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IN THE CIRCUIT COURT OF THE FIRST CIRCUIT STATE OF HAWAII

THE MATTER OF ) T. NO. 05-1-0101 ) THE ELVIN R. MEEK FAMILY ) TRUST, DATED JUNE 14, ) 1996 AS AMENDED. ) ) _________________________)

DEPOSITION OF ELIZABETH MEEK Taken on behalf of the Petitioner in Pro Se pursuant to Notice, on Friday, May 28, 2010, commencing at 10:00 a.m., at the Law Offices of Cades Schutte, LLP, 1000 Bishop Street, Suite 1200, Honolulu, Hawaii 96813.

Ali'i Court Reporting 956 Uwao Street Honolulu, Hawaii 96825 (808) 394-Alii (2544)

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APPEARANCES: For Petitioner in Pro Se:

3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 -o0o21 REPORTED BY: Laura Savo, CSR No. 347 Notary Public, State of Hawaii NANCI MEEK 3308 Ariba Street Las Vegas, Nevada 89129 (760) 413-5660 For Elizabeth Meek: JAMES ASHFORD, ESQ. Cades Schutte, LLP 1000 Bishop Street, Suite 1200 Honolulu, Hawaii 96813 (808) 521-9200

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INDEX EXAMINATION: By Ms. Meek 5 PAGE

EXHIBITS FOR IDENTIFICATION: Exhibit 1 18 (1-page excerpt from account at Bank of Santa Maria, Paso Robles, California) Exhibit 2 27 (1-page excerpt from declaration of Trust) Exhibit 3 32 (3-page First Amendment to the Elvin R. Meek and Elizabeth A. Meek Living Trust, dated 1-10-92) Exhibit 4 35 (1-page excerpt from First Amended Declaration of Trust) Exhibit 5 (1-page letter dated 8-15-03) 38

Exhibit 6 55 (2-page patient discharge instructions) Exhibit 7 58 (1-page Straub Advance Directive Checklist) Exhibit 8 (5-page certificate of trust) 67

Exhibit 9 69 (1-page photocopy of canceled check) Exhibit 10 (1-page letter dated 8-26-04) 72

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Exhibit 11 (1-page letter dated 9-8-04)

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Exhibit 12 86 (5-page transaction detail by account of the Estate of Elvin R. Meek)

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I N D E X (Cont'd) EXHIBITS FOR IDENTIFICATION: Exhibit 13 94 (3-page endorsement for change) Exhibit 14 (2-page power of attorney) Exhibit 15 (3-page letter dated 2-22-07) Exhibit 16 (3-page letter dated 4-27-07) 97 106 107 PAGE

Exhibit 17 111 (22-page tax forms for the estate of Elvin R. Meek) Exhibit 18 112 (2-page Supplemental Schedule A) Exhibit 19 114 (1-page series of emails for 11/09) Exhibit 20 115 (1-page series of emails for 10/09) Exhibit 21 (1-page letter dated 6-28-05) Exhibit 22 (1-page email dated 10-4-07) 117 118

Exhibit 23 120 (1-page series of emails dated 10-23-04) Exhibit 24 126 (31-page Report of Forensic Psychological Evaluation)

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Exhibit 25 137 (18-page series of letters and emails) UNANSWERED QUESTIONS AS REQUESTED BY COUNSEL:

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(Pursuant to Rule 14 of the Rules Governing Court Reporting in Hawaii, the reporter's disclosure was made available.) ELIZABETH MEEK, having been called as a witness and being first duly sworn to tell the truth, the whole truth and nothing but the truth, was examined and testified as follows: EXAMINATION BY MS. MEEK: Q A Q A Okay. Could you state your name? Elizabeth A. Meek. Are there any other names that you go by? Well, I have a name Ile Brerang, I-l-e

B-e-r-a-n-g (sic). Q A Q A Q A And your date of birth? 4-23-53. And where were you born? Koror, Palau. Can you spell that, please? K-o-r-o-r, P-a-l-a-u.

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Q sisters? A Q

And you have how many brothers and

I have seven brothers and five sisters. And where were you raised?

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A Q A Q A

Koror, Palau. And what is your marital history? My marital history? Correct. Okay. My -- I had an ex-husband Johnny

Reklai, and then a deceased husband Elvin R. Meek. Q And what year approximately were you and

Johnny Reklai married? A Q 1975 to 1987. Were you married in the courts or was

that the traditional marriage? A Q A Q A Q A Q A Q It was a traditional marriage. And you and Elvin Meek were married when? July 26, 1988. Okay. And do you have children? Yes. And their names? Lola Dee Meek. And that's your child with? Johnny Reklai. Johnny Reklai, who was adopted by Elvin

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Meek? A Q A Yes. Approximately what year was she adopted? 1991.

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Q

Okay. Now, when did you move --

approximately when did you move from Palau to the United States? A Q A Q A 1979. All right. Did you bring Lola with you? No. Did she stay with the father in Palau? She stayed with the parents, Johnny

Reklai's parents. Q A Q The grandparents? Grandparents, grand copas (phonetic). Copas. Did you attend school in the United States? A Q A Yes. Where and what years? Okay. 1979 to 1984 at United States

International University down in San Diego, California. Q A Did you graduate? Yes.

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Q A

And what degree did you graduate with? I had my BS degree in 1982 and then my

master in business administration in 1984. Q How long had you been a resident of

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United States? MR. ASHFORD: Objection. Vague. BY MS. MEEK: Q I'm sorry. How long -- when did you -- well, when did you become a resident of the United States? A Q States? A Q Since 1979. Okay. But you did not apply for What do you mean? How long have you lived in the United

citizenship until -When did you apply for citizenship? Approximately what year, month? A Q A Q A I think it was perhaps in late '90s. Late '90s? Uh-huh. When was that citizenship finalized? We were in here in Hawaii when we started

that 1997 or '98. Q And '97 or '98. You're not sure then?

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A Q A Q

Uh-uh. And when was the citizenship finalized? I think it was in 2005. In 2005? Approximately what month?

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A Q A Q

I don't remember. You don't recall what month? Uh-uh. When they do that, the citizenship, do

they do -- educate me a little bit on that. Do you raise your hand and take an oath saying, "I will support the constitution"? A Q Yes. Okay. You don't recall when you took

that oath? A Q A Q I know it was in 2005. But you don't recall what month? I don't remember the month. You don't remember the month. Did you stand up and hold your hand up with several other people? A Q Yes. Cool. Okay. Did you and Elvin discuss your becoming an American citizen? A Yes.

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Q A

What was the -- what was the holdup? We were traveling back and forth to

California. Q From?

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A Q A Q

From here. From here? Uh-huh. Okay. So you just never had an

opportunity -A Q Yes. -- to do it? What would you say is your frequency of travel to Palau? MR. ASHFORD: Objection. Vague as to time. BY MS. MEEK: Q A Q A Q A Q During the last say 10 years. Once a year. On average, how long do you stay there? Two months. Two months at a time? Yes. So two months a year? Would that be

correct? A Yes.

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Q

How would you define your relationship

with Melvin Meek? A Q With Melvin Meek? Correct.

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MR. ASHFORD: Objection. Vague. THE WITNESS: Good. BY MS. MEEK: Q Good? Have you ever had what you would

consider words or a conflict with him in any way during the last 10 years? MR. ASHFORD: Same. THE WITNESS: Can you repeat the question? BY MS. MEEK: Q Sure. Let me just rephrase it. During

the last 10 years, what would you -- how would you define your frequency of contact with Melvin? A Q A Q A Q A Q Not often. Not often? As in once a year maybe? Not even once a year. Not even once a year? No. Is there any reason for that? He never calls. How about from 2000 to 2003?

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A Q

I talked to him on the phone. You did? With what frequency a year

approximately? A 2001.

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Q A Q A Q

And how often? 2002 it was one time. One time in 2002? Yes. Do you recall when Melvin and his wife

Tessie had their first child, Joseph Meek? A Q No, but -- no. Is it because you didn't know that they

had a child? A No. They -- they wrote a note to Elvin

saying that Tessie is expecting a child. Q And you didn't talk to them after

Joseph -A Q A Q No. -- was born? No. How would you define your relationship

with Lola -A Q Good. -- at this point? Good? Has it always been a good

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relationship? A Q Good. Yes. Good mother-daughter relationship. Okay.

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How would you define your relationship with Robert Jones? A Q A Q Good. Were you familiar with Robert Jones -Yes. -- before the wills were executed, the

first one, the first trust in '92? A Q Say that again. Were you -- had you met Robert Jones

before the trust was executed in '92? A Q A Q A Q Yes. Did you socialize with him? He was our attorney. But did you socialize like have dinner? Once in a while, but not often. But not often. What's his wife's name? I have forgotten. How would you define your relationship

with Michael Gould? A Good.

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Q A

How long have you known him? Maybe since 19 -- when he moved to Paso

Robles. Q So 19 --

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A Q

'90, '91. Was he your accountant? Was he Elvin's

accountant -A Q A Q A Q A Q Our accountant. -- at that time? Elvin and I and -- our accountant. When did he become your accountant? Oh, he was filing our taxes. Do you recall approximately what years? When he moved Paso Robles 1990 or '91. And that was when Michael Gould was

retained to be your accountant? A Q A Q Yes. And did you socialize with Michael Gould? No. So you would define that relationship as

strictly business? A Q Yes. And how long have you known Ralph

Shumway? A He was -- I would say -- well, he's been

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our manager, Waipuna's manager. He managed the condo over there. He's the manager. Q A He's the property manager? I don't know if it's the property

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manager, but, anyway, he's the manager. Perhaps residence manager. Q Residence manager. Yes. I'll agree with

that. That is his title, I do recall. Was he the residence manager when you and Elvin first moved to the Waipuna? A Q No. No? When did he become the resident

manager? A Q A Q I don't remember. Did you socialize with Ralph Shumway? No. How would you define your relationship

with Ralph Shumway? A He's the residence manager. So I see him

all the time when I go in and out of condo. Q A Q So business and -Yeah. - a friendly, "Hi, how are you," because

he's there every day downstairs in the office there?

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A Q

Yeah. Okay. And how would you define your

relationship with Ann Taylor? A Same thing.

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Q A Q

Did you socialize with Ann? No. Do you recall approximately when she

passed away? A Q No. Would you say my father had the same --

I'm sorry. Strike that. Would you say Elvin Meek had the same type of relationship with Ralph Shumway, just casual, "Hi, how are you," not socializing? A Q A Q Yes. And the same with Ann Taylor? Yes. How would you categorize his relationship

with Michael Gould? MR. ASHFORD: Objection. Calls for speculation. BY MS. MEEK: Q Would you define it as a business

relationship? MR. ASHFORD: Same. You can still answer

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if you're able to. THE WITNESS: It was strictly business. BY MS. MEEK: Q And his relationship with Robert Jones,

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would you say that was strictly business? MR. ASHFORD: Same objection. BY MS. MEEK: Q A Did he socialize with Robert Jones? Well, they belong to Elks Club. So

sometimes they go out with each other. Q Well, that's socializing. I'm going to try and do this as best I can in some chronological order, but please be patient with me. Let's see. We're going to start with the executing of the amendment -- I'm sorry -of the trust, the Elvin R. Meek/Elizabeth Meek Trust that was executed in 1992. Do you recall that? A Q Yes. You recall executing that. Would you say that Elvin was of sound mind when he executed those documents? MR. ASHFORD: Objection. Vague. Which documents are you talking about? MS. MEEK: The Elvin R. Meek and

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Elizabeth Meek 1992 Trust. MR. ASHFORD: The only reason I ask is that you seem to be referring to a single document --

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MS. MEEK: No, no, no. I'm just referring to it myself. MR. ASHFORD: Let me just continue. You asked her about a document and then you asked her about documents plural. So I just want to know if you're changing your topic to multiple documents? MS. MEEK: No. I'm talking about just that specific trust. Q (By MS. MEEK) And that was drafted by

Robert M. Jones; correct? A Q A Q Yes. Do you recall what was in that document? No. I'm going to submit this document as

Exhibit No. 1. What this is is it's the amendment to the Elvin Meek/Elizabeth Meek Living Trust dated January 10th, 1992 and this was amended on August 26, 1994. Take a look at that document. (Exhibit 1 is marked for identification.) BY MS. MEEK: Q Tell me is that correct?

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MR. ASHFORD: Sorry. What is your question? If what is correct? BY MS. MEEK: Q Do you recall when that document was

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signed? Were you present when that document was signed? MR. ASHFORD: I object. You've given her what looks like the last page of a multi-page document. So I object to your question as being incomplete, confusing, vague and ambiguous. BY MS. MEEK: Q I'm sorry. Maybe I have the whole thing.

I apologize. That's all that I had -- I'm sorry -that Mr. Jones provided to me. I apologize. That's the amendment. A It's the accounts at the Bank of Santa

Maria, Paso Robles, California. Q A Q A Q And if you read down, what does it say? It doesn't say anything. Specifically about Lola. No. It doesn't say anything about Lola? MR. ASHFORD: She's referring to this, apparently. You want her to read the document out loud?

