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MATTHEW F. BAKER (BAR NO.

293779)
1 matthew.baker@saul.com
ROSHANNE C. KATOUZIAN (BAR NO. 307134)
2 roshanne.katouzian@saul.com
SAUL EWING LLP
3 1888 Century Park East, Suite 1500
Los Angeles, California 90067
4 Telephone: (310) 255-6100
Facsimile: (310) 255-6200
5
Attorneys for Ronald Stoffers,
6 Special Administrator of the
Estate of Marsha Claire Ross
7

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA


9 COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10
1888 CENTURY PARK EAST, SUITE 1500

11 In re the Matter of the Estate of Case No. 21STPB04567


LOS ANGELES, CALIFORNIA 90067

12 MARSHA CLAIRE ROSS,


LLP

DECLARATION RE: URGENCY OF


13 PRIORITY TO FILE ORDER AFTER
(310) 255-6100
SAUL EWING

Decedent. HEARING
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[Filed concurrently with Order After Hearing]
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DECLARATION RE URGENCY
1 DECLARATION OF MATTHEW F. BAKER

2 I, Matthew F. Baker, declare as follows:

3 1. I am an attorney duly licensed to practice before all of the courts in the State of Cali-

4 fornia. I am a partner at Saul Ewing LLP, counsel of record for Ronald Stoffers in this action. I

5 have personal knowledge of the facts set forth in this Declaration and, if called as a witness, could

6 and would competently testify to such facts under oath.

7 2. Proceedings concerning this estate were first initiated on May 10, 2021.

8 3. Mr. Stoffers’ Letters of Special Administration, first issued on February 8, 2023,


9 will expire on April 30, 2024.

10 4. The court-executed Order After Hearing is necessary for Mr. Stoffers to make dis-
1888 CENTURY PARK EAST, SUITE 1500

11 tributions to the beneficiaries pursuant to the Settlement Agreement before April 30.
LOS ANGELES, CALIFORNIA 90067

12 5. A delay in the Order After Hearing will result in additional delays in transferring
LLP

13 the administration to Michael Ross, and thus further delays in an administration that has already
(310) 255-6100
SAUL EWING

14 suffered long delays.

15 6. I respectfully request that the Court give the concurrently-filed Order After Hearing

16 filing priority in light of the urgency set forth above.

17 I declare under penalty of perjury under the laws of the State of California that the foregoing

18 is true and correct to the best of my knowledge.

19 Executed on this __th day of April, 2024, at Los Angeles, California.

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21 Matthew F. Baker
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DECLARATION RE URGENCY

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