Filing 33706934 E-Filed l0f27/20l? 10:07:53 AM IN THE CIRCUIT COURT OF THE JliDl *r a . . AND FOR PALM BE (.IAL LIRCUII ACII COUNTY. FLORIDA IN RE: 0F PROBATF DIVISION CARLA SIM MON 08 CASE NO. MU HON H) I?fn IHI NOW Mm ant. lilizahcth Sawtt, 0t Carla Simmonds [thc h) and lhl'l?llgh he: compel payman 1mm \?t'ard's l'rus?t. as follow 5 as plenary guardian nt'the pcrsaun and property and tn I. 'l?hc ard IS the (irantnr nt?thc (?arla Simmonds Rcmcahlc Trust dated May 8. 2012 {the ??I?rust") Irustcc ulthc \K?ard'u Irust is Daniel Schmidt. Daniel Schmidt is the former emergency guardian of Ward. has; continued to participatc in guardianship aftcr hc was dischargcd as guardian. and remains an person subject to the jurisdiction ul?thc unrt. Lo) ntajnrit} ut? \N?ard?s funds arc in the [?rust. At 0f the guardianship. lrust in thc. amount 4. ?It: only assets to guardianship at the Ward?s horticstcad real a 2013 Honda Civic and an IRA at Mcrrill at 345000.00. In additinn. Guardian has sincc marshalcd an HSA account with LIME Healthcarc valued at $1847.94 which can only bc in pa} for Vt?ard?s mcdical 5. The Ward receives montth Social Security in amuunt his I .43000 and this IS the Wardis primary source of The Ward payments hut payments were paid it}; Guardian trTEJhc chi.ch ghild he took as primary carcgitcr tit-[February 2015 as. sun has teachcd agt. I I . support t'ccwz. sonic Iaigc medical hillb?lld majority. In addition. Guardian paid storage fees from the funds. till a hastt'rnm h'H'i? (?human [My 1" ancc hills in the trd?r. murtgagc humcumtcr?s amnciatiun It?: and iaun Ilill 'tmuunl nf?lil 94 Juan-trig a wry small surp RON BUCK. CLERK 10r?27f20l5 10:07:53 AM I 3 nil FD- PALM BEACH COUNTY. IL 8 7. Fhe guardianship funds are thus insul?l?ic Guardian's atlnmey. By Agreed ()rder ward" 1 if: 1 tan 5 and watt; to [la (Juardian the autumn 5. eu wut'tl - greed Order was provided I IL tn the ?t?l?ard'w. Inn: -- 1' . Trustee hat: ret'us . - lulmu'? bl? ll": .e to release the iundsagreed in the entry. at the tent tn pay the l?eeie al' the tiuardian and the dated 2h. the f'nur! awarded ln the Guardian's atterne} is currently nu ed 533.584.?3 in then and emits for the period Covering .l Lute tlirnugh Septeinher Bill 3 the Guardian lacks suf?cient assets in F8 744.444t ta) ("opiewfthe invoices are attached hereto as (?nmpuzsite l?ixliihit i 9. The (ntardtun asserts that the :ird's: lrust has sul?licient assets In pm the t'eex and costs 01 the and the Guardian?s attorney and that these such fees and costs are reasonable and necessary expenses ul?the Warthirantur-Bene?ciary, It). The (iuardian requests that Mi Schmidt ?l?rnstee at the Ward's Trust. be compelled to pay all past due and future teen and ut?the upun Cuurt Order and the Guardian?s attorney as eertiticd the a ithnut t'urthereouit approval, which is not required statute and will time and expense for the Ward. Wl IEREFOR E. the Guardian respectfully requests the (?uuit enter an order compelling the Ward?s Trustee. Daniel Schmidt. to pay the fees and casts ut'the Guardian and Guardian's attome). L?nder penalties ofperjury. I declare that haxe read the tiiregtiing! and the facts alleged are true, to the best ofmy knowledge and belief. HEREBY that a enliy Ul'lhe liil?eguing wab ser?t'ed in the nit this 3- ll" dav nfOetuher. 2015 In Ronald D'Anna. luau? h-lcClusky. Ill-tuna a: llieterle. liltl?IZE Blvd, Suite 400, Even Ratun. H. 334.? and David but. In? ()llieeut Dun-1t M. Garten. 