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BY MS. MEEK: Q A If you don't mind. Okay. MR. ASHFORD: You want her to just type

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it into the record or do you want her to read it out loud because the court reporter is going to have a little bit of hard time understanding. MS. MEEK: Do you want me to read it? What is says is, "Settlor Elvin R. Meek further revokes paragraph 5-A(1) of the Elvin R. Meek and Elizabeth Meek Living Trust, dated January 10th, 1992, and as amended August 26, 1994, so as to delete the reference to Lola Dee Meek serving as a successor trustee to any trusts created by the Settlor." MR. ASHFORD: Did you get that? THE REPORTER: Yes. BY MS. MEEK: Q Now, on this document, it says it's

notarized by Robert Jones, but it's notarized June 14th, 1996. I just wanted you to see that and make sure that you were aware of that. A Q Yeah, it was notarized by Robert Jones. Okay. Do you have a copy of the

document, the trust, the Elvin R. Meek family

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trust? A Q Say that again. Do you have a copy of the 1996 Elvin R.

Meek family trust?

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MR. ASHFORD: Objection. Vague. You mean with her as she sits here? BY MS. MEEK: Q No. Do you have your own copy at home?

Do you have a copy? Have you read that document thoroughly? Have you studied that document? MR. ASHFORD: Objection. Vague as to

BY MS. MEEK: Q Trust? A Q You mean the first amendment? The Elvin R. Meek family trust that was Have you studied the 1996 Elvin R. Meek

done in 1996, have you studied that? MR. ASHFORD: Same objection. THE WITNESS: No. BY MS. MEEK: Q A Q No. You haven't studied it? No. Okay. I didn't want to have to submit

this as evidence since it's -- since the file is

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certainly big enough as it is, but this is a copy of the Declaration of Trust if you'd like to take a look at it. What I am going to submit as Exhibit No. 2 is the signature page on the last page, and

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this is a copy of this page here. If you want to look at last page and look at this page. A Q This is -- this is 1992. No. This is 1996. MR. ASHFORD: Is there a question pending? BY MS. MEEK: Q I do have a question. Were you present when that document was executed? MR. ASHFORD: Which document? MS. MEEK: This one here. I'm sorry. I apologize. MR. ASHFORD: I just want it to be clear on the record. MS. MEEK: I know. I know. MR. ASHFORD: Otherwise, it's not going to make sense. MS. MEEK: I'm sorry. I apologize. What I'm showing to Elizabeth is the Declaration of Trust, the Elvin R. Meek Trust that's dated June

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14th, 1996. This is a copy of the trust, a full copy of the trust, and this is another copy that I want to submit as Exhibit No. 2, and this is the signature page. And my question to you is were you

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present when this was executed by Elvin Meek? MR. ASHFORD: Nanci, you have your hand on two documents. So I just want to be clear when you say this. BY MS. MEEK: Q I apologize. When the Declaration of Trust was executed on June 14th 1996, were you present in the office with Elvin Meek when that was executed, in Robert Jones' office there in Atascadero? A This is the 1992 trust. MR. ASHFORD: That's '96. THE WITNESS: '96? Is this a cover for this? MS. MEEK: This is the 1996 trust. MR. ASHFORD: Take a moment to make sure you know what she's talking about. Then the last page probably. Okay. So this is the end of the document. This is the notary. BY MS. MEEK: Q I guess my question would be do you

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recall being in the office when that document was executed by Elvin in Robert Jones' office? Do you recall being there with them? A I don't recall.

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Q A Q A there. Q A Q

You don't recall being there with them? No. Are you sure? 1996. Okay. I think I recall I was in

You do recall? Yeah. Are we in agreement that the last

signature page on the document entitled "Declaration of Elvin R. Meek Family Trust" is the same as this copy, the copy next to it that I'm going to submit as Exhibit No. 2? MR. ASHFORD: Objection. Calls for speculation and opinion. Nanci, you want her to authenticate one document as a copy of the other; is that right? MS. MEEK: That's without submitting the whole document, yeah. Q (By Ms. Meek) Would you say that this is

an authentic copy? MR. ASHFORD: Same objection.

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THE WITNESS: Same as this? BY MS. MEEK: Q A Yes. Where's the original?

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Q

Neither one of those pages are original

pages. If it's too confusing for you, we can move on. Okay? Elizabeth, can you tell me a little bit about your work history? A My work history? Okay. I went to school

in San Diego. I worked on a work study program, it's called, while I was in school up until 1984. Q A Where did you work up until 1984? For work study school from 1979 -- 1979

to 1984. Q A Q A And what type of work did you do? Work study program. Was it clerical work? Clerical work and some other things that

was available on campus. Q A Q A Q And from 1984 -To 1980. Then 1984, I didn't work. Until when? Until -- until 1990. Until 1990. So from 1984 to 1990, you

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did not work? A Q A Yeah. And then from 1990 until -'95.

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Q A Q A Q A

-- '95, where did you work? I worked for Elvin. In the office? Yes. As a legal secretary or -As receptionist and doing some legal

paper, pleadings and things like that. Q Would you say you got a little bit of a

legal education while you were working for Elvin? MR. ASHFORD: Objection. Vague. BY MS. MEEK: Q Well, along the way, did you -What do I want to say? -- did you become a little more familiar with the law than you had been before working for him? MR. ASHFORD: Same objection. THE WITNESS: (Witness nods.) BY MS. MEEK: Q No? And from '95 until -- where did you

work after '95?

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A Q A Q

I didn't work. You didn't work. Are you working now? No. So from '95 to the present, you have not

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worked? A Yes. MR. ASHFORD: Nanci, did you want to mark Exhibit 2? (Exhibit 2 is marked for identification.) BY MS. MEEK: Q So it's safe for me to say then that you

worked at the work study in San Diego up until 1984, and when did you start again the work study in San Diego? A Q 1979. '79. Is that while you were going to

school there? A Q Yes. Do you recall when the first amendment

was first drafted to the 1996 trust? A again. Q The first amendment that was drafted in 1996? You're talking about -- say that

1997, the first amendment to the 1996 Elvin Meek Trust, do you recall when that was drafted?

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A Q A Q

Yes. Do you recall who drafted it? Robert Jones. Was that while you were living in Paso

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Robles? A Q Yes. The first amendment was drafted while you

were living in Paso Robles? A Q Yes. Do you recall where the first amendment

was executed? A Q A Q 1997. Do you recall where it was executed? Honolulu. So it was created by Robert Jones in Paso

Robles, but it was signed in Honolulu in 1997? I'm talking about the one that was signed September 16th, 1997. A Q A Q That's the first amendment; right? That's the first amendment; correct. Correct. Now, did Robert Jones create the copy --

create the amendment in Paso Robles, and then you took it with you to Hawaii? MR. ASHFORD: I'm going to object as

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vague. Excuse me. I'm going to object as vague because as we all know, there were two different versions -MS. MEEK: And I'm trying to be clear.

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MR. ASHFORD: Let me just finish and then you be clear, but we can't speak at the same time because of the court reporter. So there's one that seems to be signed in Atascadero and one in Honolulu. So my objection is you're being unfair to the witness by not giving her the specific document you're talking about since you're throwing around dates, but proceed as you want. I just want to put that on the record. MS. MEEK: No problem. I have the document. MR. ASHFORD: Great. Thank you. BY MS. MEEK: Q I am handing to Elizabeth my copy of the

First Amendment of the Elvin R. Meek Family Trust which was executed on September 16th, 1997. If you want to take a look at that. Would you say that that is an accurate copy? A Q Yes. So for the record, when I am speaking

about the document, the first amendment to the '96

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trust, there are two amendments I'm going to be speaking of. I'm going to be speaking about the one signed in California as well as the one signed in Honolulu. Is that understood?

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MR. ASHFORD: I'm going to object to that designation as being confusing. MS. MEEK: Well, it is confusing, but it's certainly crucial to what we're trying to do here as far as trying to prepare for the evidentiary hearing. So I'd have to object to your objection. MR. ASHFORD: You can go as you see fit, but I'm basically warning you that I think you're going to end up with a confused record, but you're entitled to go as you see fit. BY MS. MEEK: Q Okay. Do you recall how that document

came to be at the Bank of Hawaii? Was that document typed and created by Robert Jones in Paso Robles and then -Tell me a little bit. What was the history behind that? How did it get over to Hawaii? A Q By mail. By mail. He mailed it to you?

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A Q A

Yes. And then what happened? And then we took it to the bank, get it

notarized.

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Q

Was it the document that I presented in

front of you, the unnumbered document? A Q This document. The signature right here. But was everything, all the pages that

proceeded that, was the document as best you can recall? A Q A Q Yes. That is the document? Uh-huh. Why were the words -- do you know why the

words "Atascadero" were scratched off and the words "Honolulu" were written in? A Q A You mean the last page? Yes. You can see it was notarized here in

Honolulu. Q Okay. So, in other words, Robert Jones

mailed it to you? A Q Yes. He mailed it to you. Do you recall how

much time went -- how much time took place between

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the time that you received it in the mail and the time that it was executed? A Q I don't recall. You don't recall. This is a document

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that I want to submit as Exhibit 3. This is a document that's entitled "First Amendment to the Elvin R. Meek and Elizabeth Meek Living Trust, Dated January 10th, 1992." It was executed at Atascadero, California, on the 26th day of August 1994. It was executed by Elvin Meek and Elizabeth Meek with Robert Jones declaring himself as attorney and witness. I want to submit this and I'm going to hand it to you, Elizabeth, to review. (Exhibit 3 is marked for identification.) BY MS. MEEK: Q A Q Do you recall executing that document? Yes. Would you say that that's a true and

accurate copy? A Q Yes. Thank you. The next thing I'm submitting

is an affidavit of Robert Jones that's dated January 6, 2006, executed in Atascadero on November 10th, 2005. Would you take a look at this, please? Is there anything in that document that

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you would disagree with? MR. ASHFORD: You want her to read the whole thing? MS. MEEK: It doesn't take that long.

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MR. ASHFORD: That's a yes? MS. MEEK: Yes. I'm sorry. MR. ASHFORD: Objection. Calls for speculation. MS. MEEK: The document refers on page 2 -- let's see. On the second paragraph, it says, "As attorney for the Settlor and Mrs. Meek, Affiant drafted the document which established the Elvin R. Meek/Elizabeth A. Meek Living Trust, dated January 10th, 1992, as well as its Amendment. In addition, Affiant also drafted the document which established Elvin R. Meek Family Trust, dated January 14th, 1996, and its Amendment. Affiant understands --" Affiant being Robert Jones. "-- that the Settlor and Mrs. Meek signed the document entitled the 'First Amendment of the Elvin R. Meek Family Trust' on September 16th, 1997, in Hawaii. On September 19th, 1997, when the Settlor and Mrs. Meek were in California, they resigned the document. As the drafting attorney,

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Affiant confirms the document dated September 16, 1997, is the operative First Amendment of the Elvin R. Meek Family Trust." Do you have any opinion as to that?

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MR. ASHFORD: Objection. Compound. Calls for opinion. Vague. MS. MEEK: I don't think so. I have to disagree. Q (By Ms. Meek) Do you recall being in

California three days later after the document was signed in Honolulu? A Q A Q A Q A Q A Q I don't recall. You don't recall? No. Is that a no? No. You were not there? I don't recall. You don't recall or you -I don't recall. You don't recall being there? In other

words, it's possible that you were there? A Q A No. So, no, you weren't there? I wasn't there.

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MS. MEEK: Okay. Do I need to submit that as an exhibit? If I don't need to, then I won't. It's been going around and it's been copied so many times.

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This page I would like to submit as Exhibit No. 4 if it's all right with Mr. Ashford. MR. ASHFORD: You can submit anything you

MS. MEEK: This is the last page in question of the amendment that Robert Jones said was signed in California three days later. If you can take a look at this, Elizabeth. (Exhibit 4 is marked for identification.) BY MS. MEEK: Q This is the last page of the document

that Robert Jones refers to in his affidavit that was signed in California, that he states was signed in California. A Q A Q A Q What about it? Do you recall seeing that document? No. Is that your signature? Doesn't look like my signature. Is that Elvin's signature in your

opinion?

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A Q

It looks different. Tell me again when did you graduate with

your MBA approximately, do you recall? A 1984.

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Q A Q

1994? '84. '84. I apologize. At any time between 1984 and the present,

have you gone to -- had any other schooling? A Q A Q A Q that? A Q A Q '84 to '85. '84 to '85? One year. Did you attempt to take the bar exam at No. No? No. You did not take prelaw classes? Oh, yeah, I did. Thanks for reminding. You're welcome. Approximately when was

any time or the baby bar? A Q A Q I did. You did. Did you pass? No. How many times did you take it?

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A Q A Q

I don't remember. So more than two times probably? Yeah, maybe. More than three?

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A Q

I don't remember. Don't remember. Where did you take the

baby bar? Do you recall? A I don't recall. It could have been in

Pasadena. Q As I mentioned, I want to try and go in

chronological order because that's the way that my brain works. So, hopefully, that's the way you work. I would like to submit a document, and we'll call it Exhibit 5. What this is it appears to be a letter written on stationery for Elvin R. Meek and Elizabeth Meek. The date on it is August 15th. It is addressed to Boone County Tax Collector regarding property in Arkansas, and it is dated August 15th regarding a quitclaim deed mentioning copies of -- it says my mother's death certificate and 2002 real property tax statement and a $10 draft is enclosed for the recording of the new deed in my name, signed -It says, "If you would be so kind as to record the same for me, I will be gratefully

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pleased for your assistance. Very truly yours, Elvin R. Meek," and it is not signed by Mr. Meek. Do you recall seeing this document, Elizabeth?

