In re the Estate of Mabel R. Thornquist

CASE-FILE DOCUMENT · EXHIBIT 001 WILL 2024

Exhibit m10.exh.001 — Last Will and Testament of Mabel R. Thornquist

Reproduced for the case file. Original held with Ellingboe & Ravndal LLP; a self-proving affidavit is attached to the original.

LAST WILL AND TESTAMENT OF MABEL R. THORNQUIST

I, Mabel R. Thornquist, of Sable County, State of Meridian, being of sound mind, declare this to be my Last Will and Testament, and I revoke all prior wills and codicils.

ARTICLE I — Family. I am a widow. My late husband was Ferdinand Thornquist. I have two living children: my daughter, Eleanor Thornquist-Reddick, and my son, Ronald Thornquist.

ARTICLE II — Specific Devise of Real Property. I give my home and real property on Loon Rush Lake in Sable County, together with its furnishings and contents, to my daughter, Eleanor Thornquist-Reddick, if she survives me.

ARTICLE III — Cash Bequest. I give the sum of Twenty-Five Thousand Dollars ($25,000) to my son, Ronald Thornquist, if he survives me.

ARTICLE IV — Residue. I give all the rest and residue of my estate to my daughter, Eleanor Thornquist-Reddick, if she survives me; if she does not, then to my son, Ronald Thornquist.

ARTICLE V — Personal Representative. I nominate my daughter, Eleanor Thornquist-Reddick, to serve as personal representative of my estate, to serve without bond. If she is unable or unwilling to serve, I nominate my attorney's firm to designate a successor.

ARTICLE VI — Statement of Reasons. I have made this will after careful thought. My reasons for the disposition above are set out in a separate letter I have signed the same day as this will. I have provided for both of my children, though not equally, and I have done so deliberately.

I sign this will on October 18, 2024.

_/s/ Mabel R. Thornquist_ MABEL R. THORNQUIST

ATTESTATION. The foregoing instrument was signed by Mabel R. Thornquist as her Last Will and Testament in our presence, and we, at her request and in her presence and in the presence of each other, have signed as witnesses. She appeared to us to be of sound mind and under no constraint.

_/s/ Harriet Grenfell_ — Harriet Grenfell, Sable County, Meridian _/s/ Delia Fenwick_ — Delia Fenwick, Sable County, Meridian

[A self-proving affidavit, acknowledged before a Meridian notary public, is attached to the original instrument.]

CASE-FILE DOCUMENT · EXHIBIT 002 EXPLANATORY LETTER

Exhibit m10.exh.002 — Explanatory Letter of Mabel R. Thornquist

Signed the same day as the 2024 will and kept with it in the firm's file. Written in Mabel's voice at her request.

October 18, 2024

To my children, Eleanor and Ronald —

I am writing this so that no one has to guess what I wanted or why. I have just signed a new will, and I know it is not the same as the one I made years ago. I want to explain it in my own words.

I am leaving the lake house to Eleanor. I know this is a big thing and that it is not an even split. I have thought about it a long time and it is what I want.

Here is why. When I got sick and could not manage on my own, Eleanor left her own home and came to live with me. She has taken care of me every single day — my meals, my medicine, driving me everywhere, sitting up with me on the bad nights. She gave up a great deal to do it. The lake house is where she has done all of that, and it is where our family has been happiest. I want her to have it.

Ronald, I have not forgotten you, and I love you. Years ago I gave you sixty thousand dollars to help you start your business. I do not hold it against you that it did not work out — that is how business goes. But it was a real gift, and it is part of how I think about being fair to both of you. I am leaving you twenty-five thousand dollars, and I mean it as a gift with love, not as a slight.

I am doing this with a clear head and of my own free will. No one told me to. Eleanor did not ask me for the house. This is my decision about my own home, and I am at peace with it.

With love, _/s/ Mabel R. Thornquist_ Mabel

CASE-FILE DOCUMENT · EXHIBIT 003 PRIOR WILL 2015

Exhibit m10.exh.003 — Prior Last Will and Testament of Mabel R. Thornquist (2015)

The superseded will, offered for comparison. Revoked by the October 18, 2024 will.

