has set that application to be heard at the next hearing

3 date in this matter, July 14, 2021.

4 6. Conservator of the Person. On September 9, 2019, at Mr. Spears’ request, Jodi

5 Montgomery (“Ms. Montgomery”) was appointed Temporary Conservator of Ms. Spears’s person.

6 Letters of Temporary Conservatorship of the Person were initially issued to Ms. Montgomery on

7 September 9, 2019 and have been extended to September 3, 2021. On that same day, Mr. Spears

8 temporarily relinquished the powers of conservatorship of the person.

9 7. CAC Attorney. On February 1, 2008, the Court appointed Samuel D. Ingham, III

10 (“Mr. Ingham”) as the Court Appointed Counsel (“CAC”) for Ms. Spears. As of the date of the
WRIGHT KIM DOUGLAS
A Law Corporation

11 filing of this Ex Parte Petition, Mr. Ingham has not been discharged as the CAC attorney, although

12 on July 6, 2021 he filed an Application for Appointment of Counsel in which he tendered his

13 resignation.

14 8. Recent Status Hearing. On June 23, 2021, at an unsealed, open status hearing,
15 Ms. Spears addressed the Court, raising numerous concerns about her conservatorship and making

16 “serious allegations regarding forced labor, forced medical treatment and therapy, improper

17 medical care, and limitations on personal rights, to name a few.” (Mr. Spears’ Petition for

18 Instructions dtd 6/29/21 at ¶10.)

19 9. While Ms. Spears expressed her displeasure with her conservatorship at the June
20 23, 2021 hearing, she has informed Petitioner that she would like to her to stay on as her

21 conservator. Attached as Exhibit A is a true and correct copy of a text message between

22 Petitioner and Ms. Spears wherein Ms. Spears expressed her wish for Petitioner to continue

23 serving in her current role.

24 10. Assessment and Recommended Additional Security. As soon as Petitioner

25 began receiving an elevated level of threatening messages, she notified Black Box Security, Inc.,

26 the security company that has provided security to the conservatorship estate for many years. All

27 threats are being forwarded to them for ongoing assessment. In their current assessment,

28 Petitioner needs 24/7 live security at her residence / home office for a couple of months. They
3
EX PARTE PETITION FOR ORDER AUTHORIZING CONSERVATOR OF THE ESTATE
TO PAY FOR PETITIONER’S NEEDED ADDITIONAL SECURITY EXPENSES
 1 provided a quote on June 30, 2021 which is attached as Exhibit B. The initial quote is for 14 days

2 and Petitioner requests that this expense, payable by the Conservator(s) of the Estate, be approved

3 by the Court.

4 11. Request for Payment of Physical Security Expenses by Conservator of the

5 Estate: Also on June 30, 2021, Petitioner contacted Mr. Spears to request the live 24/7 security

6 recommended by Black Box Security. Mr. Spears, through the Estate’s business manager Michael

7 Kane of Miller Kaplan, approved hiring of security guards for Petitioner. Mr. Kane also stated

8 that Mr. Spears requested a risk assessment analysis, inclusive of implementation of recommend

9 protocols. Attached as Exhibit C is a true and correct copy of the email from Michael Kane

10 approving the security guard.

WRIGHT KIM DOUGLAS
A Law Corporation

11 12. Current Payment of Physical Security Expenses Have Now Been Made
12 Conditional by Conservator of the Estate: After the email at Exhibit B was sent, during a

13 conference call between counsel on the issue on July 1, 2021, Ms. Wyle on behalf of Jamie Spears

14 conveyed that Mr. Spears would not continue to approve of the payment of the security for

15 Petitioner unless Petitioner agreed that, should the Court not approve of its payment, Petitioner

16 would pay the cost of it back to the conservatorship estate. Petitioner agreed. But because the

17 cost of security guards is cost-prohibitive for Petitioner to take on for herself personally and before

18 Petitioner’s potential personal liability gets too large, this Ex Parte Application is being brought to

19 seek approval of this expense by the Court. It is Petitioner’s understanding that Mr. Spears as

20 Conservator of the Estate has no objection to the expense in and of itself, but just does not want to

21 authorize it himself without prior court approval.

