June 20, 1941 -- October 10, 2021

On December 28, 2022, I filed a criminal complaint with United States Attorney for the Northern District of California, regarding the $4.2 million fraud on the Kate Talbot Trust by divorced-ex-husband Ronald Lee Talbot who lives in Pacifica, California, and Kate's former-room-renter Sarah Okawa Ellerbrock who lives in Kirkland, Washington, and co-conspirator attorney Michael Joseph Valencia with office in San Bruno, California. On February 7, 2024, I filed a Supplement to Complaint with Ismail Ramsey, the United States Attorney for the Northern District of California

Synopsis:  Ronald LeeTalbot who lives in Pacifica, California, and Sarah Okawa Ellerbrock who lives in Kirkland, Washington, each notarized five documents on five dates in California and Washington, which makes them both subject to prosecution by the United States Attorney for the Northern District of California for their crimes of conspiracy and wire fraud, pursuant to 18 United States Code section 1343, and specifically for their deliberate and willful participation in a scheme to defraud Kate Talbot's Trust of $4.2 million by false pretenses, and the use of interstate wire communications in furtherance of their scheme, for Kate's three properties (1) 491 Ebken St, Pacifica; (2) 2201 Ensenada Way, San Mateo; and (3) 2338 Palmetto Ave, Pacifica. The September 15, 2021, Amendment to the June 3, 2016, Kate Talbot Trust was fraudulent and invalid because Kate had taken her prescribed morphine medication and lacked mental capacity, before Kate’s divorced-ex-husband Ronald Lee Talbot, whom she divorced in 2007, drove Kate to the UPS Store at the Laurelwood Shopping Center, 3182 Campus Drive, San Mateo, where Kate’s signature was notarized, and Kate’s divorced-ex-husband Ronald Lee Talbot suddenly received a sizeable percentage of Kate’s Trust, and both Ronald Lee Talbot and Kate's former-room-renter Sarah Okawa Ellerbrock were suddenly named co-trustees of Kate’s Trust, shortly before she took her prescribed aid-in-dying drugs to end-her-life on October 10, 2021. The "crime-fraud" exception to attorney-client privilege permits the United States Attorney to charge Michael Joseph Valencia, the attorney for Ronald Lee Talbot and Sarah Okawa Ellerbrock, as a co-conspirator to the $4.2 million fraud on Kate Talbot's Trust, because Michael Joseph Valencia gave legal advice to Ronald Lee Talbot in furtherance of the crime and provided the documents to Ronald Lee Talbot that were notarized on September 15, 2021, after Kate had taken her prescribed morphine and lacked mental capacity.

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San Mateo Superior Court case number 22-PRO-0010, "The Kate Talbot Trust, dated June 3, 2016"

      Michael Joseph Valencia, attorney for co-trustees Ron Talbot and Sarah Ellerbrock,  --  mvalencia@rosshackett.com, 650-588-0367  --  Ross, Hackett, Dowling, Valencia & Walti Law Firm, 600 El Camino Real, San Bruno, CA 94066

      Ronald Lee Talbot, co-trustee, The Kate Talbot Trust, --  redracer73w@gmail.com,  650-309-5711  --  20 Humboldt Court, Pacifica CA 94044

      Sarah Okawa Ellerbrock, co-trustee, The Kate Talbot Trust, --  wsforum7@gmail.com,  425-829-7763   --  307 5th Avenue, #102, Kirkland, WA 98033

                     Talbot Divorce, filed 6/12/2007

                     6/3/2016, Kate Talbot Trust

                     Deed Removing Ensenada from Trust, recorded 4/23/2021

                     August 2021, Kate Talbot Cancer Diagnosis

                     California End of Life Option Act forms

                     9/15/2021, Amendment to The Kate Talbot Trust

                     9/15/2021, Last Will of Kate Talbot

                     10/25/2021, Kate Talbot Death Certificate

                     Affidavit of Death of Kate Talbot and appointment of co-trustees

                     Notice of hearing, filed 2/3/2022 

                     Ebken Grant Deed, recorded 4/4/2022

                     Minute Order, filed 5/3/2022

                     Notice of Hearing, filed 5/4/2022

                     5/4/2022, Amended Petition, and  June 3 2016 Kate Talbot Trust

                     Order Confirming Asset to Trust, signed 5/24/2022

                     Ensenada Grant Deed, recorded 9/2/2022

                     Palmetto Grant Deed, recorded 11/23/2022

                     11/28/2022, Complaint to California State Bar

1) Kate Talbot divorced Ronald Lee Talbot in a contested divorce on June 12, 2007, San Mateo County Superior Court, case number FAM095047, where Ronald Lee Talbot was represented by attorney Paul Walti, and Kate was represented by attorney Dan Himmelheber. On March 7, 2008, Judge Richard DuBois approved the parties 17-page Settlement Agreement, which stated that Kate’s home at 2201 Ensenada Way, San Mateo was her separate property and that Ronald Lee Talbot’s home at 20 Humboldt Court, Pacifica was his separate property.

