Received: 10/27/2023 8:47 AM

Electronically FILED by
Superior Court of California,
Justin B. Gold (SBN: 227648) County of Los Angeles
OLDMAN, SALLUS & GOLD, LLP
1 10/27/2023 8:47 AM
David W. Slayton,
2 16133 Ventura Boulevard, Penthouse Executive Officer/Clerk of Court,
Encino, CA 91436 By R. Servando, Deputy Clerk
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Telephone: (818) 986-8080
Facsimile : (818) 789-0947
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Email: [email protected]
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Attorneys for Riley Keough, Trustee
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES
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In re The Matter of: Case No. 23STPB06405
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[Assigned for all purposes to the Hon. Lynn
12 H. Scaduto, Judge presiding]
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LISA'S IRREVOCABLE TRUST
EX PARTE PETITION FOR
14 APPROVAL OF SETTLEMENT
AGREEMENT; DECLARATION OF
15 JUSTIN B. GOLD
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17 Date: October 30, 2023

Time: 8:30 a.m.
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Dept: 79/Room 260
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1

EX PARTE PETITION FOR APPROVAL OF SETTLEMENT AGREEMENT

 Danielle Riley Keough ("Riley") is now the sole Trustee of the Lisa's Irrevocable Trust,
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2 and she hereby petitions this Court for an Order approving a settlement agreement, as modified

3 on October 26, 2023, and alleges as follows:

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INTRODUCTION
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This ex parte Petition is filed with the support and signature of every interested party in
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Lisa's Irrevocable Trust, and, as a result of a calendaring error on the original Petition that was

8 filed on June 14, 2023. That June 14, 2023 Petition was originally set for hearing on September

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5, 2023, but the Court did not have the Petition on calendar, and agreed to set the Petition for
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hearing on October 9, 2023. At the October 9, 2023 hearing the Petition was again not on
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calendar, and the Clerk informed Petitioner's counsel that it would be acceptable to present this
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13 Petition for approval on an ex parte basis.

14 This Petition is identical to the Petition that was previously filed in this matter, and
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already approved in the Promenade Trust matter (Los Angeles Superior Court case number
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23STPB00893), with one notable exception: Per an amendment to the Settlement agreement
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signed by all interested parties on October 26, 2023, Priscilla Presley will no longer be the Trustee
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19 of Navarone's sub-trust created under Lisa's Irrevocable Trust. Instead, that role will be filled by

20 attorney Martin Singer.

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This relief is sought on an ex parte basis because the settlement was executed months
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ago, and in order to fulfill the settlement, this Order must be approved. Administration and
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distributions are delayed pending approval of this Petition.
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25 FACTUAL ALLEGATIONS
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2
EX PARTE PETITION FOR APPROVAL OF SETTLEMENT AGREEMENT
 l. On October 6, 1993, Lisa Marie Presley ("Lisa") executed an Irrevocable Life
1

2 Insurance Trust known as "Lisa Irrevocable Trust" ("Trust"). A true and correct copy of the Trust

3 is attached hereto as Exhibit 1 and incorporated herein by this reference.

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2. Under the terms of the Trust, the initial Trustees were Priscilla Presley and
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National Bank of Commerce.
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3. On July 30, 2007, Priscilla Presley ("Priscilla") removed National Bank of

8 Commerce as Co-Trustee and appointed City National Bank as Co-Trustee. A true and correct

copy of the documentation appointing City National Bank as National Bank of Commerce's
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Successor is attached hereto as Exhibit 2.
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4. On September 12, 2022, City National Bank resigned as Co-Trustee, leaving only
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13 Priscilla Presley and Barry Siegel as Co-Trustees. A true and correct copy of City National

14 Bank's resignation is attached hereto as Exhibit 3.

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5. Lisa passed away on January 12, 2023.
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6. Lisa was survived by three children Riley, Harper Lockwood ("Harper"), and
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Finley Lockwood ("Finley"). Harper and Finley are currently minors.

