Electronically FILED by Superior Court of California, County of Los Angeles 7/1/2021 12:04 PM Sherri R. Carter, Executive Officer/Clerk, By Bella Gasper, Deputy Clerk

1 BRUCE S. ROSS (BAR NO. 051468) ALAN T. YOSHITAKE (BAR NO. 125000) 2 Seyfarth Shaw LLP 601 S. Figueroa Street, Suite 3300 3 Los Angeles, CA 90017

Received: 7/1/2021 12:04 PM (213) 270-9600 4 (213) 270-9601 FAX Email: [email protected]; 5 [email protected] 6 Attorneys for Petitioner, Bessemer Trust Company of California, N.A. 7 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF LOS ANGELES 11 Case No. BP 108 870 12 IN THE MATTER OF EX PARTE APPLICATION FOR 13 COURT APPROVAL OF RESIGNATION OF BESSEMER 14 TRUST COMPANY OF CALIFORNIA, CONSERVATORSHIP OF N.A. AS CO-CONSERVATOR OF THE 15 ESTATE DUE TO CHANGED BRITNEY JEAN SPEARS, CIRCUMSTANCES; DECLARATIONS 16 IN SUPPORT THEREOF 17 Conservatee [Probate Code §2660] 18 Date: July 2, 2021 19 Time: 8:30 A.M. Dept: 4 20 Deadline 21 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 22 PLEASE TAKE NOTICE that on July 2, 2021, at 8:30 A.M. in Department 4 of the above 23 entitled Court, located at 111 N. Hill Street, Los Angeles, California 90012, applicant Bessemer Trust 24 Company of California, N.A. (“Petitioner”) will and hereby does apply to this Court, ex parte, for an 25 order approving Petitioner’s resignation as Co-Conservator of the Estate of Britney Jean Spears due 26 to changed circumstances. In the alternative, Petitioner seeks an order shortening time to hear 27

28 -1- EX PARTE APPLICATION FOR COURT APPROVAL OF RESIGNATION OF BESSEMER TRUST COMPANY OF CALIFORNIA, N.A. AS CO-CONSERVATOR OF THE ESTATE DUE TO CHANGED CIRCUMSTANCES 1 Petitioner’s application for an order approving Petitioner’s resignation as Co-Conservator of the 2 Estate of Britney Jean Spears due to changed circumstances to meet the next Court hearing scheduled 3 for July 14, 2021. 4 Petitioner was appointed by a minute order of this Court on November 10, 2020, but has been 5 awaiting entry of the Court’s order, which was just entered yesterday, and issuance of Letters of 6 Conservatorship authorizing Petitioner to act. 7 This request for approval of resignation is being brought ex parte, based on the following 8 exigent circumstances: 9 1. The fact that the Conservatee claimed irreparable harm to her interests in her 10 testimony at the June 23, 2021 hearing, and, more specifically, the Conservatee’s objection to the 11 continuation of her voluntary Conservatorship and her desire to terminate the Conservatorship; 12 2. To promote judicial economy by obviating the need to formalize the appointment of 13 Petitioner, who has not been issued Letters of Conservatorship and is therefore not currently 14 authorized to act, has taken no actions as Conservator, has made no decisions as Conservator, has 15 received no assets of the Estate, has taken no fees, and who will immediately resign if such 16 appointment is formalized due to changed circumstances. 17 Petitioner is resigning because of the changed circumstances reflected in the Conservatee’s 18 June 23 testimony and for the following reasons:

19  In originally consenting to its appointment, Petitioner relied on the representations of 20 the partiesDeadline that the ongoing Conservatorship was voluntary, and that all parties, 21 including the Conservatee, had consented to Petitioner acting as Co-Conservator of the 22 Estate.

23  In fact, the Conservatee had nominated Petitioner to act as Conservator and consented 24 thereto.

25  As a result of the Conservatee’s testimony at the June 23 hearing, however, Petitioner 26 has become aware that the Conservatee objects to the continuance of her 27

