Electronically FILED by Superior Court of California, County of Los Angeles 10/28/2021 3:37 PM Sherri R.

Carter, Executive Officer/Clerk, By Arianna Smith, Deputy Clerk

1 GREENBERG TRAURIG, LLP

MATHEW S. ROSENGART (SBN 255750) (RosengartM@gtlaw.com)
2 ERIC V. ROWEN (SBN 106234) (RowenE@gtlaw.com)
SCOTT D. BERTZYK (SBN 116449) (BertzykS@gtlaw.com)
3 LISA C. MCCURDY (SBN 228755) (McCurdyL@gtlaw.com)
MATTHEW R. GERSHMAN (SBN 253031) (GershmanM@gtlaw.com)
4 JANE H. DAVIDSON (SBN 326547) (DavidsonJa@gtlaw.com)
1840 Century Park East, Suite 1900
5 Los Angeles, CA 90067-2121
Tel: 310-586-3889
6 Fax: 310-586-7800

7 Attorneys for Conservatee Britney Jean Spears

9 SUPERIOR COURT OF THE STATE OF CALIFORNIA

10 COUNTY OF LOS ANGELES, CENTRAL DISTRICT
11

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

Estate of
13 Hon. Brenda J. Penny, Dept. 4
BRITNEY JEAN SPEARS,
14 CONSENT AND VERIFIED JOINDER OF
Conservatee. CONSERVATEE BRITNEY JEAN SPEARS TO:
15
JAMES P. SPEARS’ SEPTEMBER 7, 2021
16 PETITION FOR TERMINATION OF
CONSERVATORSHIP OF THE PERSON AND
17 ESTATE OF BRITNEY JEAN SPEARS
18 Date: November 12, 2021
Time: 1:30 PM
19 Dept: 4
20 (Ok to Set per 9/29 Order)
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CONSERVATEE BRITNEY JEAN SPEARS’S JOINDER IN PETITION TO TERMINATE
 1 1. Having previously filed her Consent on September 22, 2021, Britney Jean Spears,

2 Conservatee (“Ms. Spears”) hereby expressly joins in the Petition For Termination Of Conservatorship

3 Of The Person And Estate of Britney Jean Spears, filed on September 7, 2021, by then (now suspended)

4 Conservator of the Estate James P. Spears, to be heard on November 12, 2021 at 1:30 p.m (the “Verified

5 Termination Petition”). For all of the reasons in those filings, and pursuant to Ms. Spears’s own

6 impassioned and compelling June 23 and July 14 testimony, after more than a decade, the time has come

7 for Ms. Spears’s freedom.

8 2. Significantly, not only is the Verified Petition unopposed, but the suspended Conservator

9 of the Estate (Mr. Spears), the Temporary Conservator of the Estate, and the Conservator of the Person

10 Jodi Montgomery all consent to termination of the conservatorship on November 12, 2021.1

11 3. Indeed, as the Court heard during the September 29, 2021 hearing, Mr. Spears and his

12 counsel fought—vehemently and extensively—for immediate termination, as of that day. (See

Transcript of September 29, 2021 hearing, a true and correct copy of which is annexed hereto as Exhibit
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A.)
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4. Further, Mr. Spears’s September 7, 2021 Verified Termination Petition advocates that
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“recently things have changed,” and that “[i]f Ms. Spears wants to terminate the conservatorship and
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Mr. Spears’s new attorney has expressly acknowledged, in an email dated October 22, 2021, that “As
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far as Jamie is concerned, the conservatorship is done and can be terminated immediately . . . . So it is
19 said in no uncertain terms my client has no interest in continuing the conservatorship and I will join
in any effort to terminate immediately . . . ” (emphasis added).
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It is of no moment, presently, whether Mr. Spears’s reversal was motivated by a desire to bolster his
21 reputation or to avoid his deposition or responding to the outstanding discovery served on him in August.
See, e.g., Exhibits B and C, which are true and correct copies of Ms. Spears’s First Set of Requests For
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Production [Of Documents] to James P. Spears and First Set of Special Interrogatories to James P.
23 Spears, seeking, among other things, all documents regarding communications between Mr. Spears and
Tri Star; all documents regarding any agreements between Mr. Spears and Tri Star; all communications
24 regarding payments made to Tri Star, including “from assets of the [Estate];” “all payments or approvals
for payments” made from assets of the Estate for legal services rendered to Tri Star; “all companies,
25 corporations, or entities through which the Conservatorship Estate of Britney Jean Spears has in any way
26 operated;” and “all entities beneficially owned by you and through which you conducted or conduct
business or have received any monies as Conservator.” Although Mr. Spears must respond to discovery
27 and sit for his sworn deposition (see Exhibit D, a true and correct copy of the Notice of his Deposition),
he and his counsel are on record—plainly and unequivocally—testifying that the conservatorship should
28 end, with no evaluation, and these are Ms. Spears’s own clearly stated wishes, as she has testified.