22 13. Preliminary Security Measures Taken by Petitioner. Petitioner has taken

23 several steps of her own to improve her security. In addition to the assessment by Black Box

24 Security, Petitioner has contacted her local sheriff’s department and they have added her to their

25 patrol watch. Petitioner also immediately began undertaking her own security improvements to

26 her property, which comes at a significant extra personal expense and will take several weeks to

27 complete. Once those additional security improvements are made, the security threat can be

28 reassessed and perhaps less physical security or no physical security will be needed.
4
EX PARTE PETITION FOR ORDER AUTHORIZING CONSERVATOR OF THE ESTATE
TO PAY FOR PETITIONER’S NEEDED ADDITIONAL SECURITY EXPENSES
 1 III. PETITIONER REQUESTS THAT CONSERVATOR OF THE ESTATE BE

2 ALLOWED TO PAY FOR ADDITIONAL SECURITY

3 14. Since Ms. Spears has requested that Petitioner retain her position as conservator,

4 Petitioner has no intention of abandoning her by resigning because of these threats. However, in

5 order for Petitioner to effectively perform her duties as conservator, her security and safety must

6 be ensured.

7 15. As a case of public interest, Petitioner has always received some level of ongoing

8 threats throughout the pendency of the case. But since the June 23, 2021, the amount as well as

9 the severity of the threats has drastically increased, threatening the very safety of the Petitioner.

10 The Petitioner as the Temporary Conservator of the Person plays an important role ensuring the
WRIGHT KIM DOUGLAS
A Law Corporation

11 best interests of the conservatorship, making it essential to ensure her safety. Because threat levels

12 and the need for security evolve rapidly over time, Petitioner has phrased the requested order to

13 apply on an ongoing basis. Notably, the order sought is a 2-step process, where an assessment is

14 made first and, then and only then, are the additional security protocols implemented, as

15 recommended by security.

16 IV. EX PARTE RELIEF IS WARRANTED UNDER THE CIRCUMSTANCES

17 16. Exigent circumstances exist to grant this Ex Parte Petition as the Petitioner is still
18 receiving violence and death threats at an alarming rate. These threats should all be taken

19 seriously and carefully addressed. The safety of all parties involved is of the utmost importance.

20 It is also in Ms. Spears’ best interest that those around her are kept safe and not exposed to a

21 constant threat of harm. Although the conservatorship estate is temporarily bearing the cost of

22 these expenses, Mr. Spears has conditioned them payment of them upon: (1) Petitioner obtaining

23 court approval for the security, and (2) Petitioner agreeing that if, for some reason, court approval

24 is not obtained, that Petitioner agree to pay back the cost to the Conservatorship Estate. The cost

25 of security guards is cost-prohibitive for Petitioner to bear herself and she seeks a Court order to

26 approve them as soon as possible.

27 VI. PRAYER
28 17. Wherefore, Jodi Montgomery, as Temporary Conservator of the Person of Britney
5
EX PARTE PETITION FOR ORDER AUTHORIZING CONSERVATOR OF THE ESTATE
TO PAY FOR PETITIONER’S NEEDED ADDITIONAL SECURITY EXPENSES
 1 Jean Spears, respectfully requests that the Court make the following orders:

2 a. Authorizing and instructing the currently serving Conservator(s) of the Estate to

3 expend such sums as is necessary to engage a security company to:

4 i. Assess the threats and security risks of Petitioner and Temporary

5 Conservator of the Person Jodi Montgomery on an ongoing basis and to

6 make recommendations as to the additional security measures that are

7 reasonable and appropriate to address credible threats and risks; and

8 ii. Provide any additional security to Petitioner Jodi Montgomery so

9 recommended by the security company for as long as the security company

10 recommends it.
WRIGHT KIM DOUGLAS
A Law Corporation

11 b. Any such other orders as the Court deems necessary and appropriate.