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(Exhibit 5 is marked for identification.) THE WITNESS: Well, I don't remember seeing that, but usually he signs all the documents he mailed in. BY MS. MEEK: Q But he didn't sign that one, did he? MR. ASHFORD: Objection. Calls for speculation. BY MS. MEEK: Q Well, there's no signature there.

There's not a signature there, is there? A Q A Q No. Did you type this letter for him? I don't recall. Do you recall why that letter was typed

up and sent to the recorder's office? A Q No. So you could not confirm or could you

confirm that it was typed up and sent on August 15th? A No. I don't remember sending this letter

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August 15th of 2003. Q sent? A No. So you don't recall this letter being

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Q

Okay. While we've already covered this

during my deposition, I just wanted to again touch on it. I'm handing to Elizabeth a copy of the second amendment to the Elvin R. Meek Family Trust. It's two pages. If you could take a look at that, please. In your opinion, would you say that those signatures are weaker than the signatures on the Elvin Meek's trust that he signed in 1997? MR. ASHFORD: Objection. Vague. Calls for speculation. Calls for opinion and testimony by a nonexpert. BY MS. MEEK: Q Well, she's his wife. I would think you would know. Would you think that those signatures are a little bit weak? MR. ASHFORD: Same objections. BY MS. MEEK: Q Okay. Would you agree that this document

was signed -- was executed on September 22nd, 2003? Do you agree to that?

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A Q

Yes. And the same document was witnessed by

Margo Corliss? Do you agree to that? A Yes.

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Q

And that's your signature as well on that

document? A Q Yes. Do you recall being at the Bank of Hawaii

with my father, with Elvin, when these documents were signed? A Q Yes. Uh-huh. How would you define his

condition? A Q A Q A Q He was walking. He was walking? He was walking. He was walking? Yeah, with a cane. With a cane. Did you have a chance to review this document before it was executed and before you signed it? A Q Yes. You did. You didn't notice this here

where it says September blank, 1999?

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A Q A Q

No. You didn't notice that at the time? No. Do you know why you didn't notice that,

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or is there some reason why you didn't -That's a pretty important document. Is there some reason why you didn't really study that document? A Well, it says 1996 trust. So it's the

same thing. Q But here it says -- here at the top, it

says, "Elvin R. Meek, Settlor of the Elvin R. Meek Family Trust dated June 14, 1996, as amended September blank 1999." Was there an amendment that you know of in 1999? A Q No. Do you find it peculiar that Elvin didn't

notice that? MR. ASHFORD: Objection. Vague. Calls for speculation. BY MS. MEEK: Q Well, he's your husband. Don't you think

he would have noticed something like that? A I don't know. MR. ASHFORD: Same objection.

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BY MS. MEEK: Q hurry? A No. Is it possible that maybe you were in a

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Q this? A Q

You weren't in a hurry to have him sign

No. I'm placing in front of Elizabeth a copy

of the will of Elvin R. Meek that was executed on the 23rd of September in Honolulu, Hawaii, with an attached attestation signed by Ralph Shumway and Ann Taylor. Elizabeth, would you please read that thoroughly and refresh your memory. Do you recall who created this document, who typed it up and sent it to you? A Q A Q A Q A Q Robert Jones. How did Robert Jones send it to you? By mail. By mail? Uh-huh. By mail, not fax? Yes, by mail. By mail, USPS? Is that the same way that

you received the second amendment, by mail?

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A Q

Yes. So were they both mailed to you at the

same time? A Yes.

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Q

So it's my understanding that you

received them in the same envelope? A Q Yes. Did you and my father discuss naming the

Bank of Hawaii as a cotrustee? A Q I don't remember. Do you recall Robert Jones making the

suggestion to make the Bank of Hawaii the cotrustee? A Q I don't know. You don't recall whose suggestion it was

to bring in the Bank of Hawaii -A Q A Q A Q A Q 1997? No. -- as a cotrustee? It doesn't that say in the trust? It says in what trust? The first amendment. In the first amendment? Uh-huh. The one that was drafted and executed in

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A Q

And signed in Honolulu. Correct. That's what you're saying

because if that was in that amendment, it's also in here?

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A Q

Yes. Now, if you have both of these documents

at the same time, like you said, they both came together through the postal service? A Q Uh-huh. And it's my understanding that you went

to Hawaii -- mean, you went to the Bank of Hawaii to have the second amendment notarized. Why didn't you have the will notarized at the same time? MR. ASHFORD: Can I see this? MS. MEEK: Sure. Q A (By Ms. Meek) Do you recall? Because they don't notarize at the Bank

of Hawaii. They don't notarize will at Bank of Hawaii. Q A They won't? And who told you this? What's her name? The lady who notarized

the -- the lady who notarized the paper. Q A Q Would that be Margo Corliss? Yes. Do you recall when this will was

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witnessed and signed by Ralph Shumway and Ann Taylor -A Q Yes. -- and signed by yourself and by Elvin?

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Can you tell me a little bit about that day, how Elvin was feeling? A Well, just usual. We get up and do our

lunch and walking in and out of Waipuna, and then we walked down and then he got that signed. Q A Q it was? A Q A Q A Q A Q A Q Yes. He was walking with a walker. With a walker? With a cane. Which was it? A cane or a walker? Cane. A cane? Yeah. Did he use a walker? No. He never used a walker while he was How was his health at the time? Well, Elvin was walking. Was he cognizant? Did he know what day

home -A No.

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Q A Q

-- for his balance? No. Whose idea was it to have Ralph Shumway

and Ann Taylor witness your signing and his signing

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of the last will and testament? At whose suggestion? A Q Oh, we both did. At both your suggestion and Elvin's

suggestion? A Q Well, they were closer to us. Was there some reason why he didn't call

Wes Stewart and Nina? A Q A Q A Q I don't know. He didn't call them. Do you know why? I don't know. Was it ever suggested? I don't know. You don't remember if it was ever

suggested? A did. Q Okay. Let me ask you this. This page No, I don't recall. I don't know if he

here, did Robert Jones type this page? A Q Yes. He did?

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A Q

Yes. He typed this page which is attached -This page, it's called the "Attestation"

which is attached to the will of Elvin R. Meek.

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Robert Jones typed that page and mailed it to you from Atascadero in that same package with the second amendment? A Q Yes. So prior to mailing that to you, the

subject of having Ralph Shumway witness the attestation and Ann Taylor witness the attestation or the subject of having witnesses must have come up a couple of days before that actually came in the mail to you? A Q No. Well, you just said he typed up this

attestation. Let me be a little more specific. It wasn't -- I'm not saying that it was at Robert Jones' suggestion that use Ralph Shumway and Ann Taylor. Obviously, he's told you to use two witnesses? A Q A Yes. He told you to use two witnesses? Yes.

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Q

And he sent you this attestation page

attached to this will of Elvin Meek and the second amendment, and they all came in the same envelope to the house there at Waipuna?

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A Q

Yes. Now, in-between that time, it was never

suggested that Wes Stewart and Nina come over and help you guys with your -A No. MR. ASHFORD: Objection. Asked and answered and compound. MS. MEEK: I have to object. That's a very important question. Q (By Ms. Meek) You never made the

suggestion of having Nina Stewart -A Q A No. -- or Wes Stewart -No. MR. ASHFORD: Objection. Asked and answered. BY MS. MEEK: Q Why is that? It has not been answered. MR. ASHFORD: Yes, it has. MS. MEEK: No, it hasn't

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MR. ASHFORD: Do you want her to read the record? MS. MEEK: Well, answer it again. I understand what you're saying, but now I'm asking

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you again. MR. ASHFORD: What are you asking? BY MS. MEEK: Q I'm asking you it was never suggested by

yourself or by Elvin to have Wes Stewart and Nina witness this document? MR. ASHFORD: Objection. Asked and answered. MS. MEEK: Well, just out of curiosity, what was the answer? Refresh my memory. MR. ASHFORD: I believe the answer was no. Either no or I don't know. MS. MEEK: You don't recall. MR. ASHFORD: You can ask the court reporter to read it back, though, and then we'll all know for sure. MS. MEEK: Okay. Can you read it back? I'm getting confused myself. (The record was read.) BY MS. MEEK: Q In 1994, the amendment to the 1992 trust

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Elvin Meek removes Lola from the trust. Do you know why? A Do I know why? MR. ASHFORD: Objection. Calls for

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speculation. BY MS. MEEK: Q trust? A Q A Q Yes. Do you have an opinion as to that? No. Do you know what the purpose of that 1994 Do you recall him removing her from the

amendment was? A What do you mean? MR. ASHFORD: Objection. The document -MS. MEEK: I'm asking you for your opinion. MR. ASHFORD: Objection. The document speaks for itself. Calls for opinion. MS. MEEK: Oh, yeah, I am. Q (By Ms. Meek) Approximately what time

would you say -- approximately what month in 2003 would you say that dad's -- that Elvin's health started to fail? A Say that again.

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Q

I said approximately in 2003,

approximately what month would you say that Elvin's health began to fail? MR. ASHFORD: Objection. Calls for

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speculation. MS. MEEK: In your opinion. MR. ASHFORD: Same. BY MS. MEEK: Q So you don't want to tell me

approximately when you thought Elvin was failing? MR. ASHFORD: Elizabeth, so you know, I'm not instructing you not to answer. I'm just making a comment on the quality of the question, basically. So if you can answer the question, then please do. THE WITNESS: I would say perhaps beginning of 2003, but, you know, it's slowly since 2000 to 2003. Of course, you know, he goes in and out of the hospital. BY MS. MEEK: Q When did he begin going in and out of the

hospital with what he passed away with with the liver, cirrhosis of the liver? Approximately when? MR. ASHFORD: Objection. Vague. THE WITNESS: I don't remember, but we

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went to -- I don't recall the date, but he was advised by the doctor that he should not drink a lot of alcohol. BY MS. MEEK:

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Q

Okay. And that was approximately what

month in 2003? A Q A Q A Q A Q I think it was in 2000. Do you recall which doctor? Dr. Wright. Does he practice here in Honolulu? No. Where does he practice? Redland. In 2003, do you recall approximately when

Lola came out, flew out from Palau to stay with you in 2003 prior to dad going in the hospital or around that time? A Q 2003? When he was going in and out of the

hospital from like August to October of 2003. A Lola, no. He (sic) only came here when

Elvin was at the hospice. Q A Q Which was October? October. So Lola didn't come out till he was in

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hospice. Okay. How did she find out he was in hospice? A I think I called her.

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Q A Q A Q A Q

Do you recall who else you called? No. Did you call Melvin? No. Did you call me? No. Was there a reason why you didn't call me

or Melvin? A Q A Q A Q A Q Wes called Melvin and you. That was after he was in a coma -No. -- in hospice. That was in Straub Hospital. He was already in a coma. No. Wes called us when he was already in a

coma. I'm talking about why didn't you call us? A Melvin was on the phone with Elvin (sic)

at Straub Hospital and you too. Q then. Right, but he was in and out of a coma

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A Q that.

No. You were talking to him. Not really, but I'm not going to go into

Do you know approximately when it was

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that Wes came over? Do you recall when Wes came over to the condo to visit with dad while he was sick in September? Do you recall that visit? A Q A Q A Q A Q A Q A I don't remember the dates, but -But do you recall his being there? Yeah. I came in and he was there. How would you define how Elvin looked? Good. Would you say he was bloated? No. Would you say that he was incoherent? He was sleeping a lot. Was he sleeping a lot then? You know, he usually sleep from morning

to noon. So that's his routine. Q A Q Was he under a lot of medication? He take medication. Would you say for most of September, he

was on a lot of medication? A Q Well, since 2000. But would you say it was a little bit

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more during the month of September and October? A Q Same. It was same medication. It was the same. Okay. I'm submitting a copy of the

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patient discharge instructions that came from Straub Clinic & Hospital. It's page 1 and 2. It's dated September 20th, 2003. Each page has a list of all the medications that Elvin was taking. Also with a directive here to follow up the physician care with Dr. Zerez on October 2nd, 2003, and I'm submitting this. I'll submit this as Exhibit No. 6. (Exhibit 6 is marked for identification.) BY MS. MEEK: Q Elizabeth, take a look at that, please.

Flip over to page 2, and I want to ask you is that your signature? A Q Yes. And while I recognize that you're not a

doctor and I'm certainly not a doctor, but as a layperson when you look at all those medications that are listed there on the first page and the second page, does that strike you as being a lot of medications or what is your opinion on that? MR. ASHFORD: Objection. Calls for

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speculation and opinion. BY MS. MEEK: Q A Are you familiar with those medications? No.

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Q

Do you recall Elvin taking those

medications? A Q A Q Yeah. But you're not familiar with them? No. In other words, you don't know what

they're for? A Q A Q No. You just know he was taking them? Well, they were prescribed by the doctor. But he was consistently taking them when

he was discharged, when he was at home? A Q Yeah. Or was that just while he was in the

hospital? A Q At home. So he was taking them at home and in the

hospital? A Q I don't know. Perhaps at hospital too. When he was discharged from the hospital,

were you with him?

