`IN COUNTY CLERK'S OFFICE
`PIERCE COUNTY, WASHINGTON
`
`May 14 2021 8:49 AM
`
`KEVIN STOCK
`COUNTY CLERK
`NO: 21-4-00956-4
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`eoCOSDBDWTAFFWHbw
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`10
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`11
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`2
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`11-12
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`Creditors have the right to open a probate. RCW 11.28.120(2) and
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`(6). Moreover, as the mother of the only heir she has a similar conflict of interest as well
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`as apparent bias against Aleta Benedicto, decedent’s mother, and Roberto Benedicto,
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`stepfather. She has an apparent bias against the decedent’s mother and stepfather.
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`Michelle Palazzo andis neither the mother nor the father of decedent.
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`3
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`I-11
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`This section is speculative and without supporting facts. This case
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`was
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`filed May 3, 2021, mailed to Ms. Palazzo on May3, 2021, and the Petition for
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`Order of Solvency mailed May 5, 2021.
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`3
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`13-19
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`This is a speculative, personal attack on Mr. & Mrs. Benedicto
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`with no actual facts supporting the claims. Ms. Palazzo presents no facts based on
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`personal knowledge of Benedictos’ financial help to their son nor of any actual
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`contributions to Lewis after she and Lewis divorced.
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`3&4 21-24; 1-3
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`Ms.Palazzo has no knowledge ofthe Jeep’s age, condition mileag
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`or other factors determining value. She has not offered to buy it which wouldatleast
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`provide an idea of her own valuation. She can have the vehicle appraised with a
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`representative of Lewis Palazzo present.
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`4
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`5-9
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`Ms. Palazzo has no personal knowledge of the Lewis Palazzo bank
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`accounts. She complainsthatfailure to consult with Owen Palazzo, an 11 year
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`old child who just lost his father. In what parallel] universe would that be reasonable or
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`appropriate?
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`RESPONSE TO MICHELLE PALAZZO’S OBJECTIONS;
`THOMAS FAUBION’S NOTICE OF APPEARANCE;
`NICOLE HANCOCK’S NOTICE OF APPEARANCE
`
`KRAM & WOOSTER,P.S
`1901 South I Street, Tacoma WA 9840
`(253) 272-7929; Fax (253) 572-416
`
`
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`ao~sSDBASelhUlhULNUUlU
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`Oo
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`22
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`23
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`25
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`4
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`10-12
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`Ms. Palazzo demonstrates no personal knowledge of the personal
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`assets of Decedent, does not demonstrate any particular bank account nor the ownership
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`of the alleged bank accounts. Certainly Ms. Palazzo does not suggest that any funeral or
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`last illness expenses were paid by her.
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`4
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`14-20
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`Settlement discussions are inadmissible under ER 408 and are
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`irrelevant.
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`5
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`4-7; 23
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`Ms. Palazzo supports the request for a probate GAL. Thisis nice
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`to hear because decedent’s non-probate 401k plan with his former employer holds
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`over $80,000 in it. The sole beneficiary is Owen Palazzo so the probate GAL would be in
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`a position and should review the plan, the beneficiary and exactly the funds would be
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`protected until his 1gih birthday. Ms. Palazzo never bothers to addressthis asset; a GAL
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`can and should.
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`5
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`9-18
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`Ms. Palazzo requests that nonintervention powers not be granted.
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`That increases the costs of the probate. Limited powers with respect to allow
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`the sale or transfer of personal effects, and autos should be granted. If bond is required
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`Petitioner should be allowed to use any estate assets to pay such bond. If Ms. Palazzois
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`appointed she should pay the bond from her own assets. No formalpetition for her
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`appointmenthas been filed with the requisite facts and estimated values and debts.
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`NOTICES OF APPEARANCE BY COUNSEL
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`Although both attorneys Nicole Hancock and Thomas Faubion work in the same
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`law firm, one that has a demonstrated ability to electronically file, each filed identically
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`wordednotices stating at page 2, Lines 5-6: “Further, this office does not accept service
`RESPONSE TO MICHELLE PALAZZO’S OBJECTIONS;
`KRAM & WOOSTER,P.S
`THOMAS FAUBION’S NOTICE OF APPEARANCE;
`1901 South I Street, Tacoma WA 9840
`NICOLE HANCOCK’S NOTICE OF APPEARANCE
`(253) 272-7929, Fax (253) 572-416
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`
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`of electronically filed documents.” This statement violate PCLGR 30(b)(5) which
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`requires electronic filing. There is no waiver identified in either Notice of Appearance as
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`required by PCLGR 30(5)(D). This unilateral change in the court rule needs to be
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`stricken from their notices of appearances. The other deficiencies in their notices of
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`appearance, items | through 7, will be addressed ata later time.
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`AANA
` 2)
`PETER KRAM WSBA 7436
`Attorney for Petitioner
`
`DATED: May14, 2021
`
`RESPONSE TO MICHELLE PALAZZ0’S OBJECTIONS;
`THOMAS FAUBION’S NOTICE OF APPEARANCE;
`NICOLE HANCOCK’S NOTICE OF APPEARANCE
`
`
`
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`
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`KRAM & WOOSTER,P.S
`1901 South I Street, Tacoma WA 9840
`(253) 272-7929, Fax (253) 572-416
`
`
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