Halperin

I. BACKGROUND

A. Warren’s Trust Warren established a trust in 2014. His three children—Susan, David, and Michael—were all beneficiaries of the trust. On or about January 1, 2021, Susan learned of the terms of the trust. In Susan’s view, the trust was more favorable to her brothers than to her. In her operative first amended complaint (FAC) in the present case, Susan alleged that, while David and Michael were to receive their shares of the trust estate “outright and free of Trust,” Susan’s share consisted of IRA retirement accounts, still held in trust under unfavorable distribution terms and subject to high tax burdens upon withdrawal. Susan alleged her beneficial share had a fair market value of about $1 million less than the beneficial share of each of her brothers. In January 2021, Susan spoke with Warren, who stated he was going to amend his trust to equalize the distributions among his three children. Warren told Susan that, as early as April 2019, he had spoken with an attorney, Paula Weaver, about making such an amendment to the trust. Susan alleges, however, that David and Michael interfered with Warren’s efforts to amend the trust. The alleged interfering conduct (most…