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A Q

Yes. Were you responsible for the medications

he was taking? A Well, again, he's living with me. Yes.

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Q

I guess the way I would want to phrase

this question would be was he capable of taking the medications on his own or did he need somebody like you to help him? A No. Well, sometimes I give him

medication, but he can get up and take his own medication. Q A Q So he was cognizant enough to know -Yeah. Approximately how many medications do you

recall he was taking at one time? A I don't recall, but he was taking

medication. Q A Q But give me a rough number. I don't know. Was it five, ten? How many -- in other

words, when you filled the prescriptions, do you recall how many prescription bottles you had to fill? A Well, I would probably say about five.

Depends on what kind of prescription that he needs

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to refill or he needs retake them. Q But at any one time in the medicine

cabinet, just education me here, in the medicine cabinet, how many medicine bottles would you say

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that he had to routinely, daily go to to take his medication for that day considering what his condition was at this time in September? A I don't know, but if that's the amount,

that's probably what it says here. Q Do you recall helping him and helping him

with his medications? Because I know in my experience with people, especially elderly people when they get sick, they can't always remember what medications to take, and it helps if somebody else is there to kind of help them. A Well, they're on the table. So he can

get up and open whatever he needs to take that day and take it. Q But was he the one primarily doing that

or were you helping him? A Q A Q Well, I was helping him. You were helping him? Yeah. Okay. Here's one more that I wanted to

submit as Exhibit No. 7.

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(Exhibit 7 is marked for identification.) BY MS. MEEK: Q This is an Advance Directive Checklist.

It says here on it, it asks, "Does the patient have

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a living will," with the yes box is checked, and it says, "At home on file." I want to show this to Elizabeth. Just take a look at that document, if you would. That document is dated 9-6-03? A Q Yes. With Elvin's signature on it; is that

correct? A Q Yes. In your opinion, would you say that

signature is weak? MR. ASHFORD: Objection. Calls for speculation and opinion. BY MS. MEEK: Q Do you recall when that document was

signed when he was submitted to the hospital? A It was on 9-6-03. So I think I was

there, but I didn't... Q A Q Do you recall what his condition was? Yes. How would you define that?

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A

Well, just a regular checkup and go see a

doctor and things like that. He was walking. Q A He wasn't being admitted to the hospital? I don't know.

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Q

You don't recall. That's okay. MR. ASHFORD: Nanci, can we take a break?

It's been an hour and a half. MS. MEEK: Yes, absolutely. Sure. For what now? MR. ASHFORD: I just said it's been about an hour and a half. MS. MEEK: Let's take a five-minute break. MR. ASHFORD: I suspect the court reporter would like that. (Brief recess.) BY MS. MEEK: Q Before I move on -- we're resuming.

Before I move on to several other items that came up after dad passed away, quickly, I just want to touch on who you did contact and who you didn't contact while he was in the hospital, in and out of the hospital, from the period of October 27th when he was first discharged from the hospital to October 19th when he passed away.

22 23 24 25

You -- it's correct to assume -- I mean, you didn't contact me? You didn't call me -A Q No. -- to tell me he was in the hospital or

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he was dying? A Q Wes contacted you. You didn't contact me because Wes

contacted me? A Q A Q A Because I asked Wes to do that. Oh, you asked Wes to contact me? Yes, and Melvin. Okay. Did Melvin contact you? No, but I know he talked to Elvin when he

was at Straub Hospital. Q A Q Melvin didn't call you on your cellphone? I don't recall him calling me. On the day that dad -- that Elvin passed

away which was in the evening, I recall or I believe -According to the death certificate, it was in the evening? A Q Yes. Within an hour after he passed away, was

there a reason why you didn't call me or Melvin? A I guess I asked Wes -- they were there.

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I asked Wes to give you a call and Melvin. Q A Q Wes was at the hospital -Yes. -- when dad passed away, and you asked

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Wes to call me and to call Melvin that evening -A Q Yes. -- when he passed away? Okay. Do you recall who you called right after he died? A Q No, I don't recall. After dad passed away, do you recall when

you called Robert Jones? A I did call Robert Jones, but I don't know

whether it was that day or the next day. Q A Q But approximately within that time frame? Yes. Did you call Robert Jones while dad was

in the hospital? A Q No. Dad's funeral was on October 21st; is

that correct? A Q A Q No. What day was his funeral? October 28th. It was October 28th?

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A Q A Q

Yeah. And do you recall where the funeral was? St. Peter and Paul Church. Within a couple of days after he passed

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away, do you recall who of his friends you did contact to let them know that he passed away? A Q A Q No. Did Lola make those phone calls for you? I don't recall. You don't recall. Well, I have a copy of

the phone records and the people that you did call or Lola called. Bob and Helen Flores, do you recall talking to them? A Q No. You don't recall speaking with them. Do

you recall speaking with Don and Debbie Hendren? A Q No. Do you recall speaking with Joyce and

Jerry Haney? A Q Lester? A Q them? No. Was there a reason why you didn't call No. Do you recall calling Stan and Sharon

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MR. ASHFORD: Objection. Assumes facts not in evidence. BY MS. MEEK: Q Did you have a reason for not calling?

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A Q A Q A Q

No. You just didn't call them? I just didn't have time. Didn't have time? I didn't have a minute to call. Would you consider yourself -- would it

be safe to say you were very much in mourning? A Q I don't know. Could be. Could be that you were in mourning? Do

you remember contacting -- calling Michael Gould within a couple of days after Elvin passed away? A Q I don't remember, but I think I did call. You did call. According to the telephone

records, you did. Do you recall that conversation? A I just let him know -- I just let him

know that he passed. Q That he passed. Was it pretty much like

the phone call you made to Robert Jones, within the same time frame? A Q Could be. I don't recall. You don't recall. Can you tell me who

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Steve Newton and Antonia Newton are? A Q Oh, okay. Antonia Newton is my cousin. Do you keep in touch with her pretty

frequently?

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A Q

Once in a while. Would you say you called her a lot while

dad was -- Elvin was in the hospital? A Q A Q A Q No, not a lot. No? No. Were you close with Toni? Cousin. Would you define your relationship as

you're very close? A Q Elvin? A Q No. While dad was -- while Elvin was in the Cousin. Just regular cousins, yeah. Had Steve Newton or Antonia ever met

hospital during August, September and October, there were several phone calls that were made to a travel lodge in El Cajon. Do you know who you were calling at that travel lodge? Do you recall? A Q No. You don't recall?

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A Q

No. According to the phone records that we

obtained, you called a lot of people on your cellphone and your personal phone and the house

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phone, but you didn't call Melvin and you didn't call myself and you didn't call Nicole? A No, because I used Wes -- asked Wes to

give you a call and Melvin. Q Was there some personal reason why you

didn't call us? A Well, I just thought Wes would be the

right person to give you a call. Q A Did you not feel comfortable calling us? Well, not really, but I just wanted to

ask Wes to give you a call to break the news to you. Q I'm talking about when he was in the

hospital. A Q Yeah, that too. Okay. I have to submit as Exhibit 8 --

I'm admitting this document. It's called the Elvin R. (sic) and Elizabeth Meek Living Trust, dated January 10th, 1992, Certification of Trust, which is executed on February 20th, 2004, Honolulu, signed by Elizabeth Meek. It appears to be signed

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by Elizabeth Meek and notarized at the Bank of Hawaii, I believe. I'm sorry. I apologize. Strike that. It doesn't say Bank of Hawaii. It just says notarized in Honolulu.

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Can you please take a look at that document? (Exhibit 8 is marked for identification.) BY MS. MEEK: Q Look at that and tell me who you recall

executed it, I mean, who drafted it. I apologize. Does that document look familiar to you? A Q A Q Yes. Is that your signature? This is my signature. Okay. Educate me a little bit and tell

me to the best of your knowledge what was the purpose of that document. And I'm sorry. Let me backtrack. First of all, who created this document? Robert Jones. Robert Jones. Did he mail it to you or

fax it to you? A Q He mailed it to me. And what was the purpose of this

document?

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MR. ASHFORD: Objection. Document speaks for itself. Calls for speculation. MS. MEEK: I want to hear her interpretation of what she thinks that document's

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about. MR. ASHFORD: You're entitled to ask your questions, and I'm entitled to make my objections. MS. MEEK: Sorry. THE WITNESS: Can you repeat your question? BY MS. MEEK: Q In your opinion, what is the purpose of

that document? Educate me. What's the purpose of that document? MR. ASHFORD: Same objections. THE WITNESS: It's a certificate -- it's a certification of a trust. BY MS. MEEK: Q A Q For which trust? Dated January 1992. And what's the purpose of that? MR. ASHFORD: Objection. Asked and answered. BY MS. MEEK: Q Do you not understand what that document

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is for? A It's a certification of trust of Elvin R.

and Elizabeth A. Meek Living Trust, and the reason why prepared -- made this for me was to do some

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other transactions that are involved in the trust. Q 2004? A Q A 2004. What were the transactions? I believe -- I'm not really quite sure, And that was signed in 2004, February

but it was one of the transactions, but I don't recall which one. Q A Q You don't recall? Yeah. That's Exhibit No. 8. I'm going to

include this as Exhibit No. 9. (Exhibit 9 is marked for identification.) BY MS. MEEK: Q A Q A Q A Take a look at Exhibit No. 9. Okay. And what does that look like to you? It's a check. Made to? Elvin R. and Elizabeth A. on January 3,

Elvin R. and Elizabeth A. Meek Living Trust.

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Q A Q A

Was that made out to you? To the trust. To the trust? Yeah.

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Q

And on the next down there, who signed

the back of it? A Q A Q A Q A Q A Q A Q A Q A Q I did. And what account did you put that into? The trust. Into the trust account? Yes. And what's the amount on there? Let me see. 646,481.96. 646,000? Yeah. What was that for? What do you mean? What was that for, the check? What? What was the check for? For the trust. But what was it for? How did you come to

have that check? A Oh, it's from the Union -- Unionbancal

Corporation.

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Q A Q

Which is what? From the stocks. Stocks. Thank you. I want you to take a

look at this letter. It's a notification by

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trustee from -- it's a letter that was sent to myself and to Lola and to my brother Melvin, and it is dated August 2nd, 2004, and it came from Robert Jones. I just want for you to take a look at it and tell me if you recall receiving a copy of that letter. MR. ASHFORD: Nanci, is this an exhibit or no? MS. MEEK: No exhibit. THE WITNESS: Well, I really don't know when I receive it because I don't recall. BY MS. MEEK: Q A Q You don't receiving this letter? I don't recall. Do you recall having a conversation with

Robert Jones about opening the trust -- opening the probate in California? A Q I don't know. I don't recall that. Do you recall Robert Jones discussing

with you opening the probate in Arkansas? A In Arkansas? I don't know. I just let

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him handle the things in regard to that. So I didn't recall that. Q I'm submitting as Exhibit No. 10 a letter

written by myself to Elizabeth dated August 26,

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2004. I wrote -- I admitted that I drafted the letter. I did not sign it, however, but I'm the one that did draft it. If you can take a look at that. (Exhibit 10 is marked for identification.) BY MS. MEEK: Q A Q Do recall receiving that letter? Yeah. To the best of your recollection, do you

recall why you didn't respond to that letter? A I just thought that Grigger, Robert

Jones, would be the right person. Q Did you misinterpret the letter? Did you

not understand that we were trying to see that you were okay; we wanted to know you were all right? A Well, I -MR. ASHFORD: Objection. Assumes facts not in evidence. BY MS. MEEK: Q Well, I will tell you right now that was

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the purpose of that letter. We just wanted to know you were all right. We were trying to get ahold of you for the longest time, and that was -- that's the reason why we sent that letter.

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A

Well, after the way you defaming me on

internet, Nanci, there's no way I would have talked to you. Q There was no defaming on the internet,

not when this letter was going on. A Oh, yeah. Those things that you were

sending me -Q A This was way before -No. This is after those things in the

internet. Q I have to disagree with you. This was

way before that. A Q I have to disagree with you too. Okay. This was before that. This is a

letter that we received shortly thereafter from Robert Jones. I'm not going to submit it as evidence because -- yeah. I will submit it as evidence. This is Exhibit No. 11. (Exhibit 11 is marked for identification.) BY MS. MEEK:

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Q A Q A

Are you familiar with that letter? Yeah. Do you have anything to say about it? No.