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CONSERVATEE BRITNEY JEAN SPEARS’S JOINDER IN PETITION TO TERMINATE
 1 believes that she can handle her own life, Mr. Spears believes that she should get that chance.” (Verified

2 Termination Petition, ¶¶ 1, 3.) Ms. Spears fully agrees.

3 5. The Verified Termination Petition further concedes that:

In [authorizing Ms. Spears to select and hire her own counsel], this Court
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has recognized that Ms. Spears has both the capacity and capability to
5 identify, engage, and instruct counsel of her own choice, on her own,
without the assistance of the Conservator or the Court. If Ms. Spears has
6 the capacity and capability to engage counsel on her own, she presumably
has capacity and capability to handle other contractual and business
7 matters.
8 (Verified Termination Petition, ¶ 12.)
9 6. Additionally, and importantly, in addition to stating that circumstances have “clearly
10 changed,” Mr. Spears’s Verified Termination Petition itself further agrees and states, no less than three
11 times, that no mental or psychological evaluation is required under the Probate Code. (Verified
12 Termination Petition, Point Heading III, at p. 4, ¶¶ 9, 11, 14.) Once again, Ms. Spears fervently agrees.
13 7. Ms. Spears has made her wishes known about ending the conservatorship she has endured
14 for so long and she has pleaded with this Court to “let her have her life back,” without an evaluation,
15 recently attending two Court hearings and asking this Court directly to end the conservatorship. It is
16 respectfully submitted—with the consent of all parties—that the time has come.
17 CONCLUSION
18 For all of the foregoing reasons, Ms. Spears joins in and consents to the pending Verified Petition
19 for Termination of Conservatorship of the Person and Estate of Britney Jean Spears.
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21 Dated: October 28, 2021 Respectfully Submitted,

22 GREENBERG TRAURIG, LLP

23

24 By: /s Mathew S. Rosengart

Mathew S. Rosengart
25 Attorneys for Conservatee Britney Jean Spears

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CONSERVATEE BRITNEY JEAN SPEARS’S JOINDER IN PETITION TO TERMINATE
Exhibit A
Exhibit B
Exhibit C
Exhibit D
 1 GREENBERG TRAURIG, LLP
MATHEW S. ROSENGART (SBN 255750) (RosengartM@gtlaw.com)
2 ERIC V. ROWEN (SBN 106234) (RowenE@gtlaw.com)
SCOTT D. BERTZYK (SBN 116449) (BertzykS@gtlaw.com)
3 LISA C. MCCURDY (SBN 228755) (McCurdyL@gtlaw.com)
MATTHEW R. GERSHMAN (SBN 253031) (GershmanM@gtlaw.com)
4 JANE H. DAVIDSON (SBN 326547) (DavidsonJa@gtlaw.com)
1840 Century Park East, Suite 1900
5 Los Angeles, CA 90067-2121
Tel: 310-586-3889
6 Fax: 310-586-7800

7 Attorneys for Conservatee Britney Jean Spears

9 SUPERIOR COURT OF THE STATE OF CALIFORNIA

10 COUNTY OF LOS ANGELES, CENTRAL DISTRICT

11

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

Estate of
13 Hon. Brenda J. Penny, Dept. 4
BRITNEY JEAN SPEARS,
14 NOTICE OF DEPOSITION OF JAMES P.
Conservatee. SPEARS AND REQUEST FOR PRODUCTION
15 OF DOCUMENTS
16
[RE: PETITION FOR SUSPENSION AND
17 REMOVAL OF JAMES P. SPEARS AS
CONSERVATOR OF THE ESTATE]
18
Date: October 20, 2021
19 Time: 10:00 a.m.
20 Place 1840 Century Park East, Suite 1900,
Los Angeles, CA 90067
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1
NOTICE OF DEPOSITION OF JAMIE SPEARS
ACTIVE 59372803v1
 1 TO ALL PARTIES HEREIN AND THEIR RESPECTIVE ATTORNEYS OF RECORD:

2 PLEASE TAKE NOTICE that Conservatee Britney Jean Spears (“Conservatee”) pursuant to

3 Section 2025.210 et seq. of the Code of Civil Procedure, will take the deposition on oral examination of

4 James P. Spears, Suspended Conservator of the Estate. The deposition will commence on October 20,

5 2021, at 10:00 a.m. at 1840 Century Park East, Suite 1900, Los Angeles, California 90067, before a

6 notary public or certified shorthand reporter authorized to administer oaths in the State of California. The

7 deposition will continue thereafter from day to day, Saturdays, Sundays and holidays excepted, until

8 complete, subject to any applicable time limitations in the Code of Civil Procedure.

