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Trustee of the Elvin R Meek Family Trust Dated 1996 Filed August 14, 2009 for the following reasons: I. BACKGROUND The objections to Elizabeth’s misreprentation of the trust intentions have been previously described in our Petition Declaring the 1st Amendment to be Invalid (filed August 14, 2009) and Answers thereto filed November 12, 2009). II. ARGUMENT In her answers to our Petition Elizabeth Meek sets forth her reasons for denying our Petition for her removal and we will address those arguments accordingly: A. Elizabeth and Her Attorney Have Been Noncommunicative During the Last Five Years of Litigation These arguments have been previously addressed in our Response to Elizabeth’s Response to our Petition Declaring the 1st Amendment Invalid (filed November 12, 2009) B. Wes Stewart’s Hearsay Letter and Affidavit These arguments have been previously addressed in our Response to Elizabeth’s Response to our Petition Declaring the 1st Amendment Invalid (filed November 12, 2009) Elizabeth’s claims that the Affidavit prepared by Attorney Richard Diehl and signed by Wes Stewart are false and baseless. The Affidavit

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notarized and signed has been submitted to the court several times. C. Nanci’s April 2002 Meeting with Elvin Meek These arguments have been previously addressed in our Response to Elizabeth’s Response to our Petition Declaring the 1st Amendment Invalid (filed November 12, 2009). Elizabeth was present at that time and was well aware of the pending dissolution of the relationship between my father and herself. Any claims otherwise are baseless and without merit and merely a vehicle for Elizabeth Meek to justify her actions isolating our father from his friends and family. As confirmed by the Accounting prepared by East West Wealth Management Elizabeth Meek withdrew $182,000 from a joint account held by herself and my father on the morning before he passed away, October 19, 2003. Her phone records show she contacted several of her friends and family on this date, however did not contact anyone in our family including my father’s brothers in California, myself, Elvin’s son Melvin, nor his granddaughter Nicole Kusley. D. Arguments in Nanci’s Petition for Declatory Relief 1. Physical appearance of the First Amendment We stand by our suspicions regarding the First Amendment based on recent forensics and Elizabeth Meek’s own admission that the 1st Amendment signed in California does not bear her 3

signature. According to Reed Hayes, the forensics expert with whom we consulted, unaligned paragraphs, contrasting fonts etc is a legitimate basis to invalidate a document and thus basis to remove Elizabeth as Trustee. 2. Nanci admits that Elvin Meek executed a document on September 16, 1997 As presented to the court by my own admission, I spoke with notary Susan Strong and obtained a copy of her notary book showing an entry reading simply “customers of Heidi Trust document” dated September 16, 1997. The pages introduced by Attorney Robert Jones, the same attorney who by his own admission and contradicing his 2005 Affidavit stated he made an “erroneous Assumption” regarding what we have proven through forensics to be a fraudulent signing of the Amendment in California. The pages on both 1st Amendments are not numbered and the 21 pages are out of alignment with each other, leading us to conclude that both the 1st Amendment signed in California as well as the document supposedly signed in Hawaii are not the operative document. We are of the opinion there was a 1st Amendment however it is not the same document introduced to the court by Attorney Robert Jones. 3. Eliabeth and Bank of Hawaii as trustees We stand by our original argument that our father would not have appointed the Bank of Hawaii as co-trustee only 1 and a 4

half years after executing his original 1996 trust. Our father being an attorney and responsible for executing the documents of others, was fully aware that Elizabeth after living in the United States for over 23 years was not an American Citizen. Having been an accountant before becoming an attorney, my father was well aware of the tax consequences involved and the need to appoint as co-trustee a United States Citizen to assist Elizabeth in dissolving properties. However, both my brother and myself are United States citizens. Therefore it is inconceivable he would have enlisted a financial institution to briefly act as trustee as was the case with the Bank of Hawaii. The Bank of Hawaii accepted appointment as trustee of the Exemption Trust and the Qualified Domestic Trust at the request of Attorney Robert Grigger Jones. Given the background and many allegations of fraud currently tied to Attorney Robert Grigger Jones it is our contention that Attorney Jones crafted the 1st Amendment as he has introduced it to the court after our father’s death in an effort to support his intentions. 4. The 1996 Trust Agreement does not mention QDOT Trust I apologize for my error. The 1st Amendment as drafted by Attorney Robert Grigger Jones mentions the QTIP and not the QDOT Trust. Attorney Robert Grigger Jones set into motion litigation in the California courts in September of 2004 to 5