2) On June 3, 2016, Kate’s attorney Bruce Friedman created “The Kate Talbot Trust” which stated on page 13, “The Trustor has deliberately and with full knowledge and intention of doing so, specifically omitted to provide in this Trust or otherwise for her three children, Michael J. Balistreri, Jane Klein and Linda Vaccarezza”. As part of Kate’s June 3, 2016 Trust, Kate’s attorney Bruce Friedman transferred three of Kate’s properties into her Trust, and on June 22, 2016, recorded with the San Mateo County Recorder the following three Grant Deeds: - (1) document no. 2016-060854, 2338 Palmetto Ave, Pacifica, APN: 115-560-020; (2) document number 2016-060855, 491 Ebken Street, Pacifica, APN: 022-035-150; (3) document no. 2016-060856, 2201 Ensenada Way, San Mateo, APN: 039-102-230.

3) Five-years later, on April 23, 2021, Kate recorded a quitclaim deed with the San Mateo County Recorder, document 2021-064829, transferring her home at 2201 Ensenada Way from “Kate Talbot as Trustee of the Kate Talbot Trust dated June 3, 2016” to “Kate Talbot, an unmarried woman”.

4) In early August 2021, Kate learned from her doctor at Kaiser Permanente Redwood City Medical Center that she had terminal cancer and was diagnosed with peritoneal carcinomatosis. Kate declined radiation and chemotherapy treatment from her doctor at Kaiser, and instead Kate decided she wanted to end-her-life with physician-assisted suicide, pursuant to the California End of Life Option Act that took effect in 2016. Kate designated her home at 2201 Ensenada Way would be her hospice and Kate arranged for hospice care at her home. Kate’s doctor at Kaiser Permanente Redwood City Medical Center prescribed morphine for her pain.

5) In early September 2021, Kate’s doctor at Kaiser Permanente Redwood City Medical Center prescribed her aid-in-dying drugs and Kate received her aid-in-dying drugs at her home at 2201 Ensenada Way. On September 15, 2021, after Kate had taken her prescribed morphine medication and lacked mental capacity, Kate’s divorced ex-husband Ronald Talbot, whom she divorced in 2007, drove Kate to the UPS Store located at the Laurelwood Shopping Center, 3182 Campus Drive, San Mateo, where Kate’s signature was notarized on a fraudulent and invalid “Amendment to the June 3, 2016, Kate Talbot Trust”, and wherein her divorced-ex-husband Ronald Lee Talbot suddenly received a sizeable percentage of Kate’s Trust, and wherein both Ronald Lee Talbot and Kate's former-room-renter Sarah Ellerbrock were suddenly named co-trustees of Kate’s Trust.

6) The FBI or the United States Attorney should subpoena Kate Talbot's medical records from Kaiser Permanente Redwood City Medical Center for the 3-month-period July 10 through her death on October 10, 2021, and the testimony of Kate’s doctors to prove Kate's lack of mental capacity on September 15, 2021, due to her prescribed morphine, the date when Kate’s signature was notarized on an Amendment to her June 3, 2016 Trust.

7) On October 10, 2021, Kate ended-her-life by ingesting her prescribed aid-in-dying drugs in the presence of her divorced-ex-husband Ronald Lee Talbot whom she divorced in 2007. After Kate died, Kate’s divorced-ex-husband Ronald Lee Talbot falsely stated on Kate’s death certificate dated 10/25/2021, that he was Kate’s husband at the time of her death.

8) On January 5, 2022, an “Affidavit of Death of Settlor/Trustor” with the notarized signatures of Sarah Ellerbrock and Ronald Talbot, was recorded as document number 2022-000721 with the San Mateo County Recorder, stating that they are the successor co-trustees of the Kate Talbot Trust, and that 2338 Palmetto Ave, Pacifica, and 491 Ebken St, Pacifica, are assets of the Trust.