19 7. On January 26, 2023, Priscilla filed a Petition in the Promenade Trust, which was

20 Lisa's Revocable Trust, Los Angeles Superior Court case number 23STPB00893 seeking to
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invalidate an Amendment which replaced her as Trustee on March 11, 2016 ("Priscilla's
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Petition").
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8. Michael Lockwood is the father of Harper and Finley, and he was appointed as
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25 Guardian Ad Litem for them in Los Angeles Superior Court case number 23STPB00893. Mr.

26 Lockwood will similarly apply to be Guardian Ad Litem for Harper and Finley in this matter.
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3

EX PARTE PETITION FOR APPROVAL OF SETTLEMENT AGREEMENT

 9. On January 26, 2023, Barry Siegel tendered his resignation as Co-Trustee of the
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2 Irrevocable Trust. A true and correct copy of that resignation is attached hereto as Exhibit 4.
3 10. Pursuant to Article XII(A)(5) of the Trust, Riley automatically became a Co-

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Trustee upon the death of her mother.
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11. Prior to May 11, 2023, the Trustees of the Trust were Priscilla and Riley.
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12. The Trust owned a large life insurance policy at the time of Lisa's death, but never
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8 had any other assets until Lisa's death. As a result of Lisa's death, the Trust is now entitled to the
9 of the life insurance.
proceeds
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13. The beneficiaries of the Trust are as follows: Lisa's half-brother Navarone
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Garibaldi (1/9 of the Trust, and subject to a separate sub-trust), and Riley, Harper, and Finley
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13 equally split the remaining 8/9's of the Trust. See Article VI of the Trust.

14 14. As a result of Priscilla's Petition and other related disputes that arose, Priscilla,

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Riley, and the Guardian Ad Litem entered into settlement discussion to resolve these various
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issues that impacted not only the Promenade Trust, but this Life Insurance Trust.
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15. On May 11, 2023, the parties entered into a settlement agreement that, with the
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19 exception of Priscilla's immediate resignation in exchange for $50,000, is subject to Court

20 approval. A true and correct copy of the settlement agreement is attached hereto as Exhibit 5.
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16. Pursuant to Section 4(a) of the Settlement, Priscilla immediately resigned as Co-
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Trustee of Lisa's Irrevocable Trust upon her signature on the settlement agreement. Priscilla did
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in fact sign the settlement agreement, and therefore, as of May 11, 2023, Riley became the sole
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25 Trustee of Lisa's Irrevocable Trust.

26 17. Absent the settlement agreement being signed, litigation was likely to occur
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related to Priscilla's role as Co-Trustee of Lisa's Irrevocable Trust, the trustee fee Priscilla
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4
EX PARTE PETITION FOR APPROVAL OF SETTLEMENT AGREEMENT
 intended to charge, and such litigation would have slowed, if not halted, the collection of the life
1

2 insurance proceeds.

3 18. Riley and the Guardian Ad Litem insisted upon Court Approval of the Settlement
4
Agreement because Harper and Finley are represented by a Guardian Ad Litem and his authority
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to enter into a settlement agreement on behalf of the minors is only valid to the extent the Court
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7 approves it.

8 19. At the request of Navarone and Priscilla, the Parties entered into an Amendment

9 to the Settlement Agreement on October 26, 2023 to have attorney Martin singer serve as Trustee
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of Navarone's sub-trust. A true and correct copy of the fully executed amendment to the
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settlement is attached hereto as Exhibit 6.
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13 20. The Settlement terms, as it pertains to Lisa's Irrevocable Trust, are as follows:

14 a $1 million will be paid off the top of Lisa's Irrevocable Trust (so borne
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proportionately by all beneficiaries, including Riley and Navarone) to Priscilla; and
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b Priscilla resigns as Trustee effective upon signature, and regardless of
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whether the settlement is approved or not;
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19 21. The settlement should also not be reviewed in a vacuum, separate and apart from

20 the benefits of settling the lawsuit filed on January 26, 2023 by Priscilla in the Promenade Trust.
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In settling the claims pending in Priscilla's Petition, the parties are saving significant legal fees
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by avoiding litigation, and they are likewise avoiding the spectacle of intra-family litigation that
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would have been inimical to Lisa's wishes and not in the best interests of the family.
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25 22. Riley and the Guardian Ad Litem are informed and believe that the settlement is
26 in the best interests of the Trust and the family, and therefore should be approved by the Court
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for the following reasons:
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5