400 ("tilumhia Drive. Suite HJU. West Palm Beach, 3.34th z? Ellen S. Morris. Esq. Attorney for Guardian Flurida Bar Number: 350306 ELDER LAW ASSOCIATES Pitt 7284 W. Palmetto Park Ruad, Sum: Bnca Rattan. FL 33433 Telephone: tStil 750-335? Fax: (561) issueiates cunt leteraizu? .. hSeeundarie E-Mail: elawreneetuiclderlawusmmates. I i Luau-II. .E. ELDER LAW ASSOCIATES PA r234 West Palmetto Part. Road Suite 101 1 Boca Raton. Florida 33433 I Phone - 3361;750:3850 Ms. Elizabeth B. Sav'm Saw? Guardians invoice Date: July 15. 2015 i 501 Caunlw Club Drive Invoice it: 55720 .r i Atlantis. FL 33462 Term: Due Upon Receipt Our ?le 30818.00? In Reference to: Guardianship tor Carla Simmonds i ProfessiOrra! Services Rendered 757?: gate Staff Description Hours . I 6119:2015 LR Telephone call from Betsy re. rental contract; 0 40 31221;: cggoges 5' Review of contract; Drafted Renewed Petition and .00 - Order to Rent Real Property $211201 5 CAL E-liled Renewed Petition to Rent Ward's Real 0 70 $125.00 $37 50 i Property to Betsy Sawtt to Slgn; Prepare Notice of 1 Hearing; Email to Betsy Savitt re same. Case i; I discussion with E. MOtl?lS. 6i'2112015 EM Rewew of contract for rent. Email to Betsy. Review 0 30 $350.00 $105 00 5 i of petition. i I 6/22/2015 EM Review Notice of Hearing 0.20 $350.00 ?i I Case Discussion with Lawrence. l' 63?23i'201 5 CAL Email from Betsy Savitt. respond to same: Prepare 0.70 $125.00 $67.50 Amended Notice of Hearing, E-fiie Amended and Petition and Notice of Hearing, Email to Mr McCLosky and Mr D'Anna Waiver and Consent 6r23f2015 LR Mailed [donate and Petition to Judge ticklin's office 0 40 $125.00 $50 00 Review of e-mails; Prepared Amended Renewed Petition. Order and Consent and Waivei to same for Daniel Schmidt. 61251201 5 LR Mailed Amended Notice and Amended Petition to 0.10 5125.00 $12.50 Judge Ticklin. CAL Review email from Betsy Savitl re Dan Schmidt. 0.20 $125.00 $25 00 respond to same. EM REVIEW oi Answer and Notice oi Adversary 0 20 $350.00 $10.00 Proceeding filed by David Garten; Case discussion with Rubin Case drecueSion Morris, Prepared and e? 0 40 $125.00 $50 .00 ?led Notice of Cancellation of UMC. E-mailed Notice to DiVlSlUf?l Ix; Ermall?d documents to 0 i 6t30i2015 CAL Telephone call from Dawd Gaden'e O?ice re hearing 0.40 $125.00 $50.0 date; Note to file; Revrew emails lrom Betsy Sayitt and print new lease and all other documents to rent 6I29i?201 5 629/201 5 6i29i2015 LR comrom EXHIBIT Elder Law Associates PA {?132} v-l-ilExpands - T-w-a Nuuv 21? ELDER LAW ASSOCIATES PA 7284 West Palmetto Park Road Some 101 Bode Ralon, Florida 33433 Phone 5451-7503850 MS. Elizabeth B. Savitl Savitt Guardians 501 N. Country Club Drive Atlantis, FL 33462 Our ?le it: 30813 007 In Reference to: Guardianship for Carla SllanndS Professional Services Rendered Date Staff Descriptioni 7101/2015 EM Review and reply to Betsy's email 7I03l2015 EM E-mails with Betsy Savit?i WOTI2015 EM Telephone call with Betsy 7l07i'2015 EM Review of email from Belay 710710015 LR E-mail to Cheryl at David Garten's office re Agreed Order Review of Agreed Order on David Garten's representation and e-meiled same to Betsy Case discussion with RUbll'T. Revrew ol Petition and Order Revuew oi BetSy's invoice; Case discussmn With [2 Morris, Drafted Petition and Order for Guardian's Fees and Costs; Email to Betsy Review of e-mail from Betsy; Directions to L. Rubin E-rnails With BetSy Savntt; Made reasons to and finalized Petition and Order for Guardian's Fees. Scanned and erliled some. mailed proposed Order to counsel. Directions lrom E. Morris; E-mail to Davrd Garten re. Carla?s property: Email from Michael Schlesinger and reply to some 7f09f2015 LR Ff29i?201 5 EM 7l29f2015 LR 75012015 EM 703010015 LR Expenses Total New Charges Invoice Date: Au905121.2015 invoice 50358 Term: Due Upon Receipt Hours 010 010 020 060 0.10 0.80 Total Fees Rate $350.00 $350 00 $350 00 $350.00 $125.00 $125.00 $350 00 $125 00 $350.00 $125.00 11.00 Total Expenses Charg??. $35 00 $140.00 $105 00 $70.00 $12 50 $12 50 $70.00 $75.00 $35.00 $100.00 $655.00 $2.75 $2 75 $657 75 Elder Law Assoclates PA Dated: Angus! 