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IN THE SUPERIOR COURT OF WASHINGTON
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IN AND FOR THE COUNTY OF KING
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IN RE: Case No.: 16-4-04845-2
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THE ESTATE OF DENNY DOUGLAS TITUS,
DECLARATION OF
12 DECEASED. SOPHIA BAGNASCHI
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14 EMILY R. HANSEN
15 Petitioner
16 V.
17 FRED V. CHRISTIANSON
18 Respondent.
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20 I, SOPHIA BAGNASCHI, am of legal age and competent to testify to the matters below, and

21 hereby declare under the penalty of perjury under the laws of the State of Washington that the foregoing
22 is true and correct:
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1. Declarant. I am a Senior Paralegal at Veterans for Guardianship & Probate Reform,
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S.P.C., a DBA of Marathon Public Interest, S.P.C., a social purpose corporation
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26 registered in the State of Washington. I live in Seattle, WA.

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DECLARATION OF SOPHIA BAGNASCHI - 1


1 2. December 11th Hearing. In the Superior Court of Washington in and for the County
2 of King in Seattle before Judge Kenneth Schubert at a hearing on December 11th,
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2018, Judge Schubert appointed Chris Lee to be the Administrator of the Estate of
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D. Douglass Titus.
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3. Excerpt from the Certified Transcript. Per the follow excerpt from a certified
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7 transcript of the proceedings (Exhibit x) of Dec. 11, 2018, Judge Schubert stated

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9 “THE COURT: So I've just appointed another guy.

10 MR. GRINDELL: Right. And Mr. --

11 THE COURT: I contacted our people down in ex parte.


12 I said, "Hey, I need a P.R. Who do you guys recommend off our list?"?
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MR. GRINDELL: Understood. Mr. --
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THE COURT: They came up with two names.
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MR. GRINDELL: Uh-huh.
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THE COURT: I don't know if they were on the list or,
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you know, it would have been next up or not. I didn't ask.
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MR. GRINDELL: Okay.
THE COURT: They gave me names. I'm familiar with
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the names. I don't know the people. I have no professional
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relationship to the people. There's no kickback. I'm not
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paying them. There's nothing. Right? I just appointed them off the list.
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MR. GRINDELL: And there was no -- you're saying
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there was no explanation needed for -- you just picked them
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off the list.
THE COURT: I said I cited the case and I said, "I
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need someone. Hopefully, grab someone that's down there
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now."
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MR. GRINDELL: Who is -- if I may, the other --
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THE COURT: I signed the order.

DECLARATION OF SOPHIA BAGNASCHI - 2


1 MR. GRINDELL: -- individual?
2 THE COURT: You'll get a copy of it.
3 MR. GRINDELL: The other individual not Mr. Friend; you said you had two.
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THE COURT: Yeah. Just hand him a copy of the order.
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MR. GRINDELL: Okay. And --
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THE COURT: Okay. One of them is Mr. Longyear.
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MR. GRINDELL: Mr. Longyear?
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THE COURT: Yeah, and who's the other one? And the
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other one is Christopher Lee (phonetic).”
End of transcript excerpt. (see Exhibit “A” for full transcript)
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4. Inquiry Regarding Existence of a List for Estate Administrators. After the hearing
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ended, I went upstairs to the Clerk’s office and spoke with Karissa Zeno, at
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approximately 1:45 p.m. on Dec. 11, 2018. I inquired about the list that Judge
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Schubert claimed an estate administrator would be chosen from, as Judge Schubert
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had referenced during the hearing.
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5. Confirmation of the Absence of a List for Estate Administration. Ms. Zeno
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informed me that no list exists for estate administrators exists, and that there is only

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a Certified Professional Guardian list, and the Guardian Ad Litem (GAL) Registry.

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I requested a copy of both, as well as the policy handbook for GAL appointments.
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6. Title 11 and Title 26 GAL Registries and Policy Handbook. In early December
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2018, I contacted Nadia Simpson, the Operations Supervisor for King County
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Superior Court at Seattle to obtain a copy of the Title 11 and Title 26 GAL registries,
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DECLARATION OF SOPHIA BAGNASCHI - 3


1 and the policy handbook. I received said reference information in early December
2 2018.
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7. Erroneous Reference. Judge Schubert’s reference to a single list that estate
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administrators are chosen from is completely erroneous for three reasons:
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8 A) No Single List for GALs and Guardians. According to reference information

9 provided by court staff, Chris Lee was listed on the Title 11-GAL list, but
10 Michael Longyear was not. I checked the CPG List online, and found that
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Longyear was listed, but Lee was not. Mr. Lee and Mr. Longyear do not appear
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on a single list.

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B) Irrelevant Reference. Judge Schubert’s reference to either list is irrelevant, as
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the GAL and Guardian lists do not relate to estate administrators.
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C) No Legal Authority. Judge Schubert’s appointment of any party to the position
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of estate administrator is without legal authority, as the proper procedure for
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the appointment of an estate administrator must result from a petition to the
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court for appointment by a party other than the court.

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8) Central Issue: Bias. Judge Schubert’s erroneous reference to a non-existent list
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without legal authority establishes both impropriety and bias in the Titus Estate.

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Dated this 3rd day of May, 2019.

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Sophia Bagnaschi
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DECLARATION OF SOPHIA BAGNASCHI - 4