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Q A Q

Any opinions or anything? No. No. Okay. Do you know what the -- here

it mentions a variety of reasons that Elizabeth has chosen not to correspond with us at this time. Do you know what those were? A Well, you left a lot of messages on my

answering machine. So you know what you told me. Q A Q A Q A Q I do recall what I told you. Okay. But it was not anything that was bad. Oh, yeah. It was bad. What about Melvin? I didn't hear from Melvin. So you didn't hear from Melvin; yet, this

letter is addressed to myself and Melvin? A Well, Robert Jones is handling the

estate. So go ahead and ask any questions from him, not me. Q letter? Did you ask Robert Jones to write this

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A Q A Q

Yes. You did? Yeah. At any time did Robert Jones suggest to

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you contacting myself or Melvin as far as selling any of dad's properties? A Q A Q A Q No. He did not? No. He never made that suggestion? No. I just let him handle everything. Would you say he kept you informed about

the sale of all the properties, of the Rialto property, the Arkansas property? A Q that? A Q Yeah. At any time did you think that Robert Yeah. Did he keep you up to speed with all

Jones was trying to dissolve properties a little bit quicker than normal, or did you think that that was -- that was the normal course of events to sell property without telling the children? Did that seem like it was normal to you? MR. ASHFORD: Objection. Vague and

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compound. BY MS. MEEK: Q Did you ever question why he didn't

contact us -- contact myself or Melvin to tell us

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he was selling properties? A Q A Q No. Did you ever question that? No. I am handing to Elizabeth a copy of the

Second Amended Petition for Reformation of Trust Agreement. It was -- this was something that was prepared before we went to court and the date on it, the hearing date was 3-15-05. I just wanted to put this in front of you and have you take a look at it to refresh your memory. Did you have a chance to review that document? A Q Yeah. I looked through it. Do you remember when that hearing was in

August, I mean -- I'm sorry -- in March of -A Q A Q A Q March 15, '05. -- '05? Yeah. Were you present at that hearing? No, I wasn't. Where were you, do you recall?

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A Q A Q

I was here in Hawaii. You were here in Hawaii? Uh-huh. Do you understand what that document --

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the purpose of that document is? MR. ASHFORD: Objection. Calls for speculation. BY MS. MEEK: Q A that. Q sorry. So, in other words, the Second Amended Petition for Reformation of the Trust Agreement, you just let Grigger Jones prepare it, and he just told you over the phone not to worry, "I'll handle everything. You don't need to really read everything and understand everything"? Is that what you're telling me? MR. ASHFORD: Objection. Assumes facts not in evidence. THE WITNESS: Well, he briefed me on the petition for reformation of trust. He briefed me on it. So you just let Grigger Jones -- I'm Can you tell me in just a few paragraphs? Well, Grigger -- I just let Grigger do

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BY MS. MEEK: Q A Q He did? Yeah. Can you brief me on it?

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MR. ASHFORD: Objection. Vague. BY MS. MEEK: Q Well, just in a couple of sentences, just

tell me if you had to define what that document says in a nutshell. MR. ASHFORD: Objection. Calls for speculation and opinion. Document speaks for itself. MS. MEEK: I just want to make sure she understands what the document's about. THE WITNESS: Well, it says right here. MR. ASHFORD: I repeat my objections. BY MS. MEEK: Q I know what it says. I know what it

says, but do you understand what it means? A Jones. Q I am not submitting this as evidence, but No. It's the reason why I used Grigger

I'm going to refresh your memory. I want you to just take a look at this document quickly. It's the Declaration of Elizabeth Meek Trustee and

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Support of Reformation of Trust, dated 11-9-2004 was the hearing. It's signed by Elizabeth October 22nd, 2004, in Atascadero, California, October 22nd. Please take a look at this, Elizabeth. Do

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you recall executing that document? A Q Yeah. I signed this document. Do you recall being in Atascadero when

you signed it? A Q A Q I don't recall that. But that is your signature? Yeah. That is my signature. Okay. Thank you. I'm going to admit

this as Exhibit No. 12. If you could just take a look at this, this was a bill that was sent to me from Diversified Collection Services sent to my address. It's addressed to Elizabeth A. Reklai, but it came to my address. Just quickly, could you take a look at that? A Q A I wondered how did they get your address. I don't know. Because you already asked them to send

everything in my name to your address. Q A Q No, no. I don't know about that. That's what happened, Nanci. That's a collection bill and that was

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for -A Q My school education. My student loan. So I guess they had a hard time getting

ahold of you, but you've taken care of it since

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then; correct? A Q (Witness nods.) Have you taken care of it? MR. ASHFORD: Objection. Why is this relevant, Nanci? MS. MEEK: Because it came up before. Because it came to my address. The relevancy here is to show that it came to my address and I don't know why. MR. ASHFORD: Hang on. And how does that tend to prove or disprove the validity of the trust amendment? MS. MEEK: Well, it doesn't really do anything. So if you want, we'll just strike it. We won't use it. MR. ASHFORD: I'm kind of baffled. MS. MEEK: It was in my stack of things. So moving on, here is another affidavit that I'm -- Affidavit of Elizabeth Meek regarding a hearing dated January 6, 2006. It was prepared by the Bank of Hawaii. It was executed by Elizabeth

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on November 15th, 2005. If you could just take a look at this and make sure that this is -Do you recall this document? Make sure everything in there is correct.

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MR. ASHFORD: So what is your question to

MS. MEEK: Is everything in there correct? MR. ASHFORD: Okay. So you need to go through every paragraph and decide if you think everyone of the paragraphs is incorrect or correct or not if you know. BY MS. MEEK: Q Is everything in this document true and

correct? A Q Yeah. Thank you. Just a couple more. Okay.

Here's one. This is a Petition for Reformation of Trust Agreement with the hearing date 9-21-04 signed by Elizabeth Meek on the 12th of August 2004. Would you take a look at that document real quickly? Can you tell me if everything in there is correct? MR. ASHFORD: Let me look at that last page for a second.

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Nanci, just for clarification, do you want her to look at the one, two, three pages of text at the beginning, or do you want her to also look at the last three pages called Attachment to

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Petition? MS. MEEK: No. The Attachment to Petition is not necessary. Just we already know what the QDOT provision is. Q (By Ms. Meek) Do you understand what the

QDOT provision is? A Q A Yes. You do? Can you define it for me? Well, actually, if you're not a citizen,

you have to be -- you have to find somebody to pay -- you know, if you're not a U.S. citizen, then somebody who is a U.S. agency, bank or person can sell those -- can sell an asset. So in a way, it was any tax consequences on any assets get sold by a non-U.S. citizen. Q Okay. So having said that, now I'm up to

speed. You've clarified that very well. Very well. Did Robert Jones ever suggest to you to use Lola, since Lola was an American citizen, to help you sell properties? A Say that again.

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Q

Did Robert Jones ever sell to you having

Lola help you sell properties? A Q No. Why is that?

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MR. ASHFORD: Objection. THE WITNESS: I don't know. MR. ASHFORD: Calls for speculation. BY MS. MEEK: Q A Q A Q A Q You don't know? Yeah. She's an American citizen. Who? Lola. I don't know. And he never -- I know -- did he ever

make the suggestion to have myself or Melvin help you sell properties? A Q I don't know. You don't know or he just never suggested

it to you? Do you recall him making the suggestion? A Q I don't know. You don't know if he made the suggestion? MR. ASHFORD: Objection. Asked and answered.

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BY MS. MEEK: Q So, in other words, you don't recall him

making the suggestion? A I don't know.

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MR. ASHFORD: Same. BY MS. MEEK: Q A Q Did the subject ever come up? No. No, never came up. So then you don't --

okay. So you do know. It never came up. And you still don't recall when your citizenship was finalized? A Q A 2005. Q Do you think it was before the summer, do No, but it was in 2005. 2005? I don't know the month, but the year is

you recall? A I don't know. I don't recall. Yeah.

Uh-huh. Q Okay. Do you recall -- Elvin being an

accountant, do you recall him discussing ways to adapt the trust to be more -What's the word I'm going to use? -- beneficial with the IRS, in other

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words? A Q No. You don't recall him having those

conversations?

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A Q

No. Do you recall Elvin conversing with

Michael Gould over certain avenues that he could take with his estate that would help cut down on estate tax? A Q No. Do you recall having those conversations

with Michael Gould regarding what you could do to avoid paying estate tax? A Q No. Did you have those conversations with

Robert Jones regarding avenues that you could take to avoid, such as are included in here, to avoid having to pay tax on the estate? He didn't discuss that with you? A Q I don't recall. Oh, you don't recall him discussing it

with you. Okay. Do you want to take a lunch break? MR. ASHFORD: It depends how much time you're going to be.

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MS. MEEK: I'm going to say maybe an hour and a half at the most. MR. ASHFORD: Okay. My suggestion would be that we just take a break now and come back for

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one final session, so to speak, and then we'll save a lot of time, and the court reporter doesn't get paid by the hour. So she'd probably rather finish up sooner rather than later. MS. MEEK: Sure. (Brief recess.) BY MS. MEEK: Q This is two, three, four, five, five

pages out of the accounting that was done for the estate by East-West Wealth Management, and it covers the period October 19th through December 31st 2003. I've highlighted a couple of things for you to look at, and the dates on these transactions were 10-19-2003. Now I'm handing it over to Elizabeth to review. I would like to submit that as Exhibit 12. (Exhibit 12 is marked for identification.) BY MS. MEEK: Q Elizabeth, we're putting that down as

Exhibit No. 12. We're recording that as Exhibit

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No. 12. A Q A Uh-huh. Can you tell me what those deposits were? You know, I don't even remember.

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Q A Q A Q

You don't recall? No, I don't recall. You don't recall? Uh-huh. 10-19-2003, that was the day dad passed

away. You don't recall -A Q A Q I don't recall. -- making those transactions? Yeah. Uh-huh. Do you recall Robert Jones advising you

on making any bank transactions or any financial transactions at that time? A Q A Q No. No. He did not advise you to -No. -- remove any accounts or take any money

out of accounts? A Q No, no. So looking at this, the total of the

accounts when you add them up, total of the -- I believe it comes to 182,000. Does that sound about

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right to you? A Q A I don't know. You don't know? I don't know.

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Q

And you don't recall what those

transactions were for? A Q Yes, uh-huh. On two, three, four -- on the fourth page

at the top -- I apologize if I'm not -A Q Fourth -Just the fourth page at the top, yeah.

At the very top where it says, "Check, Waipuna, Transfer, reimburse funeral expense, 1,719." MR. ASHFORD: Hang on one second. We might be on the wrong page. MS. MEEK: Oh, I'm sorry. I apologize. One, two, three, four. MR. ASHFORD: So where are you looking? MS. MEEK: Page 4 at the top where it says "reimburse funeral expense." MR. ASHFORD: Oh, we thought you were talking about the portion you had highlighted. MS. MEEK: No. I'm sorry. I'm sorry. I didn't highlight that. I apologize. Q (By Ms. Meek) It says, "reimburse funeral

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expense, 1,719." Can you tell me what that was for? A This, I think, is for the crematorium

services.

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Q A Q

For Ultimate Crematorium? Yes. Was that a reimbursement to you or how

exactly is that transaction reflected? MR. ASHFORD: Objection. Calls for speculation. MS. MEEK: Well, I'm a beneficiary. So I would really like to know. MR. ASHFORD: My point is Elizabeth didn't prepare this. So I think you're asking the wrong person. That's what my objection is. MS. MEEK: Okay. MR. ASHFORD: Calls for speculation. Because you said, "How was this prepared?" She didn't prepare this. BY MS. MEEK: Q No. But did you have a chance to review

the accounting? A Q What do you mean accounting? The one that came out in 2007, the

accounting that East-West Wealth Management

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prepared for you from Francis Lui-Kwan. A Q That was 2007. Today's 2010. No. This came out -- was prepared in

2007. We asked for an accounting as early as 2004,

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but it wasn't until 2007 that we were actually provided with an accounting which covered several years. And the date on those particular pages reflect the transactions that were done from October 19 through December 31st, 2003. And the one at the top, I just wanted to know, the 1,719, that was for the funeral expense? A Q For the cremation services. Correct. If you go down one more line,

it says, "Deposit 10-19-2003, Elizabeth Meek, account opening, payable to Elizabeth Meek $60,453.60." Can you recall what that was for? A No. MR. ASHFORD: Objection. Asked and answered. THE WITNESS: I cannot recall. BY MS. MEEK: Q A Q A You cannot recall? Yeah. Wow. Yeah.

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Q A Q

You don't recall making that transaction? No. That's a pretty heavy-duty transaction to

make, $60,000.

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A

Oh, this is -- you're going to have to

give some area on all or every transaction that has been accumulated that year. Q Can you explain that to me? What was

that for that deposit? A Q I don't know. It says account opening. You don't

recall going to the bank and taking money out and putting it into a separate account? A It could have been the balance forwarded

or something like that for that account. It cannot be a deposit made on that day. It could have been forwarded account for that certain account, for that particular account. Q Can you explain that to me? MR. ASHFORD: Nanci, if you want, I'll try to get a letter from Francis Lui-Kwan explaining that. MS. MEEK: That would be wonderful. I would really appreciate that. Thank you. Would it be possible to get a letter from her explaining

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everything that's in the accounting? MR. ASHFORD: I won't volunteer that. It's a lengthy accounting. MS. MEEK: Well, it is.

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MR. ASHFORD: Sincerely, you've identified a question and I understand your question. I think Elizabeth is trying to articulate it, but I think I know the answer as well and I think I can get a letter to that effect for you. MS. MEEK: Specifically on that date? MR. ASHFORD: Yeah. MS. MEEK: On the 19th? On the day that he passed away? MR. ASHFORD: Right. MS. MEEK: Okay. MR. ASHFORD: And, fundamentally, it comes down to that's the date of death from which he started things. So that's -THE WITNESS: The date of death. MS. MEEK: Okay. Sure. And also too if you could ask her about the second page. MR. ASHFORD: I don't know. I don't have a copy of it. MS. MEEK: The one for 42,000.

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MR. ASHFORD: This is another October 19th, I assume? MS. MEEK: Yes. MR. ASHFORD: Sure.