LAST WILL AND TESTAMENT OF MABEL R. THORNQUIST

I, Mabel R. Thornquist, of Sable County, State of Meridian, declare this to be my Last Will and Testament, and I revoke all prior wills.

ARTICLE I — Family. My husband is Ferdinand Thornquist. I have two children: Eleanor Thornquist-Reddick and Ronald Thornquist.

ARTICLE II — Disposition. If my husband survives me, I give my entire estate to him. If he does not survive me, I give my entire estate, including my home on Loon Rush Lake, to my two children, Eleanor Thornquist-Reddick and Ronald Thornquist, in equal shares, share and share alike.

ARTICLE III — Personal Representative. I nominate my husband, Ferdinand Thornquist, as personal representative. If he cannot serve, I nominate my two children to serve together.

I sign this will on May 12, 2015.

_/s/ Mabel R. Thornquist_ MABEL R. THORNQUIST

Witnessed and notarized. Ferdinand Thornquist predeceased the testator in 2017.

Note for the file: Under this earlier instrument the estate — including the lake home — would have passed to Eleanor and Ronald in equal shares. The 2024 will changed that disposition. The contrast between the two instruments is central to the contest.

CASE-FILE DOCUMENT · EXHIBIT 004 DRAFTING MEMO

Exhibit m10.exh.004 — Drafting Attorney's File Memorandum

Contemporaneous memorandum to the file by the drafting attorney. Part of the estate-planning file the estate now relies on to defend the will.

MEMORANDUM TO FILE Re: Mabel R. Thornquist — new will and explanatory letter By: Amara Ellingboe Date: October 18, 2024

Documenting today's execution and my earlier meeting with the client, given her age and health.

Initial meeting (September). Ms. Thornquist's daughter, Eleanor, first contacted the office and set up the appointment. When Ms. Thornquist came in, I asked Eleanor to remain in the reception area, and I met with Ms. Thornquist alone. I do this as a matter of course where a family caregiver stands to benefit, and I made a point of it here.

Meeting alone, I asked Ms. Thornquist to tell me in her own words what she owned and what she wanted to do. She described the lake home, her accounts, and her belongings. She said she wanted her daughter Eleanor to have the lake home because Eleanor had left her own home to care for her. She said her son Ronald had already received a substantial gift years earlier for a business, and that she wanted to leave him a smaller cash amount. She was clear and consistent on these points. She lost the thread on a couple of unrelated, recent-events questions, but on her property, her family, and her wishes she was steady.

Capacity precautions. Because of her diagnosis, I asked that her physician see her near the time of signing, which he did on October 4. I also arranged for a disinterested attesting witness — her friend Harriet Grenfell — in addition to our paralegal, and for a self-proving affidavit before a notary.

Execution (today). Ms. Thornquist reviewed the will and the explanatory letter with me. Eleanor again waited outside. In the presence of both witnesses I asked Ms. Thornquist whether this was her will and whether it reflected her wishes; she said yes and stated she wanted Eleanor to have the lake home. She signed; the witnesses signed; the affidavit was notarized. She appeared to understand what she was doing and to be acting freely.

Note on my role. If this will is ever contested, I am a likely witness on the client's capacity and the absence of undue influence, and the firm will need to weigh that in deciding how to handle any contest.

_/s/ Amara Ellingboe_

CASE-FILE DOCUMENT · EXHIBIT 005 CAPACITY LETTER

Exhibit m10.exh.005 — Clinic Note and Capacity Letter of Dr. Theodore Brashear

Excerpt of the clinic note from the October 4, 2024 visit, with a short letter prepared afterward at the family's request. Kept in the estate-planning file.

BRIGHTWATER FAMILY MEDICINE Patient: Mabel R. Thornquist Visit date: October 4, 2024 Provider: Theodore Brashear, M.D.

Clinic note (excerpt).

• Patient seen for cognitive assessment ahead of updating legal documents, per family request.
• History: early-stage vascular-type cognitive impairment, followed since early 2024. Fall in February 2024.
• Orientation: knows name, location, approximate date.
• Fund of knowledge / assets: able to describe her home on Loon Rush Lake, bank accounts, and personal property in general terms.
• Family: identifies two children by name — daughter Eleanor and son Ronald.
• Understanding of task: states a will directs who receives one's property after death; states intent to make one.
• Deficits: impaired short-term recall of recent day-to-day events; repeats some questions. Long-term and family memory intact.
• Mood/affect: pleasant, cooperative, non-delusional. No overt distress or fear observed.

