Contract analysis

I. INTRODUCTION AND PRELIMINARY STATEMENT Marguerite Delphine Fonseca ("Petitioner"), the surviving spouse of Teodoro Raúl Fonseca ("Decedent"), by and through her attorneys of record, Calderwood & Harkness LLP, respectfully petitions this Honorable Court, pursuant to California Probate Code sections 8000 et seq. and sections 8460 through 8469, for the issuance of Letters of Administration appointing Petitioner as th

1. At the time of his death on September 3, 2022, Decedent was domiciled in Los Angeles County, California, where he had continuously resided for more than twenty (20) years. Decedent's primary residence was located at 1847 Coldwater Canyon Drive, Beverly Hills, California 90210, which address is within the territorial boundaries of Los Angeles County.

2. This Court has jurisdiction over this proceeding pursuant to California Probate Code sections 7050 through 7052, which vest the Superior Court with jurisdiction over proceedings concerning the estates of decedents, including the granting of letters of administration.

3. Venue is proper in the Superior Court for the County of Los Angeles pursuant to California Probate Code section 7051, which provides that proceedings for the administration of the estate of a decedent shall be commenced in the county in which the decedent was domiciled at the time of death. As set forth above, Decedent was domiciled in Los Angeles County at the time of his death, and accordingly, this Court is the

4. No other petition for the probate of a will or for letters of administration concerning the Estate of Teodoro R. Fonseca has been filed in this Court or, to the best of Petitioner's knowledge, in any other court.

III. INFORMATION CONCERNING THE DECEDENT A. Personal Information

5. Decedent's full legal name was Teodoro Raúl Fonseca. He was also known informally as "Teo Fonseca" in professional and social contexts, though all legal documents and records reflected his full legal name as stated herein.

6. Decedent died on September 3, 2022. The cause of death was cardiac arrest, which was determined to be from natural causes. No autopsy was required, and the manner of death was certified as natural by the attending physician.

7. Decedent was sixty-two (62) years of age at the time of his death, having been born on January 11, 1960.

8. Decedent's last known address, and his primary residence at the time of his death, was 1847 Coldwater Canyon Drive, Beverly Hills, California 90210.

9. Decedent was a film producer and media entrepreneur by profession. Over the course of his career, Decedent was involved in the production and financing of numerous motion pictures and television series. At the time of his death, Decedent served as the Chief Executive Officer and Managing Member of Lumiére Canyon Studios LLC, a California limited liability company he co-founded with Petitioner in 2009, and held a s

10. Decedent was first married to Claudette Marchetti (née Marchetti) in 1988. That marriage was dissolved by final judgment of dissolution entered in 2005 by the Superior Court of California, County of Los Angeles. Pursuant to the judgment of dissolution and related settlement agreements, Ms. Marchetti received a divorce settlement in the amount of Four Million Eight Hundred Thousand Dollars ($4,800,000.00) and a su

11. Decedent married Petitioner, Marguerite Delphine Fonseca (née Marguerite Delphine Roux), on June 14, 2008, in Los Angeles County, California. It was Petitioner's first marriage and Decedent's second marriage. A certified copy of the Marriage Certificate of Teodoro R. Fonseca and Marguerite D. Fonseca is attached hereto as Exhibit B and incorporated herein by this reference.

12. Decedent and Petitioner remained married continuously from June 14, 2008, until the date of Decedent's death on September 3, 2022, a period of approximately fourteen (14) years. At no time during the marriage did either party file for legal separation or dissolution. The marriage remained intact and in good standing throughout its entirety. C. Intestacy.

13. Despite diligent search and inquiry, no valid last will and testament, codicil, trust instrument, or any other testamentary document executed by Decedent has been located. Petitioner avers that Decedent died intestate within the meaning of California Probate Code section 6400.

