JENSEN LAW

Attorney for Petitioner

THIRD JUDICIAL DISTRICT COURT

SALT LAKE COUNTY, STATE OF UTAH

IN THE MATTER OF:
F.S.,
a minor. / )
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) / PETITION TO APPOINT CONSERVATOR AND AUTHORITY TO SETTLE MINOR’S CLAIMS
-HEARING REQUESTED-
Probate No. 11-55555
Judge Sam Johnson

PETITIONER, Mark Sanchez, states and represents to the Court that:

1. Petitioner is an adult resident of Salt Lake County, State of Utah, and is the natural father and caregiver of F.S.

2. F.S. is a minor, not yet eighteen years of age, born September 9, 2013, and will attain his majority until September 9, 2031.

3. On or about June 28, 2016, F.S. sustained a broken arm while at a daycare facility.

4. Venue is proper in this County because F.S.’s primary residence is with his natural father, Mark Sanchez, in Salt Lake County, State of Utah.

5. Said minor is unable to manage his own property and affairs for reason of his minority.

6. Mark Sanchez, the person whose appointment as Conservator is sought, resides at 78 Bridgestone Way, Salt Lake City, Utah 84123 with F.S., the minor child, and is qualified to act as such. Mr. Sanchez’s acceptance of appointment and agreement to the proposed settlement will be filed with the court prior to the scheduled hearing.

7. F.S.’s natural mother, Courtney Kardashian, has consented to the appointment of Mark Sanchez as the conservator for her son. Ms. Kardashian’s signed consent will be filed with the court prior to the scheduled hearing.

8. The protected person’s estate consists of a claim for personal injuries with a settlement offer of ______DOLLARS from ABC Insurance Companies (“ABC”). F.S.’s recovery of $______ shall be placed in a restricted federally insured interest bearing account until his eighteenth birthday. No funds are to be removed prior to his eighteenth birthday without Court approval.

9. Petitioner believes that it is in the best interest of said minor that said offer be accepted and that said Petitioner be authorized to release all claims of said minor against Medical Center and their liability insurer, ABC, arising from said incident by accepting a distribution as specified in Paragraph no. 10 below.

10. Petitioner requests the Court approve distribution of the settlement proceeds as follows:

a. Payment of $______ to Jensen Law for attorney’s fees;

b. Payment of $______ to Jensen Law for costs incurred in bringing this action.

b. Payment of $______to outstanding medical bills/liens;

c. The balance of $______ shall be placed in a federally insured interest bearing account until said minor reaches the age of majority. No funds are to be removed prior to the minor’s eighteenth birthday without Court approval.

WHEREFORE, Petitioner requests that:

1. The Court fix a time and place for hearing;

2. The Court determine that said person to be protected has property which could be wasted or dissipated unless proper management is provided;

3. The Court appoint Anthony Stout as Conservator of the estate of said minor, to serve without bond, and approve a settlement of said minor’s personal injury claim as outlined herein; and

4. Upon qualification and acceptance, Letters of Conservatorship be issued.

DATED this _____ day of ______, 2017.

JENSEN LAW

__/s/ Steven Jensen___

Steven Jensen

Attorney for Petitioner

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