to noo further effect be null and void and having n effect aand ndunenforceable assuch.Copy unenforceableas ofJune such. Copy of June 24,1993 24, PowerooffAttorney 1993 Power Attorney iiss attached attached aass Exhibit Exhibit "A". partofofsaid Asaapart "A". As saidDeclaratory Relief, Declaratory Relief, Petitioners Petitioners would would askfortheenforcement ofsubsequently ask for the enforcement of subsequentlyexecuted executed P of Attorney, owerof Power Attorney, dated dated November 2013, a 15,2013, November 15, ppointing appointing Petitioners Petitioners each each to serve inthecapacity to serve in the capacity a attorneyiinnfactfor ass attorney fact for theProposed the Proposed Ward. Acopy Ward. A ofthatPower copyof ofAttomey that Power of isattached Attorney is heretoand attached hereto andincorporated herein incorporated herein Exhibit"B". asExhibit as "B".And, And,inintheunlikely thatthe eventthat the unlikely event shoulddeclare the Court should declarePetitioners' Petitioners' Powerooff Power Attomey Attorney not enforceable not enforceable as such,thenPetitioners as such, then Petitioners seek appointment of seekappointment first,aaTemporary of first, Temporary Guardianppending Guardian endingwhatthey what they expect o be expecttto ofthis contestof be aa contest thisPetition, Petition, andsubsequently, and subsequently,aa Permanent Permanent Guardian vertheProposed Guardian oover the ProposedWard's Ward's P ersonandEstate.Further, Person inconnection and Estate. Further, in connectionwith with theforegoing, the foregoing, Petitioners Petitioners seekofthis Orderfor anOrder seek of this Court an foran audit/accounting anaudit/accounting pursuant pursuant to Rule to Rule 172oftheTexas 172 Rulesof of the Texas Rules CivilProcedure, ofCivil Procedure,providing providing statement aa statement of behalfooffthe accountsoonnbehalf of accounts the Proposed Proposed Ward, and for the best interest oftheProposed Ward, andforthebestinterest Ward, identifying of the Proposed Ward, identifying andstating and stating tthe heextent, extent,
692687.1 692687.1
Silverado Appx. 0066 No. 1-15-586-CV 16 oftheProposed havebeensubjected Wardhave been subjected to wrongful use andexcess excess if any,ttoowhich the if any, assetsof the assets the Proposed Ward to wrongful use and
ofdistribution of distributionwhile while being inthe beingin the control ofthe controlof heretofore personsheretofore the persons exercising exercising Power ofAttorney Power of Attorney
in of the Proposed Ward, behalf oftheProposed inbehalf viz.Carol Ward, viz. Peterson Manley CarolPeterson Manley and TroyPeterson. David and David Troy Peterson.
10. Carol 10. Carol Peterson Peterson Manley Manley and David andDavid Troy Troy Peterson Peterson have have exercised exercised self-serving self-serving and and
and control o ominionandcontrol wrongfulddominion wrongful offthe the assets of the Proposed WardandherEstatepursuant assets oftheProposed o the Ward and her Estate pursuant tto the
Attorney d PowerooffAttorney Power atedJune24, dated 1993 (Exhibit June 24, 1993 (Exhibit"A").For thisreason "A"). For this thiscause uponthis reasonupon andfor causeand for
thebest andprotection interestand the best interest oftheProposed protection of the Proposed Ward, Petitioners Ward,Petitioners seekthe seek appointment the appointment of an of an
to represent the auditortorepresent auditor accounting the accounting of assetsand of assets disposition anddisposition of forthe samefor of same preceding the preceding oneyear one year
period.11. period. In connection In connection with the with i.e.theProposed person,i.e. the person, Ward,thesiblings the Proposed Ward, ofPetitioners, the siblings of Petitioners, 11.
CarolPeterson Carol Peterson M anleyaand Manley ndDavid Troy Peterson h David TroyPeterson have, addition ave,iinn addition to exercising toexercising dominion and dominion and
over the controlover control the assets