establish the QDOT Trust. I recognize as will the court the similarities to the QDOT and QTIP provisions within a trust designed to eliminate tax consequences. 5. The California “probate” Attorney Robert Jones did in fact file a probate proceeding in San Bernardino, California while attempting to sell the properties in Rialto, California and we believe in anticipation of selling the properties in Big Bear, Crestline and Hesperia, California. Attorney Jones also opened a probate in Arkansas preparing to sell the property which rendered a judgment against the estate (see Exhibit “A”) as outlined in the Affidavit of Russel Nowell, who has been and is currently acting as the legal instrument for the Havens estate. Attorney Robert Jones is only licensed to practice law in California. While Elvin Meek passed away in Hawaii and had been a resident of Hawaii since 1996 we suspect attorney Robert Jones proceedings in the California courts are suspicious and self serving. Also Robert Jones was fully aware that Elizabeth Meek began immigration proceedings with Attorney Jim Stanton which would enable her to obtain United States citizenship prior to Robert Jones filing the QDOT provision motions in California. It should be noted the law firm of Clay Chapman was hired by myself after the litigation was moved from California to Hawaii in September of 2005. Clay Chapman were partners with Attorney Jim Stanton and 8 months after 6

filing our civil complaint the conflict of interest was revealed and thus Clay Chapman had to withdraw as my representation. 6. The sale of California properties

As to Elizabeth’s arguments that the properties were sold without informing myself or my brother are false and baseless. Attorney Jones has never contacted myself or my brother regarding the sales of any or the properties listed in our father’s estate. Furthermore, Attorney Robert Jones initiated contact with the City of Rialto as far back as September of 2004 as is evidenced in the minutes of the City of Rialto council meeting previously submitted to the court. The property was sold undervalue and property comparatives already submitted to the court have already proved the property in Rialto, the property in Hesperia as well as the property at the Waipuna were sold undervalue. This issue has been raised in the past and is documented. Attorney Robert Jones and Elizabeth Meek have been determined to have the estate remain undervalue in an effort to avoid paying taxes on the estate. The Respondent and her attorneys have maintained value of the estate to be between $2.7 and $2.8 million plus the $1 million Exemption trust which they assert at times has already been funded and at times admit the $1 million Exemption trust was never funded. It is this inconsistency which again leads us to believe Elizabeth

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Meek’s has not been forthright and honest in administering the estate. 7. Inconsistencies in amendments As to the Inconsistencies in the amendments addressed, we would have to argue that Elizabeth Meek while acting as trustee had a responsibility to be truthful and forthright with respect to the validity of the 1st and 2nd amendments, by isolating family members, assisting our father who was proven by medical forensics expert Suzanne Kelb, Phd. to have been 100 % incapacitated during the signing of the 2nd Amendment and the pour over Will, with full knowledge of his terminal and weakened condition. and by colluding with Attorney Robert Grigger Jones, not admitting the 1st Amendments were false and fraudulent documents until after we had the documents scrutinized by Reed Hayes, a qualified document forensics expert is enough to have her removed as trustee of the estate. 8. Elizabeth is not sufficiently communicative This argument has been addressed in the Response to Elizabeth’s Response to our Petition Declaring the 1st Amendment Invalid (filed November 12, 2009) 9. Robert Jones is not sufficiently communicative This argument has been addressed in the Response to Elizabeth’s Response to our Petition Declaring the 1st Amendment Invalid (filed November 12, 2009) 8

10. Letter and affidavit of Wesley Stewart This argument has been addressed in the Response to Elizabeth’s Response to our Petition Declaring the 1st Amendment Invalid (filed November 12, 2009) 11. Nanci’s April 2002 meeting with Elvin Meek This argument has been addressed several times, most recently in the Response to Elizabeth’s Response to our Petition Declaring the 1st Amendment Invalid (filed November 12, 2009). Elizabeth was present at that meeting/dinner in San Bernardino, California. III. CONCLUSION

