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ENDORSED
SCOTT J. JUDSON (SBN: 287135) N4 MAR 18 PH 3: 06
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BOLD, POLISNER, MADDOW, NELSON& JUDSON PROBATE

A Professional Corporation CURERIR COURTOF C2Lir omm
520 Capitol Mall, Suite 150 CRAMENTO
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Sacramento, CA 95814
Telephone: 916.933.7511
Facsimile: 916.933.7522
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E-mail: sjudson@bpmnj.com
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Attorneys for Petitioner,

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CHRISTOPHER J. BAKES
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SUPERIOR COURT OF THE STATE OF CALIFORNIA

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IN AND FOR THE COUNTY OF SACRAMENTO

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In the Matter of: Case. No.: 34-2020-00283997

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JOHN J. BAKES DECLARATION OF SCOTT J. JUDSON

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IN SUPPORT OF ORDER AFTER

HEARING
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BY FAX
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I, SCOTT J. JUDSON, declare as follows:

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1. I am counsel of record in this matter for CHRISTOPHER J. BAKES. I am over

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18 years of age. I have personal knowledge of the facts outlined in this declaration and, if called
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upon as a witness, I could and would competently testify thereto.

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2 Following the hearing on March 12, 2023, I prepared the attached Order After
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Hearing and sent it to counsel and the parties for review.

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k A Counsel for BARBARA “DOLLY” BAKES approved the order as to form and
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has signed the order being submitted.

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4. MATTHEW BAKES did not respond to my e-mail dated March 13, 2023
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providing a copy of the order to him to review. A true and correct copy of my e-mail to
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MATTHEW BAKES is attached hereto as Exhibit A.

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In the Matter of John J. Bakes Case No.: 34-2020-00283997

DECLARATION OF CHRISTOPHER J. BAKES Page 1
 S, Pursuant to California Rule of Court 3.1312, I request that the Court execute this
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Order After hearing so that we can sell the real property.

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I declare under penalty of perjury, under the laws of the State of California, that the
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foregoing is true and correct, and that this Declaration was executed on this day, March 18, 2024

in Sacramento, California.
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COTT J. SO]
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In the Matter of John J. Bakes Case No.: 34-2020-00283997

DECLARATION OF CHRISTOPHER J. BAKES Page 2
 EXHIBIT A
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E-MAIL TO MATTHEW BAKES WITH ORDER

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In the Matter of John J. Bakes Case No.: 34-2020-00283997

DECLARATION OF CHRISTOPHER J. BAKES Page 3
Scott Judson

From: Scott Judson

Sent: Wednesday, March 13, 2024 4:48 PM
To: Matthew Bakes
Cc: Miller-Caballero, Krystan; Hubbard, Tyson
Subject: Bakes - Order After Hearing
Attachments: 2024.03.13 Order after hearing (DB Approved).pdf

Mr. Bakes,

Pursuant to California Rule of Court 3.1312, attached please find the proposed Order After Hearing that | have prepared
and counsel for Barbara Bakes has approved following yesterday’s hearing. If you approve this order as to form, | ask
that you please sign the third page under the already-affixed signature for Ms. Miller-Caballero so that | can get this
submitted to the Court.

Thank you,

SCOTTJ. JUDSON, ESQ.

Bold, Polisner, Maddow, Nelson & Judson
A Professional Corporation
520 Capitol Mall, Suite 150, Sacramento, CA 95814
Phone: (916) 933-7511
Fax: (916) 933-7522
E-mail: Sjudson@bpmnj.com

The information contained in this transmission may contain privileged and confidential information. If you are not the intended recipient, please
contact the sender by reply e-mail and destroy all copies of the original message. IRS
Circular 230 Disclaimer. Any tax advice contained in this
communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties
under the Internal Revenue Code or (ii) promoting, marketing, and/or recommending to another party any transaction or matter addressed herein.
 SCOTT J. JUDSON (SBN: 287135)
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BOLD, POLISNER, MADDOW, NELSON & JUDSON