28 -2- EX PARTE APPLICATION FOR COURT APPROVAL OF RESIGNATION OF BESSEMER TRUST COMPANY OF CALIFORNIA, N.A. AS CO-CONSERVATOR OF THE ESTATE DUE TO CHANGED CIRCUMSTANCES 1 Conservatorship and desires to terminate the Conservatorship. Petitioner has heard the 2 Conservatee and respects her wishes. 3 Due to these changed circumstances, Petitioner is tendering its resignation as Co-Conservator 4 and requests that the Court approve its resignation forthwith. Since there is still a currently acting 5 Conservator of the Estate, Petitioner’s resignation will not result in a vacancy in the office of 6 Conservator of the Estate. 7 This application is based on the attached Memorandum of Points and Authorities, the 8 supporting Declaration of Bessemer Trust Company of California, N.A., the Declaration of Ann 9 Piedmont Re: Ex Parte (“Piedmont Declaration”), the pleadings, files and records in this action, and 10 such further argument and evidence as may be presented at the hearing on this application. 11 Notice of this application was or is being given telephonically in accordance with California 12 Rules of Court Rule 379, as set forth in the Piedmont Declaration. 13 Request for Special Notice has been filed by Gladstone N. Jones III, of Jones Swanson 14 Huddell & Garrison, LLC and Yasha Bronshteyn of Ginzburg & Bronshteyn, LLP, attorneys for 15 Lynne Spears, who were provided telephonic notice of this Ex Parte Application. 16

17 Dated: ______,July 1 2021 Respectfully submitted, Seyfarth Shaw LLP 18 19

20 By______/s/ Bruce S. Ross DeadlineBruce S. Ross 21 Attorneys for Petitioner, BESSEMER TRUST COMPANY OF 22 CALIFORNIA, N.A. 23 24 25 26 27

28 -3- EX PARTE APPLICATION FOR COURT APPROVAL OF RESIGNATION OF BESSEMER TRUST COMPANY OF CALIFORNIA, N.A. AS CO-CONSERVATOR OF THE ESTATE DUE TO CHANGED CIRCUMSTANCES 1 MEMORANDUM OF POINTS AND AUTHORITIES 2 3 Petitioner, Bessemer Trust Company of California, N.A., as the appointed Co-Conservator of 4 the Estate of Britney Jean Spears, who is not currently authorized to act, is tendering its resignation as 5 Co-Conservator and requests that the Court approve its resignation due to the change of circumstances 6 set forth below. 7 Under California Rule of Court 3.1200, et seq., a party may apply ex parte for relief if it can 8 be demonstrated that there are exigent circumstances justifying the relief requested. 9 This ex parte application is being filed based upon the following exigent circumstances: 10 A. The fact that the Conservatee claimed irreparable harm to her interests in her testimony at 11 the June 23, 2021 hearing, and, more specifically, the Conservatee’s objection to the continuation of 12 her voluntary Conservatorship and her desire to terminate the Conservatorship; 13 B. To promote judicial economy by obviating the need to formalize the appointment of 14 Petitioner, who has not been issued Letters of Conservatorship and is therefore not currently 15 authorized to act, has taken no actions as Conservator, has made no decisions as Conservator, has 16 received no assets of the Estate, has taken no fees, and who will immediately resign if such 17 appointment is formalized due to changed circumstances. 18 Petitioner respectfully requests the Court to approve its resignation on an expedited basis due 19 to the exigent circumstances set forth above and the changed circumstances created by the 20 Conservatee’s objection to Deadlinethe Conservatorship and the Conservatee’s desire to terminate the 21 Conservatorship. 22 It would be expedient, in the best interests of all parties, and in the interests of judicial 23 economy for the Court to approve Petitioner’s resignation before the Court issues Letters of 24 Conservatorship to Petitioner. Since there is still a currently acting Conservator of the Estate, 25 Petitioner’s resignation will not result in a vacancy in the office of Conservator of the Estate. 26 27 28

MEMORANDUM OF POINTS AND AUTHORITIES -4- 1 THE COURT HAS AUTHORITY TO ACCEPT PETITIONER’S RESIGNATION 2 1. Probate Code Section 2660 provides for the resignation of a Conservator. 3 Specifically Section 2660 states: 4 “A guardian or conservator may at any time file with the court a petition tendering 5 the resignation of the guardian or conservator. Notice of the hearing on the petition shall 6 be given for the period and in the manner provided in Chapter 3 (commencing with 7 Section 1460) of Part 1. The court shall allow such resignation when it appears proper, to 8 take effect at such time as the court shall fix, and may make any order as may be 9 necessary to deal with the guardianship or conservatorship during the period prior to the 10 appointment of a new guardian or conservator and the settlement of the accounts of the 11 resigning guardian or conservator.” 12