EX PARTE PETITION FOR APPROVAL OF SETTLEMENT AGREEMENT

 a. The Settlement avoids litigation costs that would have been incurred by
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2 both Trustees!;

3 b. The settlement provides that Riley is the sole Trustee of the sub-trusts for
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herself and her sisters, and because she does not intend to charge any compensation for her
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services as Trustee;
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c. Now that Riley is the sole Trustee, the money will be safeguarded and
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8 invested in a manner consistent with the needs of the beneficiaries, and not influenced by the

9 desires of a Trustee"; and

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d. The settlement allows a trusted advisor, Attorney Martin Singer, to serve
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as Trustee for her son Navarone's sub-trust.
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23. Riley is informed and believes that the payments out of the Trust are small

14 compared (i) the value of the Trust, (ii) the substantial legal fees that litigation would have
15 of having Riley serve as sole Trustee.
incurred, and (iii) the benefits
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24. To that end, and to avoid any future issues with third parties, Riley also requests
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that this Court confirm that she is the sole Trustee of the Trust. This request is made given the
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and the various
19 history of the Trust and the multiple Co-Trustees that have served over the years,

20 wants to have a Court

resignations that have occurred over the last year. In sum, Riley simply
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Order she can deliver to third parties, such as the life insurance company, as appropriate, to
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Given the amount of legal fees claimed by Priscilla related to this litigation, as indicated in Paragraph 9 of the
Agreement, the litigation expenses could have become quite onerous.
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2To the extent that the Court has any questions about this, given the settlement agreement, Petitioner would
28 be happy to provide more context to this, in chambers.
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EX PARTE PETITION FOR APPROVAL OF SETTLEMENT AGREEMENT
 1
clarify that she is the sole trustee and avoid unnecessary delays associated with third parties

2 needing to determine who the trustee is.

3 25. The parties interested in this proceeding are identified in the attached Exhibit 7.
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26. The principal place of her administration of this Trust is in Los Angeles County,
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and jurisdiction and venue is therefore proper in Los Angeles County.
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7 WHEREFORE, Riley requests that this Court:

8 1 Find that the settlement is in the best interest of the Trust;

9 2. Approve the settlement;

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3. Find that the settlement is in the best interests of minors Harper Lockwood and
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Finley Lockwood and confirm that Michael Lockwood's signature on their behalf, as Guardian
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13 Ad Litem, is valid and binding.

14 4. Confirm that Danielle Riley Keough is the sole Trustee of Lisa's Irrevocable
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Trust;
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5 Confirm that Martin Singer is the Trustee of the sub-trust for the benefit of
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Navarone Garibaldi; and
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19 6 Order any other relief this Court deems just and proper.

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21 DATED: October 26, 2023 OLDMAN, SALLUS & GOLD, LLP

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23
By:
24 JUSTIN B. GOLD
25 Attorneys for Danielle Riley Keough,
sole Trustee of Lisa's Irrevocable Trust
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EX PARTE PETITION FOR APPROVAL OF SETTLEMENT AGREEMENT
1 VERIFICATION
2 I, Riley Keough, declare:
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4 I have read the foregoing EX PARTE PETITION FOR APPROVAL OF

5 SETTLEMENT AGREEMENT and know its contents. The facts contained therein are true

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of my own knowledge, except for those matters stated on information and belief, and as to
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those matters, I believe them to be true.
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9 I declare under penalty of perjury under the laws of the State of California that the
10 foregoing is true and correct. Executed on October 26 2023, at Los Angeles, CA.
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13
Riley keough Oct 26, 2023 15:10 PDT)

14 RILEY KEOUGH
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EXHIBIT 1
LISA'S







IRREVOCABLE












TRUST


























XIII.
ARTICLE













OF
POWERS






THE













GENERAL PROVISIONS,
TRUSTEE,

ADMINISTRATION
TRUST


























PROVISIONS
AND TAX













26

-
V





-






















































 LISA'S







IRREVOCABLE












TRUST

Exhibit
















"A"

1.



