Of Counsel:

In pro se

NANCI MEEK
3308 Ariba St
Las Vegas NV 89129
Telephone: (760) 413-5660
Petitioner in Pro Se

IN THE CIRCUIT COURT OF THE FIRST CIRCUIT

STATE OF HAWAII

THE MATTER OF ) T. No. 05-1-0101

) AMENDED
THE ELVIN R MEEK FAMILY ) PETITION FOR DECLATORY
TRUST, DATED JUNE 14, 1996 ) RELIEF DECLARING
AS AMENDED ) 1ST AMENDMENT INVALID;
) EXHIBITS A - P; DECLARATION
) OF NANCI L. MEEK;
)
__________________________________)

AMENDED PETITION FOR DECLATORY RELIEF DECLARING 1ST AMENDMENT

INVALID

COMES NOW NANCI MEEK, an interested person seeks declatory

relief that the 1st Amendment to the 1996 ELVIN R MEEK TRUST, the first

dated September 16, 1997 and executed in Honolulu Hawaii and included

in the original Petition For Declatory Relief Declaring the 1st Amendment

Invalid dated December 2008 (Exhibit “A”) and the second 1st

Amendment dated September 19, 1997 (Exhibit “B”) and executed in

Atascadero, California, are invalid for the following reasons:

1) Forensic examination of the signatures on the 1st Amendment

prepared by Robert Jones, Attorney for Elizabeth Meek, allegedly

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 signed in California have concluded the signatures are fraudulent.

See Exhibit “C”. Also the document has no notary witness and no

page numbers.

2) We stand by our allegations set forth in the original Petition For

Declatory Relief Declaring the 1st Amendment Invalid dated

December 2008 (Exhibit “A”) that the original Declaration of Trust

of Elvin R Meek For The Benefit of Elvin R Meek executed and dated

June 14, 1996 (Exhibit “D”) is a true and accurate document and

supports our father, an attorney himself, and his true intent as to

how he wanted his estate executed.

3) While we don’t doubt a 1st Amendment was signed by our father on

September 16, 1997 as evident by the Notarial record provided by

notary Susan Strong, an employee of the Bank of Hawaii (Exhibit

“E”) with a notation “customers of Heidi”, we believe the 1st

Amendment provided by Attorney Robert Jones who is involved

with several fraud actions in San Luis Obispo County, is not the true

and accurate 1st Amendment. The pages on the 1st Amendment are

not numbered.

4) The Elvin R Meek and Elizabeth A Meek Living Trust dated January

10, 1992 is a true and accurate document. (See Exhibit “F”) This

document names Elizabeth Meek as the trustee, allowing for

equitable distribution to myself, my brother Melvin Meek and Lola

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 Dee Meek (Reklai) however in 1996 our father removed Elizabeth

Meek as trustee, naming myself as Trustee and changed the

distribution to 1/3 to myself, 1/3 to my brother, 1/6 to Elizabeth

Meek and 1/6 to Lola Dee Meek; According to several others this

was his intention prior to being diagnosed as terminally ill in

September of 2003.

5) The Certification of Trust for the Elvin R and Elizabeth A Meek

Living Trust dated January 10, 1992 (Exhibit “G”) prepared by

Attorney Robert Jones and executed by Elizabeth Meek on February

20, 2004 four months after our father passed away supports our

allegations that the both 1st Amendments in question were non-

existent at the time of our father’s death evidenced by item #1

which only refers to the Elvin R and Elizabeth A Meek Living Trust

dated January 10, 1992 and not the 1996 Trust, or the

Amendments. We allege Robert Jones prepared and Elizabeth

executed this document in February of 2004 as part of a calculated

scheme which would enable her to introduce to Union Bank Cal as a

true instrument enabling her to cash out our father’s Union Bank Cal

stocks in the amount of $646,000 which were included in the 1992

Trust. The stocks were also included as assets in the Elvin R Meek

1996 original trust, however the 1996 trust instrument had named

Nanci Meek as the trustee. Elizabeth Meek deposited the $646,000

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 check into the Bank of Hawaii in April of 2004. Attached as Exhibit

“H” is an affidavit prepared by Goodsill Anderson, attorneys for

Bank of Hawaii and executed by Elizabeth Meek in November of

2005 just prior to selling the property located at 469 Ena Road

#3405 in Honolulu, Hawaii. The Affidavit explains Elizabeth Meek

signed the Trust Certification in 2004 to enable her to transfer title

and sell properties not included in the 1996 trust. However, we

allege it is suspicious and perhaps criminal that the 1992 Trust is

the only trust mentioned in the Certification of Trust signed

February of 2004. At the same time the law firm for Bank of Hawaii,

Goodsill Anderson also created and executed an Affidavit by

Attorney Robert Jones (Exhibit “I”) also stating the Certification of

Trust executive and drafted in September of 2004 was created by

Robert Jones to assist in the selling of properties not yet transferred

to the 1996 trust. The inconsistencies with both the Affidavits and

the Certification of trust are nothing more than a back pedal

attempt by Robert Jones and Elizabeth Meek.