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MS. MEEK: The one that says, "Payable to Elizabeth Meek." MR. ASHFORD: Right. If I may, can I just make a copy of that? MS. MEEK: Sure. MR. ASHFORD: In fact, I think you were identifying that as an exhibit. So you don't want to put that in your briefcase there. MS. MEEK: Oh, make a copy. I'm sorry. Thank you. MR. ASHFORD: This is the same thing? MS. MEEK: Same thing. Same thing. MR. ASHFORD: We'll go off the record for a moment. MS. MEEK: Off the record. (Brief pause in the proceedings.) BY MS. MEEK: Q Back on the record quickly. Elizabeth, this is an Endorsement for Change with Allianz Annuity which were annuities that you had changed apparently from the primary

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owner being Elizabeth Meek and then with the beneficiary being -- primary beneficiary as Lola Meek and contingent beneficiary estate of Elizabeth A. Meek. There are three annuities and

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endorsements for change. I want you to take a look at that. A Q copy. A Q This is private. The life insurance, that wasn't part of How did you get this? I contacted them and asked them for a

the trust? A Q A Q A Q No. 13. (Exhibit 13 is marked for identification.) BY MS. MEEK: Q A Q Do you recall making those changes? Yes. Was that on your own? Was that with any Huh? That wasn't part of the 1996 trust? I don't know. You don't know? Okay. Okay. I'll submit this as Exhibit

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counseling from Robert Jones that you made those changes? A Q No. On my own. On your own you made those changes?

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A

They wrote the letter to me. So I had to

do it. I made them do it. Q A Q And that was from Sanford Norian? Yes. And these were annuities that were

started by Elvin -A Q A Q Yes. -- that were placed in your name? Yes. And according to what Sanford Norian has

provided me, and correct me if I'm wrong, but before dad died, he was quite specific, and in the event that something were to happen to him, he wanted it divided up a third and a third and a third amongst myself, Melvin and Lola; is that correct? MR. ASHFORD: Objection. Vague and ambiguous. BY MS. MEEK: Q It's not vague and ambiguous. I had a

conversation with Sanford, and he pretty much

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explained it to me, and I do have the documentation that I can provide for the court. But I'm just asking do you recall that that's the way the distribution was?

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MR. ASHFORD: Objection. Vague and ambiguous. BY MS. MEEK: Q Do you recall what the distribution was? MR. ASHFORD: Same objection. THE WITNESS: I was the primary beneficiary. BY MS. MEEK: Q Absolutely, yes, you were. I will not

argue that. Absolutely, you were. Again, I will not argue that. Prior to his passing away, who were the beneficiaries in the event of your death, do you recall? A Q A Q No. You don't recall? No. If you don't recall, then what were the

changes that you made? MR. ASHFORD: Objection. The document speaks for itself.

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MS. MEEK: Well, I just want to know what the changes were. MR. ASHFORD: Are you referring to something that's on the document?

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MS. MEEK: Yes. MR. ASHFORD: That's why I make my objection. MS. MEEK: Right. MR. ASHFORD: Right. BY MS. MEEK: Q Who were the beneficiaries prior to your

change, do you recall? MR. ASHFORD: Same objection. BY MS. MEEK: Q say? Okay. We'll move on. Quickly, I am submitting as Exhibit No. 14 a Power of Attorney and Declaration of Representative that is in response to -- I'm sorry -- is from Jane Peebles. Elizabeth A. Meek, Trustee of the Estate of Elvin R. Meek, Elvin R. Meek Family Trust. This is signed by Elizabeth. It's tax form 2848 signed by Elizabeth on 3-12-07 and also signed by Jane Peebles on 3-8-07. Do you recall or do you just not want to

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If you can take a look at that, please, Elizabeth. Do you recall signing that document? A Yes. (Exhibit 14 is marked

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for identification.) BY MS. MEEK: Q for? MR. ASHFORD: Objection. Calls for speculation and opinion. Document speaks for itself. BY MS. MEEK: Q In your opinion, what is it for? MR. ASHFORD: Same. THE WITNESS: It's a Power of Attorney and Declaration of Representative. BY MS. MEEK: Q That's what it says, but what is it -Briefly, can you tell me what that was

can you elaborate a little bit? If I were a lay person and I needed this document, why would I need this document? MR. ASHFORD: Objection. Calls for opinion. MS. MEEK: I just want to see if she knows what it's for.

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MR. ASHFORD: Then you probably ought to talk to an attorney. That's the basis for my objection. BY MS. MEEK:

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Q

So, in other words, you can't tell me off

the top of your head what this is for? A Well, I authorized Jane Peebles to

represent me as her (sic) attorney. Q A estate. Q A Q She was the IRS attorney? Uh-huh. Do you recall the name of the firm she And who is Jane Peebles? It was the IRS attorney representing the

was with? A I think he (sic) was with Bingham, but

now he's (sic) the sole practitioner. Q A Q A Jane Peebles? Yeah. She's a sole practitioner? Yeah. She was out of the Bingham's law

firm and then she established herself. Q Do you recall writing a check to their

law firm for payment for services rendered? A I think I did, but it's been --

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Q A Q

Do you recall the amount of that check? No, I don't. I recall. I believe it was 45,000. Is

that a ballpark figure?

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A Q A Q

It could be. Does that sound about right to you? It could be. That sounds about right to you. Okay. And Jane Peebles became your

representative for what reason? MR. ASHFORD: Objection. Asked and answered. THE WITNESS: For what reason? BY MS. MEEK: Q A Q A Q Correct. I think estate got audited by IRS. Why was the estate audited, do you know? I really don't have any idea. You don't know why the estate was

audited? A Q I don't know. Just for the record, I'm not going to

submit this as evidence, but I do want you to take a look at it. This is a pleading, a notice of hearing and a pleading -- petition, I'm sorry, that

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was filed by Bingham and McCutchen by Jane Peebles with the Superior Court in the County of San Luis Obispo. I want for you to take a look at it if you could. It's dated April 10th, -- the hearing was

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April 10th, 2007. It is signed by Jane Peebles on February 16th, 2007, and it is called the "Petition for Order Clarifying Prior Order and Judgment on Second Amended Petition for Reformation of Trust Agreement Confirming Relationship Between 1992 and 1996 Trust and Instructing Petitioner Regarding Sale of Real Property." Could you take a look at that, please, for me. Do you recall seeing that document? MR. ASHFORD: Do you want her to look through the whole thing before she answers or not? She's gone through a portion of it. MS. MEEK: I'm just asking off the top of her head if she remembers reviewing it and seeing it. THE WITNESS: I remember, yes. BY MS. MEEK: Q A Q Huh? I remember seeing that. You remember seeing that. Do you recall

that the dates are correct on that, February 16th,

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2007? A Q February? February 16th 2007. MR. ASHFORD: She's asking the day it was

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signed, not the file date. THE WITNESS: I didn't sign it. BY MS. MEEK: Q A Q No, you didn't sign it. I didn't. No. I know you didn't. I'm just asking

if you recall the document. MR. ASHFORD: No, that's not what you asked her. BY MS. MEEK: Q I'm sorry. Do you recall -What did I say? MR. ASHFORD: You asked if she could confirm the date of signature, but the signature is someone else's. BY MS. MEEK: Q that. The hearing date was April 10th, 2007? Is that what it says there? Is that correct? A Yeah. I know. I'm sorry. I apologize for

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Q A Q A

Do you recall the hearing? Huh? Do you recall when they had this hearing? On April 10, 2007.

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Q

Do you recall what it was about? MR. ASHFORD: Objection. Form.

BY MS. MEEK: Q If you don't recall, it's okay if you

don't recall the reason why they went to court. I just wanted to know if you knew why, what the purpose of that document was. MR. ASHFORD: Objection. You're changing your questions and you're not -- you're confusing your question. You're mischaracterizing your question in your statement. That's my objection. BY MS. MEEK: Q Do you understand why -- can you tell me

why Jane Peebles went to San Luis Obispo, went to the court in San Luis Obispo? MR. ASHFORD: Objection. Vague. THE WITNESS: No. BY MS. MEEK: Q No, you can't tell me. Do you recall receiving this document? A Yes.

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Q

Can you tell me in your words why it took

four years for an audit -- I mean, for a tax return to be filed on the estate? MR. ASHFORD: Objection. Calls for

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speculation. BY MS. MEEK: Q Do you know -- do you have an opinion on

that? Do you know what the holdup was? MR. ASHFORD: Same. THE WITNESS: Well, I thought they were already filed. I don't really remember. BY MS. MEEK: Q A What were you told? I thought every time when I send

everything to Michael, you know, he had filed them already. Q So you thought that during that four

years -- am I to understand that you thought during those four years, Michael Gould had actually filed the tax return every year -A Q A Q return? Yeah. -- had been filing the tax return? (Witness nods.) Do you know why he hadn't filed that tax

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MR. ASHFORD: Objection. Compound. BY MS. MEEK: Q Well, did your attorney ever explain to

you why it took four years?

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A

I don't know. That's the reason why I

had Grigger -- had Grigger and Mike Gould work together to put the tax returns together. Q Did you ever sign any of those tax

returns? A Q A Q For my personal taxes filing, yes, I did. You did for your personal taxes? Yeah, but not for the estate. But you were under the impression -- just

so I'm clear, you were under the impression that for four years prior to the audit being performed, the tax returns were actually being prepared and filed -A Q A Q Uh-huh. -- by Michael Gould? (Witness nods.) How did you react when you found out that

they hadn't been filed and that there was going to be a tax audit? What was your reaction? Were you upset? A Well, they were in the process of doing

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them. So I just thought it would gradually get done. Q This is going to be Exhibit No. 15. This

is a letter dated February 22nd, 2007, and it's

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addressed to you and it's from the IRS. It looks to me like it's -It says, "The Federal estate tax return indicated above has been assigned to me for examination, and we are writing to you pursuant to your authorization to act as the estate representative before the IRS. Please provide the following by March 12th, 2007," and then there's a list of items that they need copies of all fiduciary income tax returns, copies of documents to explain why they hadn't been filed, et cetera, et cetera, et cetera. It's a three-page document signed by Megan Abrishami, Attorney, Estate Tax. If you could take a look at that. Do you recall receiving that letter, Elizabeth? A Well, I may have, but I just -- it's been

a while. So I don't really -(Exhibit 15 is marked for identification.) BY MS. MEEK: Q Do you recall when you received this --

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You don't recall receiving this letter? I may have. You do? Yeah. That's 2007. So I may have

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received it. It's probably in the file, my file. Q But you don't recall then what you did

right after you received this letter? Did you call Robert Jones or Michael Gould? Pretty powerful letter. A Yeah. I think I did call Michael Gould,

and they did get in touch with Jane Peebles. Q A Q A Q Who contacted Jane Peebles? I think I did call Michael. You called Michael Gould? Yeah. Uh-huh. Okay. And Jane Peebles, was Jane Peebles

the attorney for the estate or was she the attorney for Bank of Hawaii? A Q I really -- yeah, I don't recall. You don't recall. Okay. This is being put in as Exhibit No. 16. I'm almost done. (Exhibit 16 is marked for identification.) BY MS. MEEK:

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Quickly, this is Exhibit No. 16. This is a letter from Jane Peebles to Ms. Abrishami regarding the estate of Elvin R. Meek. It is dated April 27th, 2007.

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The way I interpret this letter, it is a response to the letter that was sent to you from the IRS. It is CC'd to Elizabeth Meek, Penny Tong, who I understand is with the Bank of Hawaii, the law firm that handles the Bank of Hawaii, Michael Gould, the CPA, and Robert Jones, and it is dated April 27, 2007. Quickly, take a look at it. Do you recall getting that letter to the best of your knowledge, a copy of that letter? A Yes. It's in my file. MS. MEEK: Okay. I'm going to submit as evidence as an exhibit if it's okay. This is a several paged document. I don't know if this is okay with you, Mr. Ashford, but it's basically a Schedule M from the estate tax return form 706 with these two attachments. Do you want me to submit it all as one document? Take a look at it and let me know. MR. ASHFORD: I don't really care if you do it as one, two or three. My only concern is

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that, you know, the tax return information is really kind of confidential information, and my concern is about this getting out into the public realm because other documents have already, but I'm

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not going to tell you -MS. MEEK: Well, this document is not going to get into the public realm. It's just within us for the purposes of the evidentiary hearing. But is it okay if I submit it all as one document? MR. ASHFORD: Let me respond to your statement. That's the hope, but court records are public documents. MS. MEEK: Oh, I see. MR. ASHFORD: But as to whether you treat that now or at the hearing as one, two or three documents, I really have no preference on that. MS. MEEK: Well, I'll tell you we'll go ahead and submit it anyway. We'll submit it as three different exhibits. The first one is the Schedule M Bequests to Surviving Spouse. This is part of the tax audit, tax return that was prepared by Michael Gould. My purpose for bringing it in as evidence is specifically a page in here where it mentions

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that there is no estate tax, no death tax and no skipping tax. I just wanted it on the record. So I also want Elizabeth to take a look at it. So let's make this Exhibit 17.