13 ARGUMENT 14 2. Petitioner was appointed by a minute order of this Court on November 10, 2020. 15 A copy of the Minute Order dated November 10, 2020, is attached hereto as Exhibit A. 16 3. Pursuant to Probate Code Section 2660, the Court has the authority to accept and 17 approve Petitioner’s resignation. 18 4. Petitioner believes that the Court should accept Petitioner’s resignation as Co- 19 Conservator forthwith, based on the following: 20 a. DeadlinePetitioner agreed to act as a Conservator of the Estate in reliance on the 21 agreement of all of the parties to provide stability to the estate administration. Declaration of 22 Bessemer Trust Company of California, N.A (“Bessemer Declaration”), attached hereto as Exhibit B, 23 ¶ 6. 24 b. It was represented to Petitioner by the parties that the ongoing 25 Conservatorship was voluntary, that the Conservatee had consented in writing to Petitioner acting as 26 Co-Conservator, and that all of the parties agreed to have Petitioner so act. Exhibit B, Bessemer 27 Declaration, ¶¶ 4, 6. 28

MEMORANDUM OF POINTS AND AUTHORITIES -5- 1 c. These representations were supported by the Conservatee’s nomination of 2 Petitioner to act as Conservator. A copy of the Nomination of Conservator is attached hereto as 3 Exhibit C. 4 d. Based upon the representations and agreement of the parties and in 5 reliance on those representations and agreements, Petitioner consented to act as Co-Conservator. A 6 copy of the Consent to Act as Conservator of the Estate is attached hereto as Exhibit D. 7 e. The same representations and agreements described above were made to 8 the Court at the November 10, 2020 hearing (at which that Petitioner was not present) and based on 9 these representations and agreements of the parties, the Court appointed Petitioner to act as Co- 10 Conservator of the Estate. 11 f. From and after the November 10 hearing to the present date, Petitioner has 12 been awaiting entry of the Court’s formal Order of appointment and issuance of Letters of 13 Conservatorship. Petitioner was just informed that the Court entered the Order on June 30, 2021. 14 g. Notwithstanding the foregoing, because Letters of Conservatorship have 15 not been issued, Petitioner still has no legal authority to act as Co-Conservator. 16 h. Petitioner has taken no actions as Conservator, has made no decisions as 17 Conservator, has received no assets of the Estate, and has taken no fees. Exhibit B, Bessemer 18 Declaration, ¶ 9. 19 i. As a result of the Conservatee’s testimony at the June 23, 2021 hearing, 20 Petitioner has become awareDeadline that the Conservatee objects to the continuance of her Conservatorship 21 and desires to terminate the Conservatorship. Exhibit B, Bessemer Declaration, ¶ 10. 22 5. Due to these changed circumstances, Petitioner is tendering its resignation as Co- 23 Conservator. Resignation of Bessemer Trust Company of California, N.A., attached hereto as Exhibit 24 E. 25 6. Petitioner has made this decision to resign only after thoughtful deliberation, 26 keeping the Conservatee’s expressed wishes in mind. 27 7. Given that Petitioner has been appointed, but has no legal authority to act because 28

MEMORANDUM OF POINTS AND AUTHORITIES -6- 1 Letters of Conservatorship have not issued, approval by the Court of Petitioner’s resignation prior to 2 Petitioner being authorized to act will promote judicial economy. 3 8. Since there is still a currently acting Conservator of the Estate, Petitioner’s 4 resignation will not result in a vacancy in the office of Conservator of the Estate. 5 9. Petitioner waives its right to receive any fees and any reimbursement of its costs. 6 10. Since Petitioner was never authorized to act as Co-Conservator, has taken no 7 actions as Conservator, and has taken no fees since the date of its appointment by minute order, 8 Petitioner requests the Court to waive any accounting by Petitioner. 9 10 WHEREFORE, Petitioner prays for an Order of the Court either that: 11 1. The resignation of Bessemer Trust Company of California, N.A. as Co- 12 Conservator of the Estate of Britney Jean Spears is accepted and is immediately effective; 13 2. Any accounting otherwise required from Bessemer Trust Company of California, 14 N.A. is waived, or; 15 3. In the alternative, the time to hear Petitioner’s application for an order approving 16 Petitioner’s resignation as Co-Conservator of the Estate of Britney Jean Spears due to changed 17 circumstances is shortened to meet the next Court hearing scheduled for July 14, 2021, and 18 Petitioner is ordered to give notice of hearing by email to all parties entitled to such notice; and 19 4. For such other and further orders as the court may deem just and proper. 20 Deadline 21 Dated: ______July 1 , 2021 SEYFARTH SHAW LLP 22 23 By: ______/s/ Bruce S. Ross 24 Bruce S. Ross Attorneys for Petitioner, 25 BESSEMER TRUST COMPANY OF CALIFORNIA, N.A. 26 27 28