21. 2015 Ow ?le a! 30818 001' In Reforenca to: lo: Cana Summon-ms P599 2 ?urn: (- nut-cl Famous Balance mm,? Balance Due s\ 535 45 1 To make an easy owlme pay-van: please .Is I we Pa'mpn- Page 1% om .-.-: mm Vueudena-wassonams my? Onlne 5-9: we Paynm??s 1! [?de'vLaw Ana-cam and (ugh (m the ame In" .E. ELDER LAW ASSOCIATES PA r284 West Palmetto Park Road Sutte 101 Boca Raton Florida 334.33 Phone - 56l?750-3850 Ms. Elizabeth B. Sat/tit Savilt Guardians 501 N. Country Club Drive Atlantis, FL 334 62 Term: Due Upon Receipt invoice Date September 21. 2015 trworco rt 5011-11 Our ?le 30818007 in Reference to: Guardianship for Carla Simmonds Professional Services Rendered Dale Btajf Description Hours Rate Char . I 5 8/03/2015 EM Case discussmn with t. Rubin; E-mail to Betsy 0.10 535000 535900 8/03/2015 LR Case discussion With E. MOrris; Telephone call to 0 60 $125.00 $75.00 Judge Ticklin's office for hearing dates; E-mailed hearing dates to counsel and client. Review of e- mails from counsel and replies to same; Telephone call to Judge Ticktin's office to confirm hearing date; Prepared Order Setting Hearing and emailed same to Judge Ticklin?s office. 8/06/2015 LR ReView of e-mail lrorn David Garten re consent to 0 10 $125.00 $12 50 guardians lees LR Telephone call from Cheryl at David Ganen's office 0 30 5125.00 337 50 re: hearing; E-mail to Ronald D?Anna's of?ce re pending Petition for Guardian's Fees; Review of e? mail lrom Cheryl. 8/10/2015 EM Review and reply to emails with Garten?s oltice 0.10 $350 00 $35.00 and Betsy 8/10/2015 LR Follow up telephone call to Manuela re: Order 0 30 $12500 537.50 Setting Hearing; Reviewed Order Setting Hearing and e-maited same to Betsy; E-mails with Besty. 8/11/2015 LR Review of e-mails from Betsy. 0.10 $125.00 $12.50 8/11/2015 LR Telephone call from Cheryl at David Garten's ot?ce 0.10 $125.00 $12.50 re. status of hearing. 8/13/2015 LR Drafted Petition and Order to List Real Property tor 0.40 $125.00 $50.00 Sale. 8/17/2015 LR Telephone call from Betsy Savitt re: cash otter 0 10 $125.00 $12 50 received. 81/18/201 5 LR E-mail to Betsy re: change in Annual Plan due 0.10 $125.00 $12.50 dates. 8/19/2015 EM Review 01 Petition and Order to List Property for 0.10 $350.00 $35.00 Sale. 8/19/2015 LR E?mailed Petition to List Property to Betsy; Esmails 0.10 $125.00 $12.50 With easy. ctions to L. Rubin 0.20 $350 00 570100 8/20/2015 EM Meeting with Betsy Savitt: Dire Dated: September 21. 2015 Our file 30818.00? in Reference to: Guardianship for Carla Simmonds 5 8f21f2015 8f24l2015 81?24!201 5 8125112015 $261901 5 $260015 83260015 Expenses 812812015 8131.1201 5 Total New Charges Previous Balance Belnoe Due Directions trorn E. Morris. E-mail to Dan's attorneys re: Betsy's fee petition. Review of e-maii from Betsy and reply; Review of e-mail from Laverne and reply; Made revismns to proposed Order on Guardian's Fees and e-rnaiie'd same to counsel. Prepared Formal Notice for Petition to List Real Property; Assembled Petition with exhibits. Sent follow up e-mail to counsel re; Agreed Order; E-mail from David Garten re: same Telephone call to Laverne at Ron D?Anna's otfioe re: Agreed Order; Scanned and e-?led Petition to List Property and Formal Notice; Mailed same