Lalanne

I. BACKGROUND

Lalanne’s and Armanino’s parents formed several estate planning entities in which Lalanne, Armanino and other immediate family members hold financial interests. The entities include Lalanne LLC (LLC), a real property investment venture; the Lalanne 1997 Trust; and the Lalanne Ranch Partnership. At some point, Lalanne became the managing member of LLC, trustee of the trust, and managing general partner of the partnership. In 2006 or early 2007, Armanino took over these positions. A. 2007–2008 Settlements of Disputes Between Lalanne and Armanino Several disputes between Lalanne and Armanino (in her individual capacity and in her management capacities of the various estate planning entities) were submitted to mediation before the Honorable Ellen S. James (retired) under the auspices of JAMS, an alternative dispute resolution firm (formerly Judicial Arbitration and Mediation Services). In 2007, Lalanne and Armanino arrived at a partial settlement, which was memorialized in a signed agreement. This settlement required LLC and the Lalanne 1997 Trust to make certain immediate distributions to Lalanne; Lalanne and his wife to vacate a home that belonged to the…