6) The non-communicative behavior by Elizabeth towards myself and

my brother after several months of attempted contact via phone,

and correspondence sent to Elizabeth Meek inquiring as to her well

being (Exhibit “J”) strengthens our allegations that both Elizabeth

and her attorney Robert Jones were knowingly and with impunity

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 attempting to dissolve our father’s estate without our knowledge

and with disregard for what we knew to be our father’s original

intent. Attached is a copy of the letter sent to myself and my

brother from Attorney Robert Jones indicating “Elizabeth Meek for a

variety of reasons has chosen not to correspond with us at this

time.” We have never in the 15 years Elizabeth Meek was with our

father had any cross words with her. (See Exhibit “K”).

7) Furthermore we continue to question Attorney Robert Jones opening

the original probate in the state of California whereas Elvin Meek

had resided for several years in Honolulu and died in Hawaii.

Attorney Robert Jones is not licensed to practice in Hawaii and we

believe it was his intent to dissolve the estate utilizing the 1st

Amendment we allege he fabricated after our father’s death and

seizing the opportunity to take advantage of our father’s weakened

condition. Robert Jones is currently involved in several fraud related

litigations in San Luis Obispo County involving the Hurst Financial

Group, and his client Kelly Gearhart, as well as illegal activity

regarding an Indian Casino venture entitled Pe Ji Ho Ta.

8) The inconsistencies in the affidavit executed by Attorney Robert

Jones on October 2, 2007 is nothing more than a poor effort by Mr.

Jones to further support mask his criminal behavior and upon

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 scrutiny does nothing more than support our allegations he

consistently acts with impunity. (Exhibit “L”)

9) As set forth in my affidavit (Exhibit “N”) filed with the court

December 15, 2005, my father approached me in April of 2002, 18

months prior to his demise, at the El Torito restaurant parking lot in

San Bernardino, California and entrusted me with a copy of The

Elvin R Meek 1996 Family trust. He was upset because he had

recently discovered that Elizabeth Meek was sending money as well

as making deposits from his bank accounts at the Bank of Hawaii to

another Bank of Hawaii branch located in Palau and in the name of

her daughter Lola. He also indicated that he and Elizabeth were

“not getting along”.

10) Attached is my affidavit executed August 13, 2007 which

outlines the repeated efforts by Elizabeth Meek and Attorney Robert

Jones to undermine and ignore our father’s intentions prior to his

death on October 19, 2003.

11) Attached as Exhibit “P” is the Objection to Petition for

Declatory Relief Declaring the 1st Amendment Invalid and with

respect to Elizabeth Meek’s responses to our allegations 1-10 we

disagree and stand by the allegations in the original Petition for

Declatory Relief Declaring the 1st Amendment Invalid.

Therefore, petitioner prays:

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1. That the original Forensics Report prepared by Reed Hayes be

lodged with the court.

2. That the court consider our allegations that the 1st Amendment to

the 1996 original Elvin R Meek Family trust executed on September

16, 1997 as originally produced for the court by Attorney Robert

Jones in September of 2004 has been fabricated and fraudulently

produced by Attorney Robert Jones after the decedent’s death in an

effort to support the 2nd Amendment and Last Will And Testament

executed by Robert Jones and signed by the decedent Elvin Meek,

while he was in a weakened state, incoherent and 100%

incapacitated as declared by forensic expert Susan Kalb upon

review of medical records.

3. Furthermore, Nanci L. Meek supports her original allegations and

supports the original Petition For Declatory Relief Declaring the 1st

Amendment Invalid dated December 2008 (Exhibit “A”) and

vehemently denies any and all of the subsequent allegations

contained in Elizabeth Meek’s Object to Petition for Declatory Relief

Declaring 1st Amendment Invalid filed January 12, 2009 see Exhibit

“P”.

4. We ask the court to declare both 1st Amendments to be invalid and

recognize the original Elvin R Meek 1996 Trust document executed

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 in Honolulu, Hawaii on June 14, 1996 to be the true and accurate

document.

I certify that the forgoing is true and correct, and that each of the

attachments are true and correct copies under penalty of perjury under

the Laws of the State of Hawaii.

DATED: August 13, 2009, Honolulu Hawaii

_______________________
Nanci Meek Petitioner
Self Represented