A Professional Corporation
520 Capitol Mall, Suite 150
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Sacramento, CA 95814
Telephone: 916.933.7511
Facsimile: 916.933.7522
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E-mail: sjudson@bpmnj.com
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Attorneys for CHRISTOPHER J. BAKES

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

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IN AND FOR THE COUNTY OF SACRAMENTO

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In the Matter of: Case. No.: 34-2020-00283997

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JOHN J. BAKES ORDER AFTER HEARING

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Date: March 12, 2023

Time: 9:00 am.
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Dept: 129
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The Petition for Letters of Administration filed by MATTHEW BAKES, The Petition for
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Partition filed by CHRISTOPHER J. BAKES, the Petition for Letters of Administration filed by
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CHRISTOPHER J. BAKES, and the Petition to 1. Determine The Lack of Existence of a Trust
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Due To Revocation; 2. For Attorneys’ Fees; and 3. For Damages filed by CHRISTOPHER J.
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BAKES came on for hearing on March 12, 2024, in Department 129 of the Sacramento County
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Superior Court in this consolidated matter.

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CHRISTOPHER J. BAKES appeared through his counsel SCOTT J. JUDSON, ESQ. of

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BOLD, POLISNER, MADDOW, NELSON & JUDSON, A Professional Corporation, via

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remote appearance. MATTHEW BAKES appeared in pro per. BARBARA “DOLLY” BAKES
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appeared through her counsel KRYSTAN MILLER-CABALLERO, ESQ. of DOWNEY

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BRAND, LLP via remote appearance. No other parties appeared despite proper notice being
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In the Matter of John J. Bakes Case No.: 34-2020-00283997

ORDER AFTER HEARING Page 1
 given.
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The Court, having read the pleadings and other documents filed herein to date, and after
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hearing oral argument issues the following Orders:

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1. The Court’s order dated December 21, 2023 is confirmed.

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2 The appointment of CHRISTOPHER J. BAKES as the Special Administrator of

the Estate of JOHN J. BAKES for the purposes of listing and selling the real property located at
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4130 61st Street in Sacramento is confirmed and extended until May 14, 2024.
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3. As Special Administrator, CHRISTOPHER J. BAKES has the sole authority to

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list and sell the real property located at 4130 61 Street in Sacramento on behalf of Decedent
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JOHN J. BAKES, the Estate of JOHN J. BAKES, and THE JOHN J. BAKES LIVING TRUST
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and/or MATHEW BAKES.

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4. The Court shall issue new Letters of Special Administration.

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5i All parties (family and any purported trustee) shall cooperate with agents,
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inspectors, and appraisers.

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6. MATTHEW BAKES shall not in any way interfere with the sale of the real
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property located at 4130 61st Street in Sacramento. MATTHEW BAKES shall not contact any
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realtors nor title companies regarding the sale of the real property located at 4130 61st Street in
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Sacramento
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7 The proceeds from the sale of the real property located at 4130 61st Street in
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Sacramento shall be distributed pursuant to title. Any proceeds from the sale of the real property
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located at 4130 61st Street in Sacramento designated for Decedent JOHN J. BAKES, the Estate
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of JOHN J. BAKES, any purported trustee of any alleged trust of Decedent and/or MATTHEW
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BAKES, including but not limited to any interests that were once in THE JOHN J. BAKES
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LIVING TRUST, shall be distributed into a blocked account opened by the Special
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Administrator.
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In the Matter of John J. Bakes Case No.: 34-2020-00283997

ORDER AFTER HEARING Page 2
 8. All matters are continued until May 14, 2024 at 9:00 a.m. in Department 129 of
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this Court to report on status of the sale of the real property located at 4130 61st Street in
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Sacramento and to set all matters in this consolidated case for trial.

Dated:
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JUDGE OF THE SUPERIOR COURT

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Approved as to form:
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DOWNEY ,BRAND, LLP

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Dated: March 13.2024 N m(/

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KRYJTAN MILLER-CABALLERO
Attorneys for Barbara “Dolly” Bakes
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Dated:
MATTHEW BAKES
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In the Matter of John J. Bakes Case No.: 34-2020-00283997

ORDER AFTER HEARING Page 3