MEMORANDUM OF POINTS AND AUTHORITIES -7- W

Ihave read the foregoing EX PARTE APPLICATION OF .bbJN BESSEMER TRUST

COMPANY OF CALIFORNIA, N.A. FOR COURT APPROVAL OF RESIGNATION AS CO-

CONSERVATOR OF THE ESTATE; DECLARATIONS IN SUPPORT THEREOF [Probate

Code §2660] and know its contents.

I \OOOQQUI am a Managing Director of Bessemer Trust Company of California, N.A., Petitioner in this

action. I am authorized to sign and verify pleadings on Petitioner’s behalf. The matters stated in the

foregoing document are true except as to those matters which are stated on information and belief, and

10 as to those matters I believe them to be true.

11 I declare under penalty of peljury under the laws of the State of California that the foregoing

12 is true and correct.

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14 .ww x v98 Meme“) Executed on , 2021, at , California.

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16 BESSEMER TRUST COIVIPANY OF CALIFORNIA, N.A. 17

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19 Jeff J. Gléwacki Managing Director 20 Deadline 21

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MEMORANDUM OF POINTS AND AUTHORITIES -3- EXHIBIT A Deadline SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES Probate Division Stanley Mosk Dept. - 4 BP108870 In re: SPEARS, BRITNEY JEAN - CONSERVATORSHIP November 10, 2020 1:30 PM Honorable Brenda J. Penny, Judge

Andrea Avalos, Judicial Assistant Lisa Luna (#10229), Court Reporter Joseph Pereyra, Court Services Assistant

NATURE OF PROCEEDINGS: Petition - Appoint Conservator of Estate Nom/Ap (Subsequent) filed on August 31, 2020 by Britney Jean Spears.

The following parties are present for the aforementioned proceeding:

Samuel Ingham, Attorney Jodi Montgomery, Nominee James Spears, Petitioner Lynne Spears, Interested Party Lauriann Wright, Attorney for Petitioner Geraldine Wyle, Attorney Jeryll Cohen, Attorney Jonathan Park, Associated Attorney Vivian Thoreen, Associated Attorney Yasha Bronshteyn, Attorney Ronald C. Pearson Gladstone N. Jones David Nelson Lynn E. Swanson The matter is called for hearing. Deadline All parties except for Yasha Bronshteyn appeared via LACourtConnect.

The Court finds that sufficient evidence has been provided to grant the matter on calendar this date based upon the reading of the moving papers and consideration of all presented evidence.

The Petition - Appoint Conservator of Estate Nom/Ap (Subsequent) filed on 8/31/2020 by Petitioner Britney Jean Spears is granted as follows:

The Court denies without prejudice the relief requested to suspend James P. Spears immediately upon the appointment of Bessemer Trust as sole Conservator of the Estate.

Minute Order Page 1 of 2 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES Probate Division Stanley Mosk Dept. - 4 BP108870 In re: SPEARS, BRITNEY JEAN - CONSERVATORSHIP November 10, 2020 1:30 PM The Court denies without prejudice the relief requested to direct James P. Spears, Tristar, and Michael Kane to deliver the entire Conservatorship Estate together with all books and records forthwith to Bessemer Trust as sole Conservator of the Estate.

The remainder of the relief requested is granted.

The Court orders the Conservator(s) to file an accounting no later than Tuesday, March 1, 2022. The Court sets an Order to Show Cause Hearing Re: Accounting on Friday, April 1, 2022 at 8:30 AM in this department.

Britney Spears is ordered to prepare the Order After Hearing.

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Minute Order Page 2 of 2 EXHIBIT A Deadline DECLARATION OF BESSEMER TRUST COMPANY OF CALIFORNIA, N.A.

ADJN I, Jeff J. Giowacki, declare:

1. I am a Managing Director at Bessemer Trust Company of California, N.A.

(“Bessemer”).

2. Unless indicated otherwise, I have personal knowledge of the matters set forth in

this if I \OOOQQUI declaration, and called upon to testify, could and would testify competently thereto.