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MR. ASHFORD: If you want, Nanci, you can read portions in, and I'll stipulate, if I can read along with you, that you read them correctly if you want to do it that way. MS. MEEK: That's fine with me. MR. ASHFORD: I don't know what portions you want to read in, though. You identified something generally that you wanted -MS. MEEK: Basically, I wanted Elizabeth to take a look at it and make sure that she had a chance to review it. And if she -Q (By Ms. Meek) Do you recall -- I just

want to know after you review it if you recall receiving this from Michael Gould, and if there was anything in there -On the second page, it's signed by you. Is it says 4-25-07. I just want to make sure that that is your signature. MR. ASHFORD: So, Elizabeth, I think there are two questions. One is whether you're able to confirm your signature on whatever page

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Nanci mentioned, MS. MEEK: Page 3. The third page down. MR. ASHFORD: So the question is whether you can say that that's your signature. And then a

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second question is, I believe, do you remember receiving this whole document from Michael Gould? MS. MEEK: Correct. THE WITNESS: Okay. This is my signature right here, 4-25-07. MR. ASHFORD: And then the next question is you answered -Keep that in order. That's all right. I think it goes here. The next question is whether you recall receiving this document from Michael Gould. MS. MEEK: No. Let me retract that. I'm not asking if she recalls receiving it. Q (By Ms. Meek) To the best of your

knowledge, did you review it before you signed it? A Q Yes. You did. Okay. MR. ASHFORD: So you're putting that into the record as an exhibit? MS. MEEK: Correct. MR. ASHFORD: Okay.

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(Exhibit 17 is marked for identification.) MS. MEEK: Okay. And then the Exhibit No. 18 is going to be this document here which is

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part of this. It's called Form 706, and it's just a supplemental Schedule A for the real estate as was valued with the tax return. Do you want to take a look at that, Elizabeth, and tell me if that's correct? MR. ASHFORD: What is your question? Sorry. MS. MEEK: I just want to make sure she takes a look at it. Because it was part of this that you signed. I just want to make sure you have a chance to look at that before I submit it as the exhibit. (Exhibit 18 is marked for identification.) BY MS. MEEK: Q Okay. This was a letter that was

provided to me -- sent to me from the Bank of Hawaii, dated May 22nd, 2007. Basically, what it says is it's addressed to Elizabeth Meek, Melvin Meek, Lola Meek and Nanci Meek, and it just says, "Ladies and Gentlemen, Bank of Hawaii hereby

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advises you of its resignation as cotrustee of the qualified domestic trust established under the trust, the QDOT." And, essentially, what it is is they are letting us know that they are going to be

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withdrawing as cotrustee. If you could take a look at that letter. Elizabeth, do you recall receiving a copy of that letter? A Q Yes. Thank you. Elizabeth, did you ever have a chance to look at the medical forensics report that was provided to your attorneys? A know. Q You don't recall receiving a copy of it? MR. ASHFORD: Objection. Misstates her testimony. Your question was whether she had a chance to look at it, and she said she doesn't recall. BY MS. MEEK: Q Oh, do you recall receiving this I don't recall. I may have. I don't

document, the medical forensics? A I may have. I don't really recall when.

Can I look at it?

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Q A

Absolutely. Oh, okay. MS. MEEK: Can we go off the record real

quickly?

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MR. ASHFORD: Sure (Off-the-record discussion.) BY MS. MEEK: Q This is an email that was sent to me from

Rhonda Griswold, and it is dated November 9th, 2009. Basically, it says, "Nanci, I have confirmed with Francis Lui-Kwan, the Trust's CPA, that the proceeds from the Unionbancal check were used to purchase two CD's in the name of the 1996 trust, one CD in the amount of 600,000 and one in the amount of 46,481.96. That purchase is reflected in the 2004 accounting that was provided to you earlier. "Also, as explained to you numerous times before and stated in court pleadings, your father intended that the assets of the 1992 trust be transferred to the 1996 trust." Did you want to take a look at it before I submit it as evidence, I mean, as Exhibit No. 19? (Exhibit 19 is marked for identification.)

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BY MS. MEEK: Q Do you have any opinion about that email

one way or the other? A No.

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MR. ASHFORD: Objection. Vague. BY MS. MEEK: Q Do you agree with it? MR. ASHFORD: Objection. Compound. BY MS. MEEK: Q Is that correct? Were those CD's created

to the best of your knowledge? Were they created? MR. ASHFORD: Objection. Vague. BY MS. MEEK: Q You're the trustee. You don't want to

answer? A Well, they were -- they are in the bank,

the CD's. Q A Q Well, then the answer is yes? Yes. Okay. Earlier we were talking about the

first amendment that was signed in California in Robert Jones' office, and this is an email from Rhonda to me dated 10-1-2009, and I want to submit this as Exhibit No. 20. I want you to take a look at it, Elizabeth, please, and tell me if you have

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an opinion as to that. (Exhibit 20 is marked for identification.) BY MS. MEEK:

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Q

Do you have an opinion either way as to

that email? MR. ASHFORD: Objection. Vague and compound. THE WITNESS: No. BY MS. MEEK: Q A Q Do you agree with it? Yes. Yes. Thank you. Are you able to tell me what the status is of the exemption trust? A The status of exemption trust? Well, it

hasn't been affirmed because you objected to it. It hasn't been set aside. Q Is that the way Rhonda Griswold explained

it to you? MR. ASHFORD: Objection. Don't answer the question. That calls for attorney-client privileged information. BY MS. MEEK: Q Okay. What do you base that on?

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A Q

What you mean? The exemption -MR. ASHFORD: Excuse me. Before you

answer the question, I instruct you not to reveal

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anything that anybody in this law firm, particularly Rhonda Griswold or I, told you that you deemed to be confidential at the time. BY MS. MEEK: Q Do you recall any mention of the First

Hawaiian Bank handling the exemption trust? MR. ASHFORD: Objection. Vague. BY MS. MEEK: Q A You don't recall? (No response.) MS. MEEK: Do you want to take a break for lunch or are we okay? MR. ASHFORD: No. It sounds like we're almost done. MS. MEEK: Yeah, we are. (Exhibit 21 is marked for identification.) BY MS. MEEK: Q This is a letter I'm submitting as

Exhibit No. 21. This is a letter dated June 28th, 2005, sent to Elizabeth from Wes Stewart.

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Did you read the letter, Elizabeth? Uh-huh. Do you have an opinion one way or the

other about it?

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A Q A Q

No. Nothing to remark about? No. Submitting this, this is an email dated

October 4, 2007, sent to me from Wes Stewart. I'm submitting that as Exhibit No. 22. Take a look at that, Elizabeth, please. (Exhibit 22 is marked for identification.) MR. ASHFORD: Nanci, have you produced this document to me? MS. MEEK: It should be filed with the pleadings. MR. ASHFORD: I don't recall it. So you don't know? MS. MEEK: I can't recall. I think it's in the pleadings. That's why I didn't provide it. I think it was already submitted to the court. MR. ASHFORD: When? MS. MEEK: I don't know. I'd have to look it up.

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MR. ASHFORD: Can you find out? MS. MEEK: Do you want a copy? MR. ASHFORD: No. Really what I want is I want you to produce all responsive documents in

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response to my request because I asked you yesterday in your deposition about a few documents that you said you hadn't produced them. MS. MEEK: I'll be honest with you, I don't know. As far as I know, that letter is dated -- I mean, he's been dead for what? Three years now. MR. ASHFORD: Right. But my point is you need to produce to me in a timely manner all your responsive documents, and you've admitted in your deposition yesterday that you haven't. I could be wrong, but I don't think you produced this one either, and it's your responsibility as a litigant to produce everything. When I ask if you have, it's not my burden to find out. It's yours. Okay? So I want you to find out whether you produced this to me or not. Okay? Will you do that? MS. MEEK: Yes. MR. ASHFORD: Thank you. When will you give me a response? MS. MEEK: I will have to give it to you

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when I get back to Las Vegas. MR. ASHFORD: When will that be? MS. MEEK: A week from today. MR. ASHFORD: Okay.

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BY MS. MEEK: Q Do you have an opinion one way or the

other to that email? MR. ASHFORD: Objection. Vague. THE WITNESS: You mean the whole letter? BY MS. MEEK: Q A Q Any part of it. I don't know. Do you have any objection to anything he

says in here? A Q No. You don't object to anything that he says

in there? He mentions the thing about Lola with the car. I don't really care to go into that too much further, but do you agree with this letter? Do you think everything in there is true? A Q No. Okay. Here is an email addressed

October 23rd, 2004, and I know this one was already submitted to the court, and it's addressed from Wes to myself and we'll submit it as Exhibit No. 23.

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(Exhibit 23 is marked for identification.) MR. ASHFORD: Nanci, while Elizabeth looks at it, I want to put you on notice on the

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record that whatever documents you haven't produced to me already, I'm going to object to the court you trying to introduce those at the hearing because you were supposed to produce them a long time ago. MS. MEEK: You asked me to produce them on Friday; correct? MR. ASHFORD: No. I asked you to produce them in my first request -MS. MEEK: I'll produce them next Friday. MR. ASHFORD: Let me finish. I asked you to produce them in my first request for discovery to which I had to file a motion to compel production. The judge granted that. That was back in Judge Harai's days -MS. MEEK: Okay. MR. ASHFORD: No. I'm not finished Over a year ago, she ordered you to produce everything. I asked you for much of the same documents again in February. MS. MEEK: Okay. Let's put this off the record, please.

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MR. ASHFORD: No. I want this on the record. MS. MEEK: Oh, you do want it on the record. I'm sorry.

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MR. ASHFORD: That's my whole point. I said I want this on the record. I submitted a second document request to you in February. It was due in March. I had to file a petition to compel documents on that one as well. The judge granted that motion. So you failed to produce documents in response to at least two different requests, and that's the basis for me objecting to these things at the hearing. To respond to your statement, I didn't ask for you to produce these next Friday. I asked for you to produce these over a year ago and over a few months ago a second time, and you failed to do it in both instances, and you failed to do it in response to two different orders from the judges to produce things. That's the basis for my objection. MS. MEEK: Okay. Let the record show that to the best of my knowledge, this document in particular was already submitted to the court. MR. ASHFORD: Nanci, when was it submitted?

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MS. MEEK: Oh, I want to say it was submitted when the case was in California to the best of my knowledge. MR. ASHFORD: You're telling me that this

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was submitted in the California proceeding, but not the Hawaii proceeding? MS. MEEK: It was submitted when the case was in California, I do believe. I don't know. Like I said, I would have to look at the -- I would have to look at the document. MR. ASHFORD: And are you going to find out the answer to that for me by next Friday as well? MS. MEEK: Yes, I will. Absolutely. MR. ASHFORD: Thank you. MS. MEEK: Let's see. Moving on to -So any of the other discovery that I have, any of the other emails and letters, you don't want me to include as exhibits until I produce them to you? MR. ASHFORD: No. The more accurate statement would be if you haven't produced documents to me that were responsive to either or both of my prior requests, on that basis alone I'm going to oppose them as exhibits at the hearing

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because you were supposed to turn them over a long, long time ago. MS. MEEK: Well, my confusion with that is this; that I did a motion to compel a year ago

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with Rhonda asking for several documents. Included in those documents were not several of the documents that you produced to me yesterday during my deposition. So at that time should I have objected? MR. ASHFORD: I'm not giving you legal advice, but I will tell you two things. One, your motion to compel was denied by Judge Harai. MS. MEEK: Correct, it was. MR. ASHFORD: Secondly, you might want to look at the documents that you requested and look at the scope of what you requested and decide whether what I have used in this case was within the scope of what you've requested. MS. MEEK: I see. Okay. Okay. So, in other words, my motion was denied for the production of documents. So, therefore, I don't have any recourse or any way to object to any documents that you introduce? MR. ASHFORD: That's not what I'm saying. I'm saying you brought it into this discussion the

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fact that you filed a motion to compel. I'm saying that motion seemingly has no relevance to this because the judge denied it primarily, as I recall, because what you're asking for was too broad and

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wasn't appropriate. MS. MEEK: Okay. So now how could I get these documents that I have that I would like to submit to the court to you? MR. ASHFORD: I encourage you to send me whatever you haven't yet sent me, whatever documents you haven't yet provided. I'll remind you that in your deposition yesterday on the record, I asked you whether you have produced to me all responsive documents, and you said yes. MS. MEEK: I thought I had. MR. ASHFORD: I think what I'm hearing from you 24 hours later is you were wrong -MS. MEEK: I was wrong. MR. ASHFORD: -- and you haven't. MS. MEEK: Very wrong. So I will resubmit those to you. MR. ASHFORD: I suggest you do that immediately. MS. MEEK: I will. I will. Immediately, would you like for me to make copies of them and

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bring them back to you? MR. ASHFORD: That would be prudent, yes. MS. MEEK: I will do that being that there's a Kinko's around the corner. Okay. Let's

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do that then. Absolutely. And just for the record, I will be doing that. Okay. The only final thing that I want to introduce and I want to talk about are the medical records, the report that was produced by Suzanne Gelb after reviewing the medical records that we had obtained. We'll start with -- there's just a few highlights. We'll start with letting Elizabeth have a copy of this. I'll let you take a look at that. Again, this has already been submitted to the court. Should I submit it as another exhibit? MR. ASHFORD: Again, I'm not -MS. MEEK: Yeah. Let's submit it as Exhibit No. 24. MR. ASHFORD: To complete my statement, I'm not going to tell you what to do. MS. MEEK: I understand. (Exhibit 24 is marked for identification.) BY MS. MEEK:

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Q

This is entitled the "Report of Forensic

Psychological Evaluation" on Elvin R. Meek, date of death October 19th, 2003. The report was dated February 28th, 2007.