to counsel via certi?ed mail; Review of e-mails from Betsy; Prepared forms for Annual Plan and Physician?s Report and emailed same to Betsy; Updated ?le. Review and revisions to Annual Plan Review of e-mail from Betsy and reply to same; Review and revisions to Annual Plan drafted by Betsy; E-rnailed revised Annual Plan to Betsy E-mailed proposed Agreed Order to Manuela at Judge Ticktin?s of?ce. POSTAGE COPIES To make an easy oniine payment escomlOnline? please via! the Payment Seoure-Paymants-toEld Elder Law Associates PA 0.20 0.30 020 010 0.80 0.20 0.30 0.10 Total Fees Total Expenses Page. 2 Invoice Number 56841 $125.00 $25.00 $125.00 $37 50 $125.00 $25.00 $125.00 $12 50 $125.00 5100 CD $350.00 $10.00 $125 00 5:0 $125.00 $12 50 1.00 $15 73 54.0.0 5?3-50 $29.28 $?99.28 $1638.45 52-13? 73 Page on our website ELDER LAW ASSOCIATES PA i'264 West Palmetto Parli Road Suite 101 Boca Raton Florida 33433 Phone - 561- {50-3850 Ms. Elizabeth Savih Savitt Guardians 501 N. Country Club Drive Atlantis. FL 33462 Our file #3 30818.00? In Reference to: Guardianship for Carla Simmonds Professional Services Rendered Date Staff Desorption 9t04f2015 LR Work on file; Rewewed. saved and e-mailed Aoreed Order on Guardian's Fees to BelSy Review of e-mail from Betsy and reply to same Prepared Proof of Service of Formal Notice E-mail trom Betsy and reply to same Review and reply to emails re fees Review of letter to attorney for Dan Schmidt Review of email from Dan and Betsy Work on ?le; Drafted letter to Ronald D'Anna E-mailed letter re: Betsy's fees to counsel and client. Review of e-mail from Daniel Schmidt. Discussmn with Rubin re same 910912015 LR 9/1012015 LR 9J1?i?201 5 EM 91161201 5 EM EM 9116/2015 LR 9l17/2015 LR 9!18!2015 EM 9/1812015 LR Discussion with Morris re: same; Drafted letter to David Garten Updated, organized and indexed Iilu Telephone call from Dan Schmidt and revrew 01 his emails to Lisa and lelephone message to her. Email to Betsy LR 9f21l'2015 EM from Betsy 91202015 EM Review of all emails to and I 921/2015 LR Further drafting of letter to David Garten; E-mails with Betsy. Case discussion math and directions to Rubin. Rewew and revisions Io letters to Ronald D'Arina and David Garten. I Telephone call from Betsy Savitt. Case discussmn with and directions from E. Morris; Drafted letter to Ronald Made revisions to letter to David Garten: E-mailed letters to Ronald D'Anna and David Garten. Telephone call with Betsy 9122i'2015 EM 912212015 LR 912412015 LR from Betsy Savitt. Further e-mails Review of e?nieil and vmcernail from Daniel Schmidt. Invoice Date: October 20. 2015 invoice it: 57380 Term: Due Upon Receipt Hours 010 0.20 0.10 010 0'20 0.10 030 010 0.30 0.90 0 20 0.20 0.40 0.40 120 030 Rate $125 00 $125 00 $125.00 $350.00 $350 00 $350 00 $125.00 $125.00 $350 00 $125.00 $125.00 $350.00 $350 00 $125.00 $350.00 $125.00 $125.00 Charges $12.50 $25.00 $12.50 $35.00 $70.00 $35.00 $37.50 $12.50 $35 00 $37 50 $112.50 $70.00 $70.00 $50.00 $140.00 $15000 $37.50 .gn? - Elder Law Associates PA Dated: October 20. 2015 Our file 1! 30818.00? in Reference to: Guardianship for Carla Simmonds Page invoice Number STSBEI 9124:0015 LR Review of e-rnail from Dan Schmidt; Review of lite; 0.20 $125.00 $25.00 Email to Betsy. 91?251201 5 LR E-mail from Belay and reply to same. 0.10 $125.00 $12 50 91250015 LR Review of e-mail from David Garten; Telephone calls 0.60. $125.00 57's 00 with David Garten and Elizabeth Saviit?. Telephone call to Chase Bank: E-meil to David Garten. 90812015 LR Raview of e?mail from Belay; Telephone call with 0.50 $125.00 $62 50 Betsy; Telephone call to David Garten's of?ce: Review of e-mail and report lrom Betsy. 