by PL

Here are several of the PETITION FOR ORDER complaints in the filing submitted by Priscilla Presley (Petitioner):

Questions:

How did Priscilla Presley “discover” this document? Who alerted her to the existence of this amendment? (“Pertaining” to be an amendment?)

Questions:

Is there any evidence that this 2016 Amendment was delivered? Is there any evidence that the 2016 Amendment was sent? Is there any evidence that the 2016 Amendment was in some way provided to Priscilla Presley?

The misspelling of a name or word in a legal document does not (alone) render it void.

[On a side note, the March 3, 1977, will of Elvis Presley also contained a date that was added by hand, similar to what is described here (and with the year changed), yet there was no objection by the mother (Priscilla Presley) on behalf of the minor beneficiary (Lisa Marie Presley).

Further, “no provisions of the [Elvis Presley March 3, 1977, will] appear on the signature page.” There was no objection to this, either. The witness signatures are included on the page with no provisions.]

Is there any provision that requires the amendment to be witnessed and notarized? See below.

What constitutes “serving” as a co-Trustee for the Promenade Trust? Is there an action that Priscilla Presley has taken that would qualify as an action as part of her duties as co-Trustee, or does “serve” mean to simply be designated, and then accept, that title?

Priscilla Presley contends in this document that from January 27, 2010, until the present day (“at all times since then”), she and Barry Siegel have continued to serve as co-Trustees. However, in other documents relating to the Promenade Trust case, Mr. Siegel references March 2016 as the time period in which he ended his employment with Lisa Marie Presley, and he and Lisa Marie Presley subsequently were involved in a lawsuit over the managing of her finances by Mr. Siegel and Provident. This case began in 2018 and continued until 2020. How can Priscilla Presley content that she and Mr. Siegel are still co-Trustees given Mr. Siegel’s relevant sworn statements to the contrary? (Note that there is a difference between Mr. Siegel’s position as financial/business advisor/manager and as co-Trustee; however, it is unreasonable to believe that Lisa Marie Presley fired Mr. Siegel as her advisor but kept him on as co-Trustee. In fact, in the court filings there is a provision wherein it appears that Mr. Siegel would be automatically removed as co-Trustee if he was terminated as LMP’s business manager.)

From 2018 to 2020 did Priscilla Presley not wonder why the co-Trustee was in a legal battle with her daughter?

Simply, Mr. Siegel acknowledges the end of his employment in 2016, while Priscilla Presley says she and Mr. Siegel, in 2023, are still co-Trustees. This runs counter to what Mr. Siegel has stated in sworn declarations.

Questions:

Are we supposed to believe that in the past seven years that Priscilla Presley was not aware that she and the co-Trustee, Mr. Siegel, had been removed from their positions as co-Trustees?

And…that Priscilla Presley was not aware that Mr. Siegel had been removed? That it was her own daughter who removed Mr. Siegel?

Are we to believe that over seven years Priscilla Presley and Lisa Marie Presley, between them, not once mentioned or discussed that Lisa Marie Presley had removed her mother and Mr. Siegel as co-Trustees of the Promenade Trust? This would tend to support Priscilla Presley’s contention that the removal did not occur, and thus she did not hear about it and was not informed about it, except for the fact that Mr. Siegel acknowledged the removal as early as 2018 in court documents.

Note that there is no mention by Mr. Siegel of only his removal as co-Trustee, and not the removal of Priscilla Presley. He specifically refers to the 2016 removal of Priscilla Presley from the position of co-Trustee.

In Lisa Marie Presley’s 2018 action against Mr. Siegel, we find the following reference to his employment status: “Up to the time that Lisa fired Siegel in 2016…” [Paragraph 32]

Priscilla Presley states that she “believes” (present tense) that “Barry [Siegel] has already or will soon resign as a co-Trustee of the Trust.” This contention comes from a document filed with the Superior Court in early 2023, which would require that Priscilla Presley had not been aware…for seven years…that Mr. Siegel was no longer a co-Trustee. Is this possible? Did she not contact Mr. Siegel before filing this Petition? Did her attorneys not contact Mr. Siegel?

[And why is Brigitte Kruse, the head of GWS Auctions, listed in this Petition as Priscilla Presley’s attorney-in-fact, with an address listing in Orlando FL (that of private attorney Lynn Walker Wright)?]

Note that in Paragraph Four of this Petition that Mr. Siegel is referred to, by attorneys for Priscilla Presley, as Lisa Marie Presley’s “former business manager.” So does Priscilla Presley take the position that Mr. Siegel is her daughter’s “former” business manager, but also “current” co-Trustee? That would suggest that Priscilla Presley is alleging that Lisa Marie Presley fired Mr. Siegel as her business manager, then sued him, but did not remove him as the co-Trustee, which is ludicrous (and runs counter to the Trust, as noted above).