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Elizabeth, if you can turn to the second page. Let me ask you a quick question. Do you understand what testamentary capacity means? MR. ASHFORD: Objection. Vague. Are you speaking of the legal term "testamentary capacity." MS. MEEK: I just want to know in general if she knows what "testamentary capacity" means because it is referred to several times in the report. MR. ASHFORD: Right. And just to be real clear, my objection is that your question is vague and apparently calls for a legal conclusion. That's why I asked if you're asking her if she knows what the legal term or, for that matter, the medical term "testamentary capacity" means. MS. MEEK: Yeah. The first paragraph -I'm sorry. The second paragraph on the second page, it defines testamentary capacity. If you could have a look at that. MR. ASHFORD: You're talking about the definition from the --

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MS. MEEK: Correct. MR. ASHFORD: -- decision in re: Estate of Herbert; right? MS. MEEK: Yes.

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THE WITNESS: What page are you? MS. MEEK: Second page. MR. ASHFORD: She's asking about this. BY MS. MEEK: Q As you go down towards the end of page 2,

Elizabeth, the second to the last paragraph where it says, "Around October 14th, Melvin spoke with Mrs. Meek on her cellphone and inquired about his father's condition," do you see that? A Q Yeah. And it says, "Mrs. Meek said, 'He's a big

man and he can call you himself.'" Do you recall that? A Q I don't recall. Okay. Going to the next page there where

it says, "Summary of medical history 8-27-03 to 10-19-03." If you read down the next paragraph down where it says, "On August 27th, about two thirds of the page down, the patient was discharged from the hospital." Do you recall his being in the hospital and his being discharged on August 27th?

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A Q A Q

I don't recall. You don't recall what his condition was? He may have. I don't recall. And when you read along, it says,

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"Mr. Meek remained at home for the next 11 days from September 20th through October 2nd. Then on October 2nd, Mr. Meek was readmitted to the hospital." Do you recall why he was readmitted to the hospital? A Q A Q A Q A When? On October 2nd. I think he had a fall. Did you call an ambulance? Yes. Was the fall from his losing his balance? I don't know because he just fall in the

bedroom. Q A Q A Q A Q Fell in the bedroom -Yes. -- or in the bathroom? Bathroom. In the bathroom? Uh-huh. So it is the bathroom. Okay. I apologize if these pages --

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well, they're numbered, but they're numbered at the top. So if you want to take the clip off there, that would be easier for you to read. Let's skip ahead quickly to page 4 about

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one, two, three paragraphs down where it begins, "Dr. Zerez assessed the patient as having 12 medical conditions, including volume depletion, congestive heart failure." Do you see that? A Q Uh-huh. Yes. Does that sound about right to you? MR. ASHFORD: Objection. Vague. THE WITNESS: I don't know. BY MS. MEEK: Q Well, that's according to the medical

records. It says he was taking 12 medications. Do you recall when he had the operation to insert the triple lumen venous catheter? Do you recall that, when they did that operation on him? A Q A Q I don't recall when was this. You don't recall? I don't recall. Let's skip ahead to page 9. Scroll down

to half the page where it says September 17th and then scroll on down where it says, "The patient met with the social worker for hospice consultation or

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consult." Do you recall that, meeting with the hospice care worker, caseworker? A Q No, I don't remember. You don't remember?

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A Q

Yeah. You don't remember when that was

happening? A Q No. Let's go to page 11. Halfway down the

page, let's see, I'll identify it for you. One, two, three, four, five paragraphs down, do you see that where it says, "The types of wounds"? It says, "The types of wounds which the patient suffered were identified as pressure ulcers and is traumatic." Did Elvin have bed sores? Is that what that's referring to, do you recall? Q (No response.) MR. ASHFORD: Objection. Calls for speculation. Document speaks for itself. BY MS. MEEK: Q Let's scroll down to two thirds of the

page down where it says September 19th. Do you see that, Elizabeth? A Yes.

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Q

It says, "The patient's wounds were

identified as traumatic." It says, "At 0800, the patient was suffering sharp constant pain." And then you get down to the end, it says, "Patient and

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wife agreed to home hospice. Referral made." MR. ASHFORD: You're at the very bottom paragraph? BY MS. MEEK: Q down. Do you see that? Do you recall what his condition was on September 19th, 2003? A Q A Yes. How would you define his condition? Well, he was -- you know, he was already Very bottom paragraph. Keep scrolling

where he was at. Q A Was he still in the hospital? I don't recall because in hospital or

perhaps discharging or what. I don't recall that. Q Do you recall if his abdomen was -- was

he bloated and his abdomen distended? A Q No, I don't recall that. Let's go to page 12. The heading there

where it says -- at the top, it says, "At 1500, the social worker telephoned Mrs. Meek. She stated

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that the patient wants to hold off meeting with hospice until he goes home." Do you recall that? A Yes.

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Q

Is there anything you want to tell me

about that conversation? A Elvin didn't want -- didn't want to be in

hospice. Q Okay. September 20th -MR. ASHFORD: What page are you on, Nanci? BY MS. MEEK: Q The same page. The next paragraph where

it says "September 20th" there on the same page, page 12. And you keep scrolling down where it says, "Notes at 11:15 a.m. concerning discharge." And then you keep scrolling down, it says, "It appears that Mrs. Meek signed both pages of the patient discharge instruction form on behalf of the patient." It says, "18 medications were listed on the form." 18 medications. Because it says, "Mrs. Meek signed both pages of the patient discharge instruction form," am I to understand that you were responsible for all of those medications or would he be able to

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take those medications on his own? A Well, actually, I'm signing. I have to

take them out of the hospital, and then helping him taking them at home, that's another thing. So

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that -- I did that too. I did help him. Q There are several times, several entries

in here where it mentions that patient was admitted for weakness and hypertension and his volume depleted. Was he dehydrated a lot during that time? A I really don't know. Might have. I'm

not a doctor. Q A But you don't recall? Yeah. Every time there's something, we

have to go to the hospital and keep up with hypo and things like that. Q Two days later according to this at

bottom here, it says, "Signed the second amendment." And then September 23rd signed the will. And then on page 13 -- page 13 at the top, it says, "Signed the will." And then, "October 2nd, the patient was rehospitalized." When he was rehospitalized on October 2nd, when they were taking him to the hospital in the ambulance, was he conscious?

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A

Very conscious. He was -- he was

conscious, yes. He was joking with the people who came and picked him up. Q Really?

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A Q

Yeah, really. Because here it says -- the next

paragraph down, it says, "Emergency physician characterized the event as lost consciousness." A Uh-uh. MR. ASHFORD: Meaning the fall or the ambulance ride? BY MS. MEEK: Q That was in the ambulance. It says,

"Although, patient was still awake and responsive." Finally, go to page 25, please. This is the last paragraph there where it says, "Recommendations." If you could read that, please. MR. ASHFORD: Which? There are four paragraphs there. MS. MEEK: Page 25, the one titled Recommendations. MR. ASHFORD: Yeah, but there are four paragraphs. MS. MEEK: I apologize. Just read the first three paragraphs --

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MR. ASHFORD: You want her to -MS. MEEK: -- under "Recommendations." MR. ASHFORD: Do you want her to read those into the record or do you want her --

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MS. MEEK: Just read those on her own. MR. ASHFORD: -- to read to herself? BY MS. MEEK: Q To yourself. Do you have an opinion one way or the other to those last three paragraphs? A No. MR. ASHFORD: Objection. Vague. BY MS. MEEK: Q A Are they accurate do you think? I don't know. MR. ASHFORD: Objection. Calls for an opinion about a psychological opinion. BY MS. MEEK: Q Okay. I'm done. At this point, Elizabeth, is there anything that you've said so far that you may want to retract or you may want to change or anything you may want to refer to? A Q No. Okay.

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MR. ASHFORD: Before we go off the record, can I grab some of those exhibits and copy them because I haven't seen all this stuff before? Do you mind, Nanci?

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MS. MEEK: No. MR. ASHFORD: Is that all right with you, Laura? THE REPORTER: Yes. (Brief recess and Exhibit 25 is marked for identification.) MR. ASHFORD: So while we were off the record, I photocopied some of the exhibits that Nanci Meek introduced today in the deposition, some of which, as I already put on the record, had not been previously produced. Ms. Meek also produced to me for the first time roughly 20 pages of documents, emails and the like, which we have marked as Exhibit 25 to Elizabeth Meek's deposition. It's my understanding, and, Nanci, if you can confirm this, the documents that are Exhibit 25 to Elizabeth's deposition are documents that you have not previously produced to me; is that accurate? MS. MEEK: That's correct.

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MR. ASHFORD: I have nothing further. Anything you need to add, Nanci? MS. MEEK: The only thing I want to add is just briefly before we finish is just have

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Elizabeth look at Exhibit 25 and just read it through. MR. ASHFORD: You want her to read every page of that? MS. MEEK: Yeah. It won't take that long. THE WITNESS: All these emails? MS. MEEK: Yeah. These are emails and letters that were sent to me. MR. ASHFORD: And what do you want her to answer? MS. MEEK: I just want to see if you have any comments to make after you look at them. That's all. The first one I think is from Armstrong. I guess, basically, what it is it kind of gives you an idea because you were not communicating with myself and with Melvin, and these other people were communicating with me, maybe it kind of gives you a better understanding of where we were coming from and how we were

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possibly being influenced from other people. MR. ASHFORD: Okay. And I understand what you're saying. MS. MEEK: You understand what I'm

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saying? MR. ASHFORD: I absolutely do. Can I suggest that she look at these in a more deliberate and leisurely manner, and if she or I want to -I understand what you're saying. So if we want to respond to it, then we'll do that independently as opposed to have her read all this now. MS. MEEK: That would be fine with me. That's fine with me. I don't have a problem with that at all. Basically, just for the record what they are is the first one is a letter that was sent to me in 2006 from Armstrong, Lola's ex-husband. The next one was from -- just dated December 2006 from Rose, not Rose Taneo, but another Rose. Another one is dated 2-15-2008 from Miriam. Then another one is from Steve Nakamura that's dated June of 2005. Another one from Armstrong, Lola's husband, dated 3-27-2006. One from Kaleb Udui that's dated 5-2-2006. One more from Rose Taneo that's dated

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1-23-2006. Another one from Armstrong, Lola's ex-husband, dated 1-24-2006. Another one from Miriam dated 9-12-2007, and another one from Miriam dated 9-10-2007.

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To the best of my knowledge, these are all people that live in Palau. One that was sent to me from Imelda Nakamura which is dated 11-15-2004 which, for the record, is an email that was sent to me, and then I responded to that email with an email that was brought up yesterday during my deposition. Then there's one dated 8-31-2005 from Fritha, and one dated 11-10-2004 from Weldon, which refers to the court not being able to help us out with information that we were asking for. 6-7-2006 again from Armstrong, and the last one is dated 11-8-2009, and that came from Phil Reklai, and that was the request that he had made to me about -Oh, never mind. This was a different one. That's it. I just wanted to have for the record what they were. MR. ASHFORD: Nanci, I think I understand what you said that you were apparently relying on what these people said, and I'll just leave it at that. I won't make any editorial comment. Thank

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you. We're done. (Whereupon the proceedings were adjourned at 1:48 p.m.)

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I, the undersigned, ELIZABETH Meek, being first duly sworn say: I have read and/or had translated the foregoing deposition and know the contents thereof, and I certify that the same is true of my own knowledge, except as to those matters which are therein stated upon my information and belief, and as to those matters, I believe it to be true. I declare under penalty of perjury that the foregoing is true and correct.

Executed on _________________________, 2010, at ______________________________________, _______________________________________________.

_______________________ ELIZABETH Meek Signed before me this_____day of____________, 2010. _______________________________ Witness to Deponent's Signature

22 23 24 25 In The Matter of Elvin R. Meek Family Trust T. No. 05-1-0101, May 28, 2010 by Laura Savo, RPR, CSR

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CERTIFICATE STATE OF HAWAII ) ) ss. CITY AND COUNTY OF HONOLULU ) I, LAURA SAVO, a Notary Public in and for the State of Hawaii, do hereby certify: That prior to being examined, the witness herein, ELIZABETH Meek, was sworn by me to testify to the truth, the whole truth and nothing but the truth; That the foregoing deposition was taken down by me in machine shorthand at the time and place herein stated, and was thereafter reduced to typewriting under my supervision; That the foregoing is a full, true and correct transcript of said deposition; That after said deposition was reduced to typewriting, the witness, in accordance with Rule 30(e) of the Hawaii Rules of Civil Procedure, was duly informed of the right to make such corrections as might be necessary to render the same true and correct. I further certify that I am not of counsel or attorney for any of the parties to this case, nor in any way interested in the outcome hereof, and that I am not related to any of the parties hereto. Witness my hand and seal this 25th day of June, 2010.

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__________________________ LAURA SAVO, RPR, CSR NO. 347 Notary Public, State of Hawaii My Commission Expires: 11/28/2013

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