this is in their rfoI am the Petilioner in this matter and I know the facts to be tnre from my own personal knowledge,
except for those facts which are stated on information and beli.ef and as to those facts I believe them
to be true. If called to testifii I could and would competently rtestify under oath to each fact stated
I. On3/13115 this court appointed Special Master, Cornmissioner Richard G.Vogl, retired..
Each party wrs to pay Il2 of the fee (Pet. paid it all since Respr. would not) and both parties were
ordered to corcperate (initially Resp. said she didn't have to cooperate so at a subsequent RFO the
court then orclered Resp. to cooperate). Respondent
failed to aftend the 6117l15 meeting set by the
AMENDED DECLARATION OF PETITION]ER LEVI BRADFORD
In Re Marriage of Bradford and Camarenal CaseNo. 14D007406
Special Master. I attended the meeting with my attomey, Anna C. Brace. Afterwards, Comm.
Vogl prepared an "Interim Report of Special Master" (a copy is attached hereto as Exhibit "A") and
filed it with the court on(###) ###-####.I request that the court adopt the recommendations of the Special
Master as set forth on page 6 of the report. I also request Petitioner reimburse me $2,100 forthwith as
and for her one-half of the $4,200 Special Master's retainer fee that I advanced.
2. I also request that this matter be assigned to Comm. Vogl regarding 1)
the characterizatron of the real property on Seneca in Anaheim (see "Further Suggestion" on page 6
of Ex. "A".) and 2) to determine the construction needed to finalize the family residence and
determine and manage logistics required to finahze said project (see Ex."B" "Building
Project Tracking Application"). At an Ex Parte on 717lI5 this court ordered that the minor children
not be allowed at the property because of the condition of the residence. I also request Respondent to
be ordered againto cooperate and to attend the next meeting with Comm. Vogl and that there be
monetary and/or evidentiary sanctions if Respondent continues to fail to cooperate.
3. The characterization of the family residence is in dispute as the Respondent believes thatit
is in her name alone and thus her separate property. The Petitioner believes that the community has a
substantial equity in the residence based on Moore/Marsden as the parties have resided and used
community funds to pay the mortgage for 10 years. Further the community paid for building
materials and substantial work to improve the residence during the remodel. The Petitioner has a
binder worth of receipts for improvements which is 6 inches thick. It is anticipated that the
constructions related expenses alone would require days of court time. Petitioner believes that
Commissioner Vogl will require the assistance of a forensic accountant and I request that the court
appoint Joel Dannenhauer under Evidence Code 730, to calculate a Moore/Marsden; to assist
in the determination of Family Code 264A tracing and of the characlerization of the family residence.
4. The Respondent has commenced work on the remodel project at the family residence
without consideration of the need to get permits for certain items. For instance, the Petitioner
finished drywall and painted prior to an inspection which requires acoess to the sheer wall. The
AMENDED DECLARATION OF LEVI BRADFORD
In Re Marciage of Bradford and Camarenal Case No. 14D007406
Respondent continues to cut corners and fails to understand what is required to finahze the project.
There are open building permits which must be completed (see Exhibit'oB" attached). I am
requesting ttrat the Court appoint Commissioner Vogl to determine what construction needs to be
completed and manage the logistics necessary. Without this project frnalized, the family residence is
merely a debt that no on can reside in and its sale is impossible.