The arguments included in Elizabeth Meek’s Response to our Petition for Removal of Elizabeth Meek as trustee are baseless, false and selfmotivated. We argue that the facts presented before the court support our petition to remove Elizabeth Meek as current trustee of the Elvin R Meek 1996 Trust. We vehemently deny her assertion that we stated we would withdraw any further efforts to contest the matter if the document is produced. We stated we would deny any further claims if the 1st Amendment were validated. It was not. Quite to the contrary, it was in fact proven to be false, a fraud and Elizabeth Meek herself asserts and agrees the signatures on the amendment signed in California are not hers. This only leads us to question the pages preceding the signature page from the 1st Amendment signed in Hawaii. 9

Therefore we pray the court will do the following: 1. Remove Elizabeth Meek as current Trustee. 2. Re-Appoint Nanci L. Meek-Kusley, who was named trustee in the original Elvin R Meek Family Trust executived June 14, 1996 , as acting trustee as set forth on page 9 Article V which reads as follows: 5.1 Death of Trustee: In the event that the initial trustee, ELVIN R. MEEK, fails to qualify or ceases to act as a trustee, as a result of death, resignation or inability to act as trustee, then the following will act as trustees in the following order as the following property in the succession stated: NANCY LORRAINE MEEK KUSLEY as Trustee. In the event that NANCY LORRAINE MEEK KUSLEY fails to qualify or ceases to act as trustee as a result of death, resignation or inability to act as trustee, then MELVIN RAY MEEK shall act as Trustee for the purposes of administering this Trust. 3. The court acknowledge the original Elvin R Meek Family Trust executed on June 14, 1996 as the operable and valid instrument and allow the estate to be dissolved and distribution to be completed as set forth on page 4 which reads as follows: 3.02.2 Distribution of Trust Estate On the death of the Trustor, after payments made pursuant to paragraph 3.02.01 above, the successor trustee(s) shall distribute the trust estate free of trust as follows: One share equaling 1/3 of the trust estate to NANCY LORRAINE MEEK-KUSLEY, or her issue. One Share equaling 1/3 of the trust estate to MELVIN RAY MEEK, or to his issue. One half share equaling 1/6 of the trust estate to ELIZABETH A. MEEK, or her issue. One half share equaling 1/6 of the trust estate to LOLA DEE MEEK, or her issue.

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4. The judgment entered in Arkansas against the estate for the wrongful sale of property by Elizabeth Meek and Attorney Robert Grigger Jones owned by the Havens family be paid by Elizabeth Meek and Robert Grigger Jones respectively and independently of the trust. 5. The court order Elizabeth Meek to reimburse to the trust monies already paid to attorneys for the Bank of Hawaii in Hawaii (Goodsill, Anderson, Quinn and Stiffel) as well as attorney Jane Peebles who represented the Bank of Hawaii in California during the IRS tax audit of the estate. 6. Reimburse Nanci Meek for costs incurred as and for attorney fees, travel expenses, and costs during the last 5 years in the amount of $58,783.27. DATED: November 12, 2009, Honolulu Hawaii

Nanci Meek Petitioner Self Represented

IN THE CIRCUIT COURT OF THE FIRST CIRCUIT STATE OF HAWAII IN THE MATTER OF THE ELVIN R MEEK FAMILY TRUST ) 11 ) ) ) T. No. 05-1-0101 CERTIFICATE OF SERVICE

DATED JUNE 14, 1996, AS AMENDED ) _______________________________ ) CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the RESPONSE TO ELIZABETH MEEK’S MOST RECENT RESPONSE TO PETITION FOR REMOVAL OF ELIZABETH MEEK AS TRUSTEE OF ELVIN R. MEEK FAMILY TRUST DATED 1996 FILED AUGUST 14, 2009 RE-APPOINTMENT OF NANCI MEEK,ORIGINAL TRUSTEE OF 1996 TRUST; EXHIBITS A-C and attachments was duly served again upon the following individuals by depositing the same in the United States Mail, postage prepaid addressed as follows: (All parties were served from Hawaii via e mail on November 12, 2009) LOLA DEE MEEK (REKLAI) previous E mail P.O. Box 7042 Koror, Palau 96940 Lola@ palaunet.com MELVIN RAY MEEK previous E mail 1633 E Chaparral Drive Casa Grande AZ 85222 MelvinMeek@yahoo.com Robert M Jones Esq mail 8655 Morro Road Suite C Atascadero CA 93422 Attorney for ELIZABETH A MEEK in California grigger@robertmjones.com DATED: Las Vegas, Nevada November 16, 2009 BY MAIL and

BY MAIL and

BY MAIL and previous E

Nanci L Meek, in pro se

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