NOTICE OF TIME FOR FILING OBJECTIONS TO MOTION TO STRIKE RESPONDENT’S ANSWER, HOLD HIM IN DEFAULT AND DENY HIM ANY FURTHER SHARE OF TRUST ASSETS

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF CLACKAMAS Probate Department Case No. 18PB08943 NOTICE OF TIME FOR FILING OBJECTIONS TO MOTION TO STRIKE RESPONDENT’S ANSWER, HOLD HIM IN DEFAULT AND DENY HIM ANY FURTHER SHARE OF TRUST ASSETS. In the Matter of the DOROTHY M. CONNELLY TRUST, u/a/d December 3, 2014. PATRICIA A. STRAND, in her capacity as Trustee of the DOROTHY M. CONNELLY TRUST, Petitioner, and MARK CONNELLY, former Trustee of the DOROTHY M. CONNELLY TRUST, Respondent. Notice is hereby given that Patricia Strand, Petitioner, has filed a MOTION TO STRIKE RESPONDENT’S ANSWER, HOLD HIM IN DEFAULT AND DENY HIM ANY FURTHER SHARE OF TRUST ASSETS (Motion). A copy of the Motion accompanies this notice. Any objections to the Motion must be filed in the above proceeding in the above court 28 days from the date of the first publication of this notice. If no objections are received, no court hearing will be held on this matter. DATED this 27th day of April, 2021. DRANEAS HUGLIN COOPER LLC /s/ Brooks Cooper Brooks F. Cooper, OSB No. 941772 Brooks@draneaslaw.com Of Attorneys for Patricia Strand Published May 4, 11, 18 & 25, 2021. ____________________________________________________________________ IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF CLACKAMAS Probate Department Case No. 18PB08943 MOTION TO STRIKE RESPONDENT’S ANSWER, HOLD HIM IN DEFAULT AND DENY HIM ANY FURTHER SHARE OF TRUST ASSETS. In the Matter of the DOROTHY M. CONNELLY TRUST, u/a/d December 3, 2014. PATRICIA A. STRAND, in her capacity as Trustee of the DOROTHY M. CONNELLY TRUST, Petitioner, and MARK CONNELLY, former Trustee of the DOROTHY M. CONNELLY TRUST, Respondent. As this Court is well aware Respondent has simply ceased responding to discovery demands by Petitioner and orders by this Court. He has failed to comply with multiple orders to compel. His conduct has necessitated motions to compel that should not have been necessary. He even failed to attend the recent remedial contempt show cause proceeding. As Petitioner has indicated she simply cannot accurately compute each beneficiary’s share of the trust and make final distributions without information that Respondent, alone, possesses. This status quo means that this proceeding can simply never be concluded in a proper fashion. To break the utter logjam caused by Respondent’s choice to ignore this proceeding Petitioner proposes as follows: First, as a sanction for repeated discovery violations and repeated failure to attend court proceedings (in person, through counsel, or both) this Court should strike Respondent’s answer and hold him in default. Second, the trust at issue distributes as follows: one share to Petitioner; seven shares to Respondent, two shares divided between Carole Booth, Margaret Hill, Federico Franco and Laura Franco. The records available to Petitioner indicate that there are over $100,000 that should be in her hands as trustee which are not. Without Respondent’s records she cannot determine how much has gone missing and how much, if any, of the apparently missing funds were properly expended by Respondent in trust administration. Given the lemons that Petitioner and this Court have been presented, she suggests this rough measure to make lemonade, do equity, and resolve this proceeding: This Court, as a sanction for Respondent’s decision to simply ignore this proceeding, should declare that Petitioner should distribute the remaining assets in her hands as if no shares were given to respondent. Thus, instead of 10% to her and 20% to the other five beneficiaries, this Court should direct her to distribute one-third of the assets on hand to herself and two-thirds to the other five in even shares. There is simply nothing else to be done here, other than keep this proceeding on the docket until an unknown amount of time passes. That is unacceptable to Petitioner and should not be acceptable to this Court. Petitioner requests, for all the reasons stated in her motion to serve the remedial contempt proceeding by publication that this Court accept service of this petition by publication as well, given that she cannot find Respondent’s current domicile or mail receptacle and his counsel has resigned. WHEREFORE, Petitioner prays for this Court’s General Judgment as follows: 1) Finding Respondent in default for multiple violations of orders of this Court; 2) Striking Respondent’s Answer; 3) Directing Petitioner to distribute the remaining trust funds as if Respondent were not a beneficiary such that 1/2 of the remainder passes to her and 2/3 of the remainder to the other beneficiaries in equal shares; 4) When receipts are filed, entering a supplemental judgment discharging her and closing this proceeding. IT IS SO MOVED. DATED: April 27, 2021. DRANEAS HUGLIN COOPER LLC /s/ Brooks F. Cooper Brooks F. Cooper, OSB No. 941772 brooks@draneaslaw.com Of Attorneys for Patricia Strand Published May 4, 11, 18 & 25, 2021. BT200675

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