9 NOTICE IS FURTHER GIVEN that, pursuant to California Code of Civil Procedure sections

10 2025.220, 2025.330, 2025.340 and 2025.620, Conservatee reserves the right to record the deposition by

11 audio and video and further reserves the right to use the same at trial. The deposition testimony will be

12 reported stenographically, and Conservatee may use instant visual display or real-time transcription of

13 the testimony.

14 NOTICE IS FURTHER GIVEN that, pursuant to California Code of Civil Procedure Sections

15 2025.220(a)(4) and 2025.280(a), the deponent is required to produce the documents, records, and other

16 materials described below, which are in his possession, custody, or control, or the possession, custody, or

17 control of any of his agents, representatives, and/or attorneys on or before the date and time set forth for

18 the deposition.

19 DEFINITIONS AND INSTRUCTIONS

20 1. The term “DOCUMENT(S)” means all forms of tangible expression, including all

21 “writings” as defined by California Evidence Code § 250, and further including, without limitation,

22 computer diskettes, computer electronic mail, and any retrievable data or information, however stored,

23 recorded or coded. The term DOCUMENT(S) shall incorporate the original and duplicate copies of any

24 “writing,” as well as any writing that served as a recorded recollection of any COMMUNICATION.

25 2. The term “COMMUNICATION” is used in its broadest sense and includes, the

26 transmission of information in any form (whether by way of facts, ideas, questions, opinions, or

27 otherwise), between or among any persons or entities, including, without limitation, written, oral, or

28 electronic transmissions, such as telephone conversations, letters, memoranda, notes, e-mails, summaries,
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NOTICE OF DEPOSITION OF JAMIE SPEARS
ACTIVE 59372803v1
 1 photographs, motion pictures, television shows, audio tapes, video tapes, computer or other electronic

2 telecommunications, text messages, electronic or magnetic media, facsimiles, electronic mail, telegrams,

3 press releases, and newspapers.

4 3. The terms “RELATING TO” or “RELATED TO” means concerning, pertaining to,

5 referring to, describing, mentioning, containing, evidencing, constituting, dealing with, discussing,

6 considering, analyzing, studying, reporting on, commenting on, setting forth, supporting, recommending

7 or otherwise concerning in any manner, in whole or in part, whatsoever the subject matter of the inquiry.

8 4. As used herein, the term “all” includes “any” and vice versa.

9 5. Whenever appropriate, the singular form of a word shall be interpreted in the plural, or

10 vice versa; verb tenses shall be interpreted to include past, present and future tenses; and these terms shall

11 he construed in the broadest sense as necessary to bring within the scope of these requests that which

12 might otherwise be construed to be outside their scope.

13 6. All DOCUMENTS are to be produced in the files in which such DOCUMENTS have

14 been maintained and in the order within each file in which such DOCUMENTS have been maintained.

15 7. If any DOCUMENT(S) are withheld from production on the basis of a claim of attorney-

16 client or any other privilege, or on the basis of the attorney work-product doctrine, you must set forth

17 with specificity the privilege or work product claim and furnish a list identifying each DOCUMENT for

18 which the privilege or work product doctrine is claimed, together with:

19 a. a brief description of the nature and subject matter, including the title and type of

20 the document;

21 b. the date of preparation;

22 c. the name and title of the author(s);

23 d. the name and title of the addressee(s);

24 e. the name and title of all PERSONS to whom the DOCUMENT was sent, including

25 blind carbon copies;

26 f. the number of pages;

27 g. the DOCUMENT request(s) to which the withheld information or DOCUMENT is

28 otherwise responsive; and

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NOTICE OF DEPOSITION OF JAMIE SPEARS
ACTIVE 59372803v1
 1 h. the complete basis upon which you contend that you are entitled to withhold the

2 information or DOCUMENT from production

3 REQUESTS FOR PRODUCTION

4 REQUEST FOR PRODUCTION NO. 1:

5 All DOCUMENTS and COMMUNICATIONS RELATING TO the electronic surveillance,

6 monitoring, cloning, or recording of the activity of Britney Jean Spears’ personal telephone, including but

7 not limited to the surveillance, monitoring, cloning, icloud mirroring, or recording of calls, e-mails, text

8 messages, internet browser use or history, and social media use or direct messages on social media.

9 REQUEST FOR PRODUCTION NO. 2:

10 All DOCUMENTS and COMMUNICATIONS RELATING TO any recording or listening device

11 in the home or bedroom of Britney Jean Spears, including all DOCUMENTS and COMMUNICATIONS

12 relating to the decision to place any such recording or listening device and the records of any such

13 recordings.