9130(2015 LR Telephone call from Betsy Savitl. 0.20 $125100 525.00 Total?Fees $1 142 50 Expenses 18 on $4 50 91'30/2015 COPIES Total Expenses $450 51.14100 Total New Charges $2.43? T3 Previous Balance 53,554.73 Balance Due ehSIIe To make an easy onlme payment please the Payment Pap-e alriggm?cfm '?elderlawaasocmtes aw? . .. p. and click on the LawPay link. 2. 5 Filing 36771135 E-Filed 01/20/2016 01:43:09 PM IN THE CIRCUIT in? OF THE :llt'IEhN'lH JUDICIAL CIRCUIT, IN OR PALM BEACH COUNTY, FLORIDA Case No. IN RE: GUARDIANSHIP UF CARLA SIMMONDS. RESPONSE MOTION 0 ill FRUM THE 'I'ltl I Respondent and Trustee [)uniel Schmidt. :13 the Successor ?l?rustee under the Carla Simmonds Revocable Trust Agreement urn/"d Mary 2012 Schmidt"). by and through the undersigned counsel, hereby responds to the Motronho (?onipel l?ttyments from the Ward?s Trust ?led on October 27, 2015 (the ?Motion to (.?ompel Payments"), and in support states: l. The Ward. Carla Simmondst as Settlor {prior to her itienpacity)? established the Carla Simmonds Revocable 'l?rusr Agreement on May H, 20D (the Carla named Mr. Schmidt as Successor Trustee under the Trust due to her trust and con?dence in Mr. Schmidt? Carla knew that Mr. Schmidt would act for the best interests 2. Therefore, pursuant to her trust and con?dence in Mr Schmidt, Carla granted Mr. Schmidt the unfettered discretion on how and when to make distributions to ('nrla, or for her bene?t, in the unfortunate event ot?an incapacity. Unlortumttely. such risks came to pass and Lurk: needed a guardian appointed over her person because. ot?Curlat?s inability to cure for herself. Fhe Guardian then filed the Motion to Compel Puyments. 3. The Trust?s clear terms provide: In such event of ineupucity, the co 'dltt i i 1 111'}; s, it appropriate, and/or Succeswr Trustee?st it? any. present benehci 000110001 1 1 1 SHARON R. BOCK, CLERK, 01/20/2016 01:43:09 PM . FILED: PALM BEACH COUNT nu?. a? ?a?m-v Ind-'1 In re: Grmm'iinm?np til Carin Case No: 5020 ld?MltJUJ-Z?i?x Response to Guardian?s Motion in Compel Payments from the Ward's Trust Page 2 of 4 gife discretion. stint? use so much of the interim and principal of the mi}: frame for the Snider's bene?t am! more dqn'ndmir npim Senior nun H'J'?f?li?li?i n} .?ii'i'i'l'ui'h' incapacity, adding income to prmetpal Trust at Article XI. Section At?) (emphasis added). 4. In the face of such trust terms providing absolute discretion, the Guardian requests this I-{onorublc Court to compel the 'l?t?ustcc to distribute Florida courts have been clear that a court cannot compel the l'rustce of a discretionary trust to make distributions in order to pay guardianship expenses, making a cl ".ar distinction that a guardian cannot supplant his or her determination for that ot?a scitlor with to a trust established prior to the incapacity. Sec. Covenant Trust (my. Hirmrm. 45 So. 3d 499. (Fla. 4th DCA 2010}. Moreover, it is highly improper, and there is no basis in law or fact, to request a court to make a prospective ruling compelling a trustee (or anyone else) to make payments to, or for the bene?t of, a guardianship estate without a ofticcd or propriety, and without court oversight. In fact, established Florida law states the exact opposite. See. rag. 7441.!08. Fla. Stat. (2015). See also Fla. Stat. (2015) {expenses may be paid during the interim . .Subject to obtaining court approval of the annual accounting. . 