12 Respectfully Submitted:

13 Dated: July 6, 2021 WRIGHT KIM DOUGLAS ALC

14
By: _____________________________
15
Lauriann Wright
16 Marie Mondia
Attorneys for Jodi Montgomery,
17 Temporary Conservator of the Person
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EX PARTE PETITION FOR ORDER AUTHORIZING CONSERVATOR OF THE ESTATE
TO PAY FOR PETITIONER’S NEEDED ADDITIONAL SECURITY EXPENSES
 1 DECLARATION OF LAURIANN WRIGHT

2 I, Lauriann Wright, declare:

3 1. I am an attorney licensed to practice law in the State of California and am a partner

4 at the law firm Wright Kim Douglas, ALC, counsel for Temporary Conservator Jodi Montgomery,

5 in her capacity as temporary conservator of the person of Britney Jean Spears. Except as otherwise

6 stated, the statements contained in this Declaration are based on my personal knowledge and

7 experience. If called as a witness, I could and would testify competently to those facts.

8 2. Exigent Circumstances. Exigent circumstances exist to grant this Ex Parte

9 Petition as it is in Ms. Spears’ best interest if those around her are not placed in any danger. There

10 are grave concerns regarding the safety of the Conservator of the Person and counsel involved in
WRIGHT KIM DOUGLAS
A Law Corporation

11 this highly-publicized matter arising from a drastic increase in threats of violence and death since

12 the June 23, 2021 unsealed status hearing. If the Court would like additional detail on the threats

13 that are being made, we can provide them for in camera review or discuss them at a sealed hearing

14 on this matter.

15 3. Notice. On July 6, 2021, at approximately 6:00 p.m, my office e-mailed Samuel D.

16 Ingham, Court-Appointed Counsel for Conservatee, Britney Jean Spears, David C. Nelson and

17 Ronald Pearson, associated counsel for Ms. Spears, Vivian L. Thoreen, Jonathan H. Park, Roger

18 B. Coven, Geraldine A. Wyle, Jeryll Cohen, and Rebekah Swan, counsel for James P. Spears,

19 Yasha Bronshteyn, Gladstone N. Jones, III, and Lynn E. Swanson, counsel for Lynne Spears and

20 Bruce S. Ross, and Alan T. Yoshitake, counsel for Bessemer Trust Company, and informed them

21 that the Temporary Conservator would be applying ex parte for an Order Authorizing Conservator

22 of the Estate to pay for additional security. They were advised of the time, place, subject matter,

23 grounds, and relief sought with regard to the Ex Parte Petition.

24 4. Copies of this Ex Parte Petition and the Proposed Order are being sent to all parties

25 entitled to notice via email concurrently with this filing.

26 //

27 //

28 //
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EX PARTE PETITION FOR ORDER AUTHORIZING CONSERVATOR OF THE ESTATE
TO PAY FOR PETITIONER’S NEEDED ADDITIONAL SECURITY EXPENSES
 1 5. At the time of this filing, I have no information as to whether the Ex Parte Petition

2 will be opposed.

3 I declare under penalty of perjury under the laws of the State of California that the

4 foregoing is true and correct. Executed this 6th day of July 2021, at Los Angeles, California.

6 _____________________________
LAURIANN WRIGHT
7

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WRIGHT KIM DOUGLAS
A Law Corporation

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EX PARTE PETITION FOR ORDER AUTHORIZING CONSERVATOR OF THE ESTATE
TO PAY FOR PETITIONER’S NEEDED ADDITIONAL SECURITY EXPENSES
 VERIFICATION

I, the undersigned, say:

I am the Petitioner in this action. I have read the foregoing document which bears the title:

EX PARTE PETITION FOR ORDER AUTHORIZING CONSERVATOR OF THE

ESTATE TO PAY FOR ADDITIONAL SECURITY EXPENSES; DECLARATION OF
LAURIANN WRIGHT RE: URGENCY AND NOTICE

and know the contents thereof and that the same is true of my own knowledge.

Executed on June 6, 2021 at Pasadena, California.