Letter.

October 4, 2024

To whom it may concern:

I examined my patient, Mabel R. Thornquist, today. She carries a diagnosis of early-stage cognitive impairment. Based on today's examination, it is my opinion that she understands the general nature and extent of her property, knows the identity of her children, and understands what a will is and does. Her difficulties are with recent, short-term recollection; her understanding of her property, her family, and her intentions was intact today.

I express no opinion on the terms of any document she may sign, and I did not observe the circumstances under which any document would be executed.

_/s/ Theodore Brashear, M.D._

CASE-FILE DOCUMENT · EXHIBIT 006 OBJECTION PETITION

Exhibit m10.exh.006 — Objection and Petition to Contest Will

Filed by the contestant. Reproduced in factual summary for the case file; procedural posture only, no argument of law.

STATE OF MERIDIAN DISTRICT COURT — PROBATE DIVISION COUNTY OF SABLE

In re the Estate of Mabel R. Thornquist, Deceased.

OBJECTION AND PETITION TO CONTEST WILL

Ronald Thornquist, son of the decedent and an heir, objects to the will admitted to probate on August 11, 2025, and petitions to set it aside. In support, he states:

1. The decedent, Mabel R. Thornquist, died on June 22, 2025, a resident of Sable County.

1. The decedent's son, Ronald Thornquist, and daughter, Eleanor Thornquist-Reddick, are her only children and heirs.

1. The instrument admitted to probate is dated October 18, 2024. It leaves the decedent's Loon Rush Lake home and the residue of the estate to Eleanor Thornquist-Reddick, names her personal representative, and leaves the contestant a cash bequest of $25,000.

1. The decedent's earlier will, dated May 12, 2015, left her estate to her two children in equal shares.

1. First ground — lack of testamentary capacity. The contestant alleges that at the time she signed the 2024 will, the decedent did not understand the nature of her property, the natural objects of her bounty, or the effect of the instrument, by reason of her cognitive decline.

1. Second ground — undue influence. The contestant alleges that Eleanor Thornquist-Reddick, who lived with and cared for the decedent, held her financial power of attorney, controlled access to her, and stood to benefit, procured the 2024 will through undue influence.

1. The contestant asks the court to set aside the 2024 will and to admit the 2015 will, or to distribute the estate as if the decedent left no valid will.

WHEREFORE, the contestant prays for relief as stated.

Filed September 15, 2025. Ronald Thornquist, by counsel, Placidia Ohnstad, Esq.

CASE-FILE DOCUMENT · EXHIBIT 007 ASSET SUMMARY

Exhibit m10.exh.007 — Estate Asset and Account Summary

Prepared by the personal representative for the estate file. Figures are approximate and reflect date-of-death values.

Estate of Mabel R. Thornquist — Asset Summary

Account activity notes (2024–2025)

• Eleanor Thornquist-Reddick held the decedent's financial power of attorney from April 2024.
• Eleanor was added as a joint signer on the checking account in 2024 to pay the decedent's bills.
• Between 2024 and 2025, approximately $8,000 was withdrawn from the decedent's accounts and applied to care expenses and reimbursements to Eleanor. Documentation for a portion of these withdrawals is incomplete.

Distribution under the contested 2024 will

• Loon Rush Lake home and residue → Eleanor Thornquist-Reddick
• Cash bequest of $25,000 → Ronald Thornquist

Distribution under the prior 2015 will

• Entire estate, including the lake home → Eleanor and Ronald in equal shares

WITNESS STATEMENT · WITNESS GRENFELL

Witness Statement — Harriet Grenfell

Witness: Harriet Grenfell Relationship to decedent: Longtime friend and neighbor; attesting witness to the will Date of statement: October 2, 2025 Taken at: Brightwater, Sable County, Meridian

My name is Harriet Grenfell. I am seventy-one years old and I live two doors down the shore road from the Thornquist place on Loon Rush Lake. Mabel and I were friends for the better part of thirty years. We took our coffee together most weeks, and after Ferdinand passed I looked in on her often.