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15 Dated: October 1, 2021 GREENBERG TRAURIG, LLP

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17 By: /s/ Mathew 4. Rosengart

MATHEW S. ROSENGART
18 Attorneys for Conservatee Britney Jean Spears
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NOTICE OF DEPOSITION OF JAMIE SPEARS
ACTIVE 59372803v1
 1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

3 I am employed in the aforesaid county, State of California; I am over the age of 18 years and not a
party to the within action; my business address is 1840 Century Park East, Suite 1900, Los Angeles,
4 CA 90067-2121. My email address is davidsonja@gtlaw.com.
5
On October 28, 2021, I caused the document(s) described as: &216(17$1'VERIFIED
6 JOINDER OF CONSERVATEE BRITNEY JEAN SPEARS TO JAMES P. SPEARS’
SEPTEMBER 7, 2021 PETITION FOR TERMINATION OF CONSERVATORSHIP OF THE
7 PERSON AND ESTATE OF BRITNEY JEAN SPEARS a to be transmitted to the addressee(s) listed
on the attached Service List by electronic mail at the e-mail address(es) set forth herein.
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(BY E-SERVICE) I caused the document(s) to be sent to the person(s) at the e-mail address(es)
9 indicated on the attached service list.
10
(BY MAIL) I am readily familiar with the business practice of my place of employment with
11 respect to the collection and processing of correspondence, pleadings, and notices for delivery by
mail. On the same day that correspondence is placed for collection and mailing, it is deposited in
12 the ordinary course of business with the United States Postal service in a sealed envelope with
postage fully prepaid.
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14 (STATE) I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
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16 Executed on October 28, 2021, at Los Angeles, California.

17
___/s/ Jane H. Davidson______________________
18 Jane H. Davidson

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PROOF OF SERVICE
ACTIVE 60973708v1
 1
SERVICE LIST
2 CASE BP108870
3
Alex Weingarten Attorneys for James P. Spears, Suspended
4 Wilkie Farr & Gallagher, LLP 2029 Century Park East, Conservator of the Estate
Suite 400 Los Angeles, CA 90067
5 Email; aweingarten@wilkie.com
ebakewell@wilkie.com
6

7 Vivian L. Thoreen Former Attorneys for James P. Spears,

Jonathan H. Park Suspended Conservator of the Estate
8 HOLLAND & KNIGHT, LLP
400 S. Hope Street, 8th Floor
9 Los Angeles, CA 90071
Tel: 213-896-2400
10
Fax: 213-896-2450
11 Email: vivian.thoreen@hklaw.com
jonathan.park@hklaw.com
12

13 Geraldine A. Wyle Former Attorneys for James P. Spears,

Jeryll S. Cohen Suspended Conservator of the Estate
14
FREEMAN FREEMAN & SMILEY, LLP
15 1888 Century Park East, Suite 1500
Los Angeles, CA 90067
16 Email: Geraldine.wyle@ffslaw.com
Jeryll.cohen@ffslaw.com
17

18 Yasha Bronshteyn Attorneys for Lynne Spears, Mother of

19 GINZBURG & BRONSHTEYN, LLP Conservatee
11111 Santa Monica Blvd., Suite. 1840
20 Los Angeles CA 90025
Tel: 310-914-3222
21 Email: yasha@gbllp-law.com
22

23 Gladstone N. Jones, III Attorneys for Lynne Spears, Mother of

Lynn E. Swanson Conservatee
24 JONES SWANSON HUDDELL & GARRISON, LLC
Pan-American Life Center
25 601 Pyodras Street, Suite 2655
New Orleans, LA 70130
26 Tel: 504-523-2500
27 Email: gjones@jonesswanson.com;
lswanson@jonesswanson.com
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PROOF OF SERVICE
ACTIVE 60973708v1
 1 Justin B. Gold, Esq. Attorneys for John Zabel, Conservator of the
Oldman, Cooley, Sallus, Estate
2 Birnberg, Coleman & Gold LLP
3 16133 Ventura Boulevard, Penthouse Suite Encino,
California 91436-2447 Telephone: (818) 986-8080
4 Fax: (818) 789-0947
jgold@oclslaw.com
5
Lauriann C. Wright Attorneys for Jodi Montgomery, Conservator
6
Marie Mondia of the Person
7 WRIGHT KIM DOUGLAS, ALC
130 S. Jackson Street
8 Glendale, CA 91205-1123
Tel: 626-356-3900
9 Email: lauriann@wkdlegal.com
marie@wkdlegal.com
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11
Bryan Spears Sibling of Conservatee
12 [Address on file with the Court]
Jamie Lynn Spears Sibling of Conservatee
13 [Address on File with the Court
Kevin Federline Father of minor children and minor children
14
Sean Preston Federline and Jayden James Federline
15 c/o Kevin Federline
[Address on file with the Court]
16
Court Investigator’s Office Court Investigator
17 Los Angeles Superior Court
18 111 N. Hill Street, Room 250
Los Angeles, CA 90012
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PROOF OF SERVICE
ACTIVE 60973708v1