Take a look at this paragraph from Mr. Siegel’s 2018 “Declaration” in the Promenade case:

This is pretty clear, isn’t it? Mr. Siegel states, in a sworn declaration, that he was removed as co-Trustee, along with Priscilla Presley, on or about March 5, 2016. How, then, did Mr. Siegel come to be removed, and yet Priscilla Presley had no knowledge of this removal? Seven years…and she knew nothing…? At no time did Priscilla wonder, “Hey, what happened to Barry?”?

Just for reference, here is another mention of March 2016 by Mr. Siegel:

This reference does not specifically cite the co-Trustee removal, but does support the notion that it was March 2016 when Lisa Marie Presley was making changes in her financial advisors.

Questions:

Where was the amendment document discovered, and is there another copy other than the PDF document sent to Priscilla Presley? Who sent this document to Priscilla Presley? Has the document been forensically examined? It is interesting to note that even with the “11” added to the document date, Priscilla Presley is still agreeing in her Petition that the document “appears” to be dated “March ___, 2016.”

[Again, to note, the signature page of Elvis Presley’s will did not include any of the will’s provisions, and no one had any objection to that (and certainly Priscilla reviewed the will since her minor daughter was the beneficiary).]

A .PDF file is typically created from any document where there is the capability to convert the document into a .PDF format. (Or, a .PDF file can be created as a new document.) This is often done with a Microsoft Word document as the original. There should be copies of this document in .PDF format and Word format, unless the attorney who prepared the amendment for some reason destroyed his/her electronic data files, which seems very unlikely.

It is interesting that Priscilla Presley is asserting that since the original 2016 Amendment has “not yet been located,” then the original Amendment document is “presumed” to have been destroyed. Lacking further details, this is not a reasonable inference.

In this first document above there is a misspelling/typo in one of the Lisa Marie Presley documents (“I make revoke” should obviously read, “I may revoke,” based on the subsequent wording in the same sentence), but this is not raised by Priscilla Presley. Likewise, it is worth noting that Paragraph One of the Petition includes the words, “at the time of his death,” even though the decedent was female.

As to the meaning and intent of this Section (above), it does spell out the requirements for Lisa Marie to revoke or amend the document. It is this Section that appears to provide the most legal support for the Petition. Again, though, the issue of delivery must be addressed, as do the facts pertaining to when and from where the document may have been mailed/provided to Priscilla Presley. Mr. Siegel was aware that he had been removed/replaced, so it must be determined why/how Priscilla Presley did not (allegedly) know that she had also been removed/replaced. The attorneys who handled this amendment would have been aware of how and when Priscilla Presley and Barry Siegel were notified of the changes, and there would be a record of this action with the attorney. Who is the attorney who provided counsel to Lisa Marie Presley in March 2016, and who handled this amendment on her behalf? Was this person not identified, located, and interviewed before this Petition was filed?

Another curious section of the filings further supports the Petitioner, and it perhaps speaks to the intent of the decedent. In her 2018 action against Barry Siegel and Provident, Lisa Marie Presley lists three persons who are “entitled to notice of this Petition,” these three being Priscilla Presley, Danielle Keough, and Benjamin Keough. In the field indicating the relationship between the decedent and each person listed, Priscilla Presley is referred to as “Co-Trustee,” while Danielle Keough is referred to as “Adult daughter of beneficiary,” and Benjamin Keough is referred to as “Adult son of beneficiary.” (LMP is the beneficiary.) So, the big question here is, if Lisa Marie Presley removed her mother as co-Trustee in March 2016, why did she list Priscilla Presley as “Co-Trustee” in a 2018 court filing? And if LMP designated one or both of her adult children as co-Trustees in March 2016, why is neither listed as such in a 2018 court filing? One explanation may be that the document was not updated to reflect these specific changes, and is referencing the Trustee arrangement going back to 2010. The intent of the decedent, then, could not be ascertained without the background on the preparation of this filing. (Note below the signature issue pertaining to this section of the filings.)

The second big question on this part of the filing pertains to the signature. In all the court filings signed by Lisa Marie Presley, her signature is unusually large, and as was typical of her signature, pretty much illegible. Her “signature” on legal documents was very much like her public “autograph,” to put it another way. On this specific filing (LMP v Siegel/PFM), however, the signature is noticeably smaller, and appears (in my view) to be a signature copied from somewhere else and applied/inserted here (Page 18, 18STP). Consider the following:

Questions:

Which of these above is not like the others?

Does the purported 2016 Amendment feature an unusual “signature” like this?

And did the attorney who put together this filing not know about the 2016 Amendment?

According to Mr. Siegel, he is not a co-Trustee for the Promenade Trust as of the filing of this Petition (January 2023), and certainly the attorneys for Priscilla Presley know this. And there is the open question of whether Priscilla Presley, as of the filing of this Petition (January 2023), is a co-Trustee of the Promenade Trust.

Question:

Why?