I am one of the two people who watched Mabel sign her will. I want to say plainly that I was asked to be a witness, I said yes, and I went to the lawyer's office in the middle of October last year. The other witness was a young woman who worked at the firm. A lawyer, Ms. Ellingboe, ran the whole thing.

Here is what I remember. It was afternoon. Eleanor drove her mother and me over, but Eleanor did not come into the room where we did the signing. It was Mabel, Ms. Ellingboe, the young woman from the office, and me. Ms. Ellingboe asked Mabel, in front of us, whether this was her will and whether she wanted us to witness it. Mabel said yes, this was her will, and she said — I remember this clearly — that she wanted Eleanor to have the lake house. She said it like it was the most obvious thing in the world.

I will be honest about the part that troubles some people. Mabel did seem tired that afternoon. She was slower than she used to be, and once or twice she lost her place in a sentence. That was not new by then; that was Mabel in her last year. But tired is not the same as confused, and on the thing that mattered — whose house it was and where she wanted it to go — she was not confused at all. She knew it was her house. She knew Eleanor and Ronald were her children. She knew what she was signing.

People have asked me whether Eleanor pushed her into it. I can only tell you what I saw, and what I saw was that Eleanor was not in the room. Mabel signed, then the young woman signed, then I signed, and there was a notary who stamped it. Mabel thanked us both. On the way home she told me she felt good about having it done.

I was fond of Mabel and I have no stake in this fight between her children. I am telling you what I saw because she asked me to be her witness, and I take that seriously.

/s/ Harriet Grenfell

WITNESS STATEMENT · WITNESS BRASHEAR

Witness Statement — Dr. Theodore Brashear

Witness: Theodore Brashear, M.D. Role: Mabel Thornquist's treating physician (family medicine) Date of statement: October 9, 2025 Taken at: Brightwater Family Medicine, Sable County, Meridian

I am Dr. Theodore Brashear. I have practiced family medicine in Sable County for twenty-six years. Mabel Thornquist was my patient for more than a decade, until her death in June of last year.

Beginning in early 2024, I followed Mabel for cognitive changes. She had a fall at home in February, and over that winter and spring her family and I noticed she was becoming forgetful — misplacing things, repeating questions, losing track of recent conversations. I diagnosed her with an early-stage, vascular-type cognitive impairment. I want to be careful about what that means. It is a real diagnosis, and it explains the memory lapses. It does not, by itself, mean a person cannot understand her own affairs.

On October 4, 2024, Mabel came in for an appointment. Her daughter had told me the family wanted her seen around that time because Mabel was going to update some legal documents, and I made a point of assessing her orientation and understanding at that visit. My notes from that day, which I have reviewed, record the following. Mabel knew who she was, where she was, and roughly the date. She could describe her property in general terms — the lake home, her accounts, her belongings. She knew she had two children, a daughter and a son, and she named them. She understood that a will is a document that says who gets your things after you die, and she told me she intended to make one that afternoon or soon after.

What Mabel did not have was a reliable memory for recent, day-to-day events — what she had eaten, who had visited that week, small things like that. That is consistent with her diagnosis. But her memory for long-standing matters — her family, her home, the shape of her life — was intact at that visit.

I have been asked whether, in my medical opinion, Mabel understood what she was doing when she made a will around that time. Based on my examination of her on October 4, she understood the general nature and extent of her property, she knew who her children were, and she understood what a will does. I did not observe her to be delusional, and I did not see any sign that she was being coerced, though I would not necessarily have seen that in an office visit.

I offer this as her physician, from my own records and recollection. I am not taking a side between her children.

/s/ Theodore Brashear, M.D.

WITNESS STATEMENT · WITNESS SUNDBERG

Witness Statement — Lorna Sundberg

Witness: Lorna Sundberg Role: Home health aide for Mabel Thornquist Date of statement: October 6, 2025 Taken at: Brightwater, Sable County, Meridian

My name is Lorna Sundberg. I am thirty-four and I work as a home health aide. I was assigned to Mabel Thornquist starting in the spring of 2024, and I worked weekday afternoons at the lake house through the rest of that year and into 2025, until close to the end.