JODI MONTGOMERY

9
EX PARTE PETITION FOR ORDER AUTHORIZING CONSERVATOR OF THE ESTATE
TO PAY FOR PETITIONER'S NEEDED ADDITIONAL SECURITY EXPENSES
Exhibit A
 4:28©IIIII ° 3““.122‘56!

lneed u to stay as my co
conservator of person

AA I'm asking u for ur assistance

in getting a new attorney

Thank u for ur help

1 ©Qo
Exhibit B
Marie Mondia

Subject: FW: BBX Quote - Residential Security Services

From: Stas
Date: June 30, 2021 at 7:31:09 PM CDT
To: jodi
Cc: , Edan >, Katya

Subject: BBX Quote - Residential Security Services

Dear Jodi and Jamie,

Per your conversation with Edan, below please find our quote for residential security services in
the Los Angeles, CA area.

Residential Security Services :

Scope: Professional security services rendered by a team of experienced protection specialists
assigned to patrol and monitor residential premises with the objective of maintaining a safe and
reassuring environment and protecting privacy of residents and their guests.
Rate: $65.00/hour per agent

Estimated cost for 24/7 security: $1,820 (day & night shift) x 14 days = $25,480

Service Terms:
- California Overtime Rules: Overtime will be billed at one and one-half times the regular rate for
agents who will be requested to work over 8 hours per day, and two times the regular rate for agents
working longer than 12 hours per day.
- Holiday Rates: BBX charges one and one-half times the regular rate for holiday hours. Double rates
apply to any additional time worked in excess of 12 hours per day.
- Minimum Service: eight (8) hours per day per agent.
- Job-related expenses (e.g. parking, tips, expenses paid on behalf of the client, miles driven on client’s
business outside of the residential post at $0.75/mi, security post maintenance, etc.) are reimbursable and
will be invoiced as incurred.
- Cancellation Policy: should the services be canceled within 24 hours prior to the scheduled time of
assignment, the minimum service charge will apply.

Please let us know if you would like to move forward with this assignment or if you have any
questions.

Thank you,

Stas
Staff Accountant
Please note our new address for payments by check

1
 BLACK BOX SECURITY INC.
27001 Agoura Road, Ste #170, Calabasas, CA 91301
T: (818) 888-8985 x 108 | F: (818) 975-9595
www.bbxsecurity.com | finance@bbxsecurity.com
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THIS E-MAIL (INCLUDING ANY ATTACHMENT) CONTAINS PRIVILEGED AND

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NOTE: This e-mail is from a law firm, Holland & Knight LLP (“H&K”), and is intended solely for the use of the individual(s) to whom it is
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preserve the attorney-client or work product privilege that may be available to protect confidentiality.

2
 

Exhibit C
Marie Mondia

Subject: FW: Request for Security

From: Michael Kane    
Sent: Wednesday, June 30, 2021 6:50 PM 
To: jodi paismontgomery.  
 
Subject: Re: Request for Security 
  
Jodi, 
  
Just to give you a quick update since my prior e‐mail.  Your safety is of paramount importance and in 
reviewing your request it wasn't clear to me if you have notified law enforcement.  If not, please report any 
such threats to law enforcement ASAP.  Second, Jamie has approved hiring an additional security guard 
effective immediately.  Let me know once they arrive or if you have any concerns in this regard.  Third, Jamie 
has requested a meeting with Sam & Bessemer to alert them of your concerns. Fourth, Jamie has requested 
that we put together a risk assessment analysis promptly, inclusive of implementation of recommended 
protocols.  Lastly, Jamie has requested that appropriate court approvals for the above be obtained as 
expeditiously as possible.. 
  