14. The diligent search undertaken by Petitioner has included, but has not been limited to, the following: (a) A thorough search of Decedent's primary residence at 1847 Coldwater Canyon Drive, Beverly Hills, California 90210, including all personal files, home office records, storage areas, and personal effects; (b) A thorough search of Decedent's office at Lumiére Canyon Studios LLC, located at 4200 West Olive Avenu

15. The foregoing search has produced no evidence whatsoever that Decedent executed any testamentary instrument at any time during his lifetime. Petitioner's Declaration Regarding Diligent Search for Testamentary Instruments, attached hereto as Exhibit D, sets forth the details and results of this search under penalty of perjury.

IV. IDENTIFICATION OF HEIRS AT LAW Petitioner identifies the following persons as the heirs at law of Decedent, entitled to distribution of the Estate under the laws of intestate succession as set forth in California Probate Code sections 6400 through 6414: A. Surviving Spouse

16. Marguerite Delphine Fonseca, age 54, residing at 1847 Coldwater Canyon Drive, Beverly Hills, California 90210. Petitioner is the surviving spouse of Decedent, having been married to Decedent on June 14, 2008, and having remained married to Decedent continuously until his death on September 3, 2022. In addition to her role as surviving spouse, Petitioner serves as the Chief Creative Officer of Lumiére Canyon Studi

17. Rafael Teodoro Fonseca, age 33, residing at 502 Olive Avenue, Unit 3, Burbank, California 91502. Rafael is the eldest child of Decedent, born during Decedent's first marriage to Claudette Marchetti. He is currently employed as the Vice President of Development at Crestline Media Group Inc. Rafael is an adult and is competent.

18. Isabela Claudette Fonseca-Greer, age 30, residing at 78 Eucalyptus Lane, Santa Monica, California 90402. Isabela is the middle child of Decedent, born during Decedent's first marriage to Claudette Marchetti. She is married to Connor Greer and is a documentary filmmaker, currently serving as the principal of Amber Light Documentary Films LLC. Isabela is an adult and is competent.

19. Nicolás Raúl Fonseca, age 26, residing at 1190 Elm Street, Apt. 4B, Palo Alto, California 94301. Nicolás is the youngest child of Decedent, born during Decedent's first marriage to Claudette Marchetti. He is currently a graduate student residing in Northern California. Nicolás is an adult and is competent. C. No Other Heirs

20. To the best of Petitioner's knowledge and belief, the foregoing persons — Marguerite D. Fonseca (surviving spouse), Rafael T. Fonseca, Isabela C. Fonseca-Greer, and Nicolás R. Fonseca (children) — constitute all of the heirs at law of Decedent.

21. Decedent had no other children, whether natural or adopted, whether born during his marriages or otherwise, other than the three children identified above.

22. No other persons are known to Petitioner to have claims as heirs of Decedent under the provisions of California Probate Code sections 6400 through 6414, and Petitioner is not aware of any other individuals who would take a share of the Estate by intestate succession.

V. DESCRIPTION OF ESTATE ASSETS The following is a description of the known assets of the Estate, together with their estimated values as of the date of Decedent's death or, where noted, as of the most recent valuation available to Petitioner. A preliminary inventory of estate assets is attached hereto as Exhibit C. Petitioner reserves the right to amend or supplement this description as additional information become

23. Property Address: 1847 Coldwater Canyon Drive, Beverly Hills, California 90210.

24. Description: The property is a single-family residence that served as the marital home of Decedent and Petitioner throughout their marriage. The residence includes the primary dwelling and associated grounds, improvements, and fixtures.

25. Estimated Fair Market Value: Eight Million Four Hundred Fifty Thousand Dollars ($8,450,000.00), based on preliminary comparable market analysis. A formal appraisal will be obtained during the course of administration.

26. Character of Property: Petitioner contends that this property is community property of Decedent and Petitioner, having been acquired and maintained during the course of their marriage with community funds and resources. The property was purchased during the marriage, and title was held jointly by Decedent and Petitioner.

27. Property Address: 27100 Pacific Coast Highway, Malibu, California 90265.

28. Description: The property is a beach-front residential property located along the Pacific Coast Highway in Malibu, California.