3. Iwas contacted by Samuel D. Ingram, HI, the Court appointed counsel for

Britney Jean Spears (the “Conservatee”), who inquired whether Bessemer would be interested in

10 acting as Co-Conservator of the Estate.

11 4. I was told by the parties that the Conservatorship was an ongoing, voluntary

12 Conservatorship and am aware that the Conservatee had consented to Bessemer’s appointment.

13 5. On August 27, 2020, the Conservatee nominated Bessemer to act as Conservator

14 of her Estate.

15 6. Once the agreement of the parties that Bessemer should act as a Conservator of

16 the Estate was obtained, and in reliance thereon, Bessemer agreed to act.

17 7. The Court appointed Bessemer as Co-Conservator of the Estate on November 10,

18 2020. l9 8. I am informed that the Order was signed on June 30, 2021, but that Letters of 20 Conservatorship haveDeadlinenot been issued to Bessemer, and therefore Bessemer is not currently 21 authorized to act as Co-Conservator.

22 9. To date, although Bessemer was appointed on November 10, 2020, because

23 Bessemer does not have the legal authority to act, Bessemer has taken no actions as Co-

24 Conservator, has made no decisions as Co-Conservator, has received no assets of the Estate, and

25 has taken no fees.

26 10. As a result of the Conservatee’s testimony at the June 23, 2021 hearing, I became

27 aware that the Conservatee obj ects to the continuance of her Conservatorship and desires to

28 terminate the Conservatorship. I declare under penalty of perjury under the laws of the State of California that the

ADJN foregoing is true and correct.

Executed at Los Angeles, California A 0D! \ on , 2021.

Jeff J. Gl'owacki \OOOQQUI Managing Director

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-2- DECLARATION OF BESSEMER TRUST COMPANY OF CALIFORNIA, N.A. EXHIBIT A Deadline SAMUEL b> · iNGHAM s_tate .Bar #"66Z79 444 South Flowex suite 4260 · Los Angeles, California 9007),-2966

TeTephone: (310) 556-'9751 Fax: (310} SSfr-1311 E-4mail: [email protected]

·-.· ·-. ' court--,Appointed Counsel For BRITNEY JEAN SPEARS, Conservatee

SUPER!OR COURT OF THE ·

FOR >TltE COUNTY OF LOS ANG!!LES

In th.e Matter of the N.o. BP 108 870 Conservatorship of the Person and Estate of N0MIN.ATT0N - OF

JEAN. SPEARS,

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17 18 Conservatee. 19 BRITNEY JEAN -. SPEARS hereby nominates

COMPAN'.{ N .. A. - to -serve 1 Deadline EXHIBIT A Deadline Electronically FILED by Superior Court of California, County of Los Angeles 9/29/2020 1:36 PM Sherri R. Carter, Executive Officer/Clerk, By A. Malfavon, Deputy Clerk

1 SAMUEL D. INGHAM III State Bar ()66279 2 444 South Flower Street Suite 4260 3 Los Angeles, California 90071-2966 4 Telephone: (310) 556-9751 Fax: (310) 556-1311 5 E-mail: sam8inghamlaw.corn

6 Court-Appointed Counsel For BRITNEY JEAN SPEARS, Conservatee 7

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

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11 In the Matter of the No. BP 108 870 Conservatorship of the Person 12 and Estate of CONSENT TO ACT AS CONSERVATOR OF ESTATE

14 BR1TNEY JEAN SPEARS,

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17 Conservatee.

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20 BESSEMER TRUST COMPANY OF CALIFORNIA, N.A. hereby Deadline BRITNEY JEAN 21 consents to act as conservator of the estate of

22 SPEARS .

23 Dated: August 27, 2020

24 BESSEMER TRUST COMPANY OF CALIFORNIA, N.A. 25

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27 g~~ Cn&o~c.~ 28 ~CeEAQ Dike'cd~

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1 m664 v2 CONSENT TO ACT EXHIBIT A Deadline RESIGNATION OF CO-CONSERVATOR OF

THE ESTATE OF BRITNEY JEAN SPEARS

Bessemer Trust Company of California, N. A. hereby resigns as Co-Conservator of the

Estate of Britney Jean Spears effective upon approval of the Court.

BESSEMER TRUST COMPANY OF CALIFORNIA, N.A.

Date: <30 Di \. 10M By: mmy/d Jeff J. Glowacki Managing Director

Deadline

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