Please let me know if you need any additional assistance, 
  
Regards 
  
Michael Kane 
  

1
 PROOF OF SERVICE

RE: The Conservatorship of the Person and Estate of Britney Jean Spears
LASC Case No. BP108870
_____________________________________________________________________________________

I am employed in Los Angeles County. My business address is 130 South Jackson

St. Glendale, California 91205 I am over the age of 18 years, and I am not a party to this
cause.
On July 7, 2021 I served ☒ true and genuine copy(ies); ☐ the original(s) of
document(s) bearing the title(s):
EX PARTE PETITION FOR ORDER
AUTHORIZING AND INSTRUCTING CONSERVATOR(S) OF
THE ESTATE TO PAY FOR ADDITIONAL SECURITY EXPENSES; DECLARATION
OF LAURIANN WRIGHT RE: URGENCY AND NOTICE

on interested parties in this action as follows:

☐ (BY MAIL): I am readily familiar with the practices of the offices of Wright Kim
Douglas, ALC and the postal service to this building for collection and processing of
correspondence for mailing with the United States Postal Service. Such correspondence
is deposited with the United States Postal Service as indicated below on the same day in
the ordinary course of business. I placed the foregoing documents in a sealed envelope(s),
postage prepaid, addressed to the parties as indicated on the attached Service List, and
placed such envelope(s) for collection and mailing on this date following ordinary
business practices.
☒ (BY ELECTRONIC MAIL): I served the above-mentioned document
electronically on the parties listed on the attached E-Service List at the email addresses
shown below and, to the best of my knowledge, the transmission was complete and
without error in that I did not receive an electronic notification to the contrary.

**SEE ATTACHED SERVICE LIST**

I declare under penalty of perjury that the foregoing is true and correct. Executed
on July 7, 2021, at Glendale, California.

Vanessa Gonzalez X
Type or Print Name Signature
 SERVICE LIST

RE: The Conservatorship of Britney Jean Spears

LASC Case No. BP108870

Name & Address Status/ Relationship/ Phone/ Fax/ Email

Samuel D. Ingham, III Court Appointed Counsel for Conservatee

444 South Flower Street, Suite 4260
Los Angeles, CA 90071-2966 Tel: 310-556-9751
E: sam@inghamlaw.com
Yasha Bronshteyn Attorney for Lynne Spears
Ginzburg & Bronshteyn, LLP
11755 Wilshire Blvd., Ste 1250 Tel: 310-914-3222
Los Angeles, CA 90025 E: yasha@gbllp-law.com

Gladstone N. Jones, III Attorneys for Lynne Spears

Lynn E. Swanson Pro Hac Vice
Jones Swanson Huddell & Daschbach, LLC T: 504-523-2500
Pan-American Life Center E: gjones@jonesswanson.com
601 Pyodras Street, Suite 2655 Lswanson@jonesswanson.com
New Orleans, LA 70130

Geraldine A. Wyle Attorneys for James P. Spears

Jeryll S. Cohen
Freeman Freeman & Smiley, LLP Tel: 310-255-6100
1888 Century Park East, Suite 1500 E: geraldine.wyle@ffslaw.com
Los Angeles, CA 90067 jeryll.cohen@ffslaw.com

Vivian L. Thoreen Attorneys for James P. Spears

Jonathan H. Park
HOLLAND & KNIGHT LLP Tel: 213-896-2400
400 South Hope Street, 8th Floor E: vivian.thoreen@hklaw.com
Los Angeles, CA 90071 jonathan.park@hklaw.com

David C. Nelson Associated Counsel for Conservatee

Ronald Pearson
Loeb & Loeb LLP E: dnelson@loeb.com
10100 Santa Monica Blvd., Suite 2200 rpearson@loeb.com
Los Angeles, CA 90067
 Bruce S. Ross Attorneys for Bessemer Trust Company
Alan T. Yoshitake
Seyfarth Shaw LLP Tel: 213-170-9600
301 S. Figueroa Street, Suite 3300
Los Angeles, CA 90017 E: bross@seyfarth.com
ayoshitake@seyfarth.com

Bessemer Trust Company of California, Co-Conservator of the Estate

N.A.
ATTN: Jeff J. Glowacki, Western Regional E: glowacki@bessemer.com
Head
10250 Constellation Blvd., Suite 2600
Los Angeles, CA 90067

James P. Spears Co-Conservator of the Estate

[contact information withheld for privacy]