My job was to help Mabel with her afternoons — a light meal, her medications, keeping her comfortable and company. I was fond of her. She liked to sit by the window and watch the lake.

If you ask me how she was, the honest answer is that it went up and down. Some afternoons Mabel was clear and funny and knew exactly what was going on. Other afternoons she was foggy — she'd ask me the same question a few times, or she wouldn't be sure what day it was. Her best time was usually the morning; by late afternoon she'd tire and get more confused. I wasn't there in the mornings, so I only saw her at her more tired time of day.

Eleanor was there constantly. I want to be fair about that. Whatever anyone says, I never saw Eleanor be rough or unkind to her mother. She was patient with her. She did the hard, unglamorous work of taking care of someone who is slipping — the meals, the medicine, the cleaning up. I saw that with my own eyes, day after day.

There is one thing I have gone back and forth about mentioning, because I don't want it taken the wrong way. One afternoon, Eleanor was frustrated — tired, I think — and I heard her say to Mabel something like, "Ronald doesn't care about you." Mabel just nodded. I don't know what to make of it. People say things when they're worn out. But I heard it, and I don't want to pretend I didn't.

I'll also say I'm uneasy being in the middle of this. Eleanor is the one who arranged for me to be paid, and I know someone could say that makes me biased toward her. That's part of why I've tried to just say what I actually saw and not more.

I was not at the lawyer's office the day Mabel signed her will. I have no idea how she was that day. I can only speak to the afternoons I was there.

/s/ Lorna Sundberg

BUSINESS EXHIBIT · ENGAGEMENT LETTER

Engagement Letter — Estate-Planning (Flat Fee)

Ellingboe & Ravndal LLP 310 Riverwalk Plaza, Suite 400 Norsholm, Meridian 55901

September 16, 2024

Mabel R. Thornquist 14 Shoreline Road (c/o Eleanor Thornquist-Reddick) Brightwater, Meridian 56021

Re: Preparation of your will and explanatory letter

Dear Ms. Thornquist:

Thank you for asking our firm to prepare your new will. This letter sets out the terms of our work so we both understand the scope and the fee.

Scope of work. We will prepare a new last will and testament for you, together with a companion letter, in your voice, explaining the reasons for your choices. Our work includes meeting with you to confirm your wishes, drafting the documents, arranging for your physician to assess you near the time of signing, arranging disinterested witnesses, and supervising the signing with a self-proving affidavit before a notary. This engagement does not include any other estate-planning documents unless we agree separately in writing.

Flat fee. Our fee for this work is a flat fee of $1,800, due on completion of the signing. This is a fixed price for the scope above; it does not change with the hours we spend. We track our time for our own management, but you are billed the flat fee, not by the hour. Any out-of-pocket costs (such as a notary or recording fee) would be billed separately, and we do not expect any of significance here.

Meeting with you alone. Because your daughter is helping with your care and is one of the people who may benefit under your will, we will meet with you privately, without her in the room, to confirm that the decisions are yours. This is our normal practice and protects you and your will.

If your will is later questioned. You should know that because we are drafting and supervising your will, our attorney could later be a witness if anyone ever challenges it. If that happened, we would discuss with your family how best to handle it, which might include another lawyer.

Client decisions. The terms of your will are entirely your decision. We advise; you decide.

If these terms are agreeable, please sign below. We are glad to help.

Sincerely,

Amara Ellingboe Ellingboe & Ravndal LLP

Agreed and accepted:

_/s/ Mabel R. Thornquist_ — Mabel R. Thornquist — Date: September 16, 2024

BUSINESS EXHIBIT · INTAKE & CONFLICTS

Intake (2024-09-16). Flat-fee estate planning for Mabel R. Thornquist — a new will and explanatory letter (2024) — and defense of the resulting will against a contest brought by the decedent's son alleging lack of capacity and undue influence.

Conflicts check (2024-09-16) — CLEAR. No adverse-client conflict identified at intake. Flagged for the file: because the firm drafted and supervised execution of the will, the drafting attorney is a potential witness if the will is later contested; the advocate-witness question is to be revisited at that time.

BUSINESS EXHIBIT · BILLING STATEMENT (10 TIME ENTRIES)

BUSINESS EXHIBIT · INVOICES