9) On January 20, 2022, co-trustees Ronald Talbot and Sarah Ellerbrock listed 491 Ebken Street, Pacifica, for $1,200,000, MLS 81875176 by Mary Yeargain, DRE 00609423, and accepted an offer for $1,290,000, utilizing Lawyers Title Company, escrow order number FLNP-0042200003. On April 4, 2022, a Grant Deed with the notarized signatures of Sarah Ellerbrock and Ronald Talbot, was recorded as document number 2022-028809 with the San Mateo County Recorder. 

10) On February 3, 2022, Michael Valencia, the attorney for co-trustees Ronald Talbot and Sarah Ellerbrock, filed case number 22-PRO-0010 with the San Mateo Superior Court, and on May 4, 2022, Michael Valencia filed an amended petition with the notarized signatures of Sarah Ellerbrock and Ronald Talbot, that stated Kate’s home at 2201 Ensenada Way, San Mateo, “is actually owned by the Trust, and is part of the Trust estate.”  Michael Valencia lied to the Court by never disclosing to the Court that Kate had removed 2201 Ensenada Way from her Trust on April 23, 2021, less than 6-months before her death. Michael Valencia lied to the Court by never disclosing to the Court that Ronald Talbot was Kate’s former husband she divorced in 2007. Michael Valencia lied to the Court by never disclosing to the Court that Ronald Talbot had falsely stated on Kate’s death certificate that he was Kate’s husband at the time of her death. Michael Valencia lied to the Court by never disclosing to the Court that Kate learned from her doctor at Kaiser Permanente Redwood City Medical Center that she had terminal cancer, had declined radiation and chemotherapy treatment from her doctor at Kaiser, and instead Kate decided she wanted to end-her-life with physician-assisted suicide, pursuant to the California End of Life Option Act that took effect in 2016. Michael Valencia lied to the Court by never disclosing to the Court that Kate designated her home at 2201 Ensenada Way would be her hospice and Kate arranged for hospice care at her home. Michael Valencia lied to the Court by never disclosing to the Court that Kate’s doctor at Kaiser Permanente Redwood City Medical Center prescribed morphine for her pain. Michael Valencia lied to the Court by never providing the Court with the testimony from Kate’s doctor about Kate's lack of mental capacity on September 15, 2021, because of her prescribed morphine medication, which is the date when Kate’s signature was notarized. Michael Valencia lied to the Court by never disclosing to the Court that in early September 2021, Kate’s doctor at Kaiser Permanente Redwood City Medical Center prescribed her aid-in-dying drugs and Kate received her aid-in-dying drugs at her home at 2201 Ensenada Way. Michael Valencia lied to the Court by never disclosing to the Court that on September 15, 2021, after Kate had taken her prescribed morphine medication and Kate lacked mental capacity, Kate’s divorced-ex-husband Ronald Talbot, whom she divorced in 2007, drove Kate to the UPS Store at the Laurelwood Shopping Center, 3182 Campus Drive, San Mateo, where Kate’s signature was notarized on a fraudulent and illegitimate “Amendment to the June 3, 2016, Kate Talbot Trust”.  Michael Valencia lied to the Court by never disclosing to the Court that on September 15, 2021, Kate’s divorced-ex-husband Ronald Talbot suddenly received a sizeable percentage of Kate’s Trust. Michael Valencia lied to the Court by never disclosing to the Court that on September 15, 2021, both Ronald Talbot and Sarah Ellerbrock were suddenly named co-trustees of Kate’s Trust. The "crime-fraud" exception to attorney-client privilege permits the Court to review Michael Valencia's emails and communications with Ronald Talbot and Sarah Ellerbrock, and to charge Michael Valencia as a co-conspirator to the $4.2 million fraud on Kate Talbot's Trust, because Michael Valencia gave legal advice to Ronald Talbot in furtherance of the crime and provided the documents to Ronald Talbot that were notarized on September 15, 2021, after Kate had taken her prescribed morphine and lacked mental capacity.

14) On December 28, 2022, I filed a criminal complaint with United States Attorney for the Northern District of California, regarding the $4.2 million fraud on the Kate Talbot Trust by divorced-ex-husband Ronald Lee Talbot who lives in Pacifica, California, and Kate's former-room-renter Sarah Okawa Ellerbrock who lives in Kirkland, Washington, and co-conspirator attorney Michael Joseph Valencia with office in San Bruno, California.

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