Hundred
One Dollars
($100.00)

BST-240C.LIT/100493
~28-







LA


(




GP.




Lede

LEVINSON, MILLER,








PHILLIPS
JACODS &











PROFESSIONAL
A












CORPORATION

























































EXHIBIT 2














EXHIBIT 3
 RESIGNATION OF TRUSTEE

TO: LISA MARIE PRESLEY, Settlor

BARRY SIEGEL and PRISCILLA PRESLEY, Co-trustees
DANIELLE RILEY KEOUGH, Adult beneficiary
LISA MARIE PRESLEY, Adult with whom minor beneficiaries reside

WHEREAS, City National Bank is serving as corporate co-trustee of LISA’S

IRREVOCABLE TRUST, pursuant to an appointment by Priscilla Presley dated July 30,
2007, and an acceptance by City National Bank dated August 2, 2007;

WHEREAS, the other trustees of LISA’S IRREVOCABLE TRUST are Priscilla

Presley and Barry Siegel;

WHEREAS, paragraph O of article XII of LISA’S IRREVOCABLE TRUST permits

City National Bank to resign as trustee by delivering a signed, written instrument to the
recipients noted above thirty days before such resignation shall take effect; and

WHEREAS, the settlor, co-trustees, and adult beneficiary of LISA’S IRREVOCABLE

TRUST (acting on her own behalf and on behalf of the minor beneficiaries), have consented
to waive the thirty-day notice period such that City National Bank may resign effective
immediately.

WHEREFORE, City National Bank hereby resigns as trustee of LISA’S

IRREVOCABLE TRUST.

CITY NATIONAL BANK

City National Bank, Trustee

By:

Its: Vice President

Date: 9/12/22

CONSENT TO WAIVER OF THIRTY-DAY NOTICE PERIOD:

LISA MARIE PRESLEY, Settlor date PRISCILLA PRESLEY, Trustee date

BARRY SIEGEL, Trustee date DANIELLE RILEY KEOUGH date

Adult beneficiary and representative of
minor beneficiaries
EXHIBIT 4
DocuSign Envelope ID: 105477D4-E336-44CD-A6F5-7AE5442007B2

BARRY SIEGEL
3130 WILSHIRE BOULEVARD
SUITE 600
SANTA MONICA, CA 90403

January 27, 2023

Priscilla Presley
c/o Lynn Walker Wright, Esq.
2813 Hiawassee Road
Suite 102
Orlando, Florida 32835
By Email To: [email protected]

Riley Keough
c/o Brad Russell, Esq.
Russell & Russell
6550 St. Augustine Road, Suite 305
Jacksonville, Florida 32217
By Email To: [email protected]

Harper and Finley Lockwood

c/o Michael Lockwood
5 San Lucas Avenue
Newbury Park, California 91320
By Email To: [email protected]

Navarone Garibaldi
15341 Leadwell Street
Van Nuys, CA, 91406
By Email To: [email protected]

Re: Lisa’s Irrevocable Trust Dated October 6, 1993

Dear Priscilla, Riley, Harper, Finley and Navarone:

DocuSign Envelope ID: 105477D4-E336-44CD-A6F5-7AE5442007B2

January 26, 2023

Page 2

I hereby resign as a Trustee of Lisa’s Irrevocable Trust Dated October 6, 1993 (the
Trust”). Pursuant to the terms of the Trust, my resignation is effective 30 days from the
date of this letter, i.e., as of February 27, 2023.

Very truly yours,

DocuSigned by:

Barry Sica
OBA6CC58246E46D...
Barry Siegel
EXHIBIT 5
 SETTLEMENT AGREEMENT AND RELEASE

This Settlement Agreement and Release (the "Settlement Agreement") is made and entered
into by and between Danielle Riley Keough, individually and as a Trustee of the Promenade Trust
dated January 29, 1993 (the "Promenade Trust") and as a Trustee of Lisa s lrrevocable Trust dated