29. Date of Purchase: August 22, 2007, which was prior to the marriage of Decedent and Petitioner.

30. Original Purchase Price: Four Million Seven Hundred Fifty Thousand Dollars ($4,750,000.00).

31. Estimated Current Fair Market Value: Six Million Two Hundred Thousand Dollars ($6,200,000.00), based on preliminary comparable market analysis. A formal appraisal will be obtained during the course of administration.

32. Community Contributions: Although the property was acquired prior to the marriage, community funds contributed significantly to the property during the marriage. Specifically, community funds were used to finance a major renovation of the property completed in 2016 at a cost of approximately One Million Eight Hundred Thousand Dollars ($1,800,000.00), and community funds were used to make approximately One Hundred

33. Title Records: Title records for this property are maintained by Coastline Title & Escrow Co., 9401 Wilshire Boulevard, Suite 720, Beverly Hills, California 90212. The contact person at Coastline Title & Escrow Co. is Andrea Solis.

34. Character of Property: While the property was initially acquired by Decedent as his separate property prior to the marriage, Petitioner contends that she and the community have a community property interest in this property proportional to the community contributions made during the marriage, including the renovation expenditures and mortgage payments described above, pursuant to the principles set forth in In re

1. Lumiére Canyon Studios LLC.

35. Entity Type: California limited liability company, California Secretary of State Filing Number 200906410337.

36. Date of Formation: March 18, 2009, during the marriage of Decedent and Petitioner.

37. Principal Office: 4200 West Olive Avenue, Burbank, California 91505.

38. Co-Founders: Decedent and Petitioner co-founded this entity.

39. Decedent's Membership Interest: Decedent held a fifty percent (50%) membership interest in Lumiére Canyon Studios LLC, as set forth in the Operating Agreement dated March 18, 2009.

40. Petitioner's Membership Interest: Petitioner holds the remaining fifty percent (50%) membership interest in Lumiére Canyon Studios LLC.

41. Valuation: The most recent internal valuation of Lumiére Canyon Studios LLC, conducted as of December 31, 2021, placed the enterprise value of the company at approximately Thirty-One Million Six Hundred Thousand Dollars ($31,600,000.00). Based on this valuation, the estimated value of Decedent's fifty percent (50%) membership interest is approximately Fifteen Million Eight Hundred Thousand Dollars ($15,800,000.00

42. Business Operations: Lumiére Canyon Studios LLC is engaged in film and television production. The company's intellectual property portfolio spans fourteen (14) feature films and six (6) television series. The company maintains ongoing production, distribution, and licensing activities.

43. Character of Property: Petitioner contends that Decedent's membership interest in Lumiére Canyon Studios LLC is community property, as the entity was formed during the marriage of Decedent and Petitioner, and the business was developed and operated using community labor, skill, and resources.

2. Pacific Rim Narrative Partners LLC.

44. Entity Type: California limited liability company, California Secretary of State Filing Number 201518720492.

45. Date of Formation: 2015, during the marriage of Decedent and Petitioner.

46. Principal Office: 8455 Beverly Boulevard, Suite 310, Los Angeles, California 90048.

47. Managing Member: Victor Sandoval serves as the managing member of Pacific Rim Narrative Partners LLC.

48. Decedent's Membership Interest: Decedent held a thirty-five percent (35%) membership interest in Pacific Rim Narrative Partners LLC.

49. Assets Under Management: The fund manages assets totaling approximately Seventy-Eight Million Five Hundred Thousand Dollars ($78,500,000.00).

50. Estimated Value of Decedent's Interest: Based on the assets under management, the estimated value of Decedent's thirty-five percent (35%) membership interest is approximately Twenty-Seven Million Four Hundred Seventy-Five Thousand Dollars ($27,475,000.00). Petitioner acknowledges that the actual fair market value of this interest may differ and will need to be determined through a formal, independent valuation du

51. Business Operations: Pacific Rim Narrative Partners LLC operates as a media investment vehicle, investing in content creation, production, distribution, and related media ventures.