5. Still further, the Guardianship Estate. here has the assets and ability to meet t'arla 5 needs. For instance, the Guardian has control over an IRA from h'tei?r'ill in the amount ot $45 000.00? montth Social Security in the amount ot??il?sutit} (giVing the guardianship estate a surplus ofover 5300.00, as admitted by the. Guardian); funds from ii tax refund: funds in an insurance- policy. Thus. even it?the?i?mst did not have a health savings account; and funds from 1 relief a wholly discretionary standard for making distributions, tlii. could not obtain In re: Guardianship af'Cnriu Stunt?thth (Jase Non Response to Guardian's Motion to Compel Payments From the Ward's Trust Page equated herein the law tdu? that the assets uftiw guardianship errata are be used to pay such arpenses. 744.108t8), Fla. Stat. (2015} (?When court proceedings are instituted to review or determine a guardian?s or an attorney?s ?Des under subsection such proceedings are part of the guardianship administration process and the costs. including costs and attorney fees for the guardian's attorney, an attorney,r appointed under s. 744.33 I (2 or an attorney who has rendered services to the ward, shall be determined by the court am] pair! from the (tracts of the guardianship estate unless the court ?nds the requested compenqation under subsection (2) to be substantially unreasonable") (emphasis added). 6. Still further, Mr. Schmidt, in his capacity as 'l?rustee. is not subject to the personal jurisdiction of this Honorable Court: as no service of process has: been directed to him in such capacity. Therefore, no relief can be granted against him. as ?l'rustee. Daniel Schmidt, as 'l'rustee, respectfully requests this Honorable Court to enter its Order denying the Motion to Conich denying any reliet?to the Guardian and awarding all such other and further reliet?as the (Tour! deemsjust and proper. SERVICE I HEREBY CERTIFY that a true and correct copy ol'the foregoing has been furnished via e-mail to Ellen S. Morris, Esq., Elder Law Assoeiatcs PA, Attaineys tm (ntardian, 7-84 Palmetto Park Road Suite 10] Boea Rama, Fl. 33433 .. 00043.01]! In re: Guardianship QI'Cm'ia Case No.: Response to Guardian's Malian In Compel Payments f'rmu the Ward's Trust Page 4 0H FL 33409 and on this 20th day of January,? 2016. MAGUIRE LAW CHARTERED 400 Columbia Drive, Suite 100 West Palm Beach, FL 33409 561-300?6812 561-687-8103 Attorney for Daniel Schmidt is] William J. Maguirc William J. Maguirc Fla. Bar 00043.000l '33 i FILED: PALM BEACH CO ion. Filing 36949207 E-Filed 01/25/2016 02:10:05 PM IN THE CIRCUIT COURT OF THE Fl JUDICIAL CIRCUIT IN AND FOR PALM BEACH FLORIDA IN RE: GUARDIANSHIP OF PROBATE CARLA SIMMON 08 CASE NO. NOTICE OF OF MOTION TO COMPEL FROM TRUST COMES NOW the Movant, Elizabeth Suvitt, as plenary guardian ei?the person and property of Carla Simmonds {the 51rd), by and through her undersigned counsel, and hereby withdraws her Motion to Compe! the ll-hn! 's Trust ?led in the above-referenced case on Oetober27, 2015. I HEREBY ERTIFY that a copy of the foregoing was served via the e?Portul on this 25?' day ofJanuary, 20l6, to Ronald E. Esq, McClosky, [)?Annu (lit Dieterle, 210l NW. Corporate Blvd. Suite 400, Been Ruton, 10.33431; David M. F,qu Law Of?ce ot?lmvid M. Garten. 400 Columbia Drive, Suite 100. West Palm Beach. 141,33: and William J. Maguire, Esq, MAGUIRE LAW CHARTERED. 400 Columbia Drive. Suite IUD. West Palm Beach. FL 33409. Ellen 3. Morris, Esq. Attorney for Guardian Florida Bar Number: 850306 ELDER LAW ASSOCIATES PA 7284 W. Palmetto Park Road, Suite It? Boca Raton, FL 33433 Telephone: (56 I 750-3850 Fax: (56] 750-4069 EdMuil: Secondary E?Muil: Secondary E- Mail: 02:10:05 PM I UNTY SHARON R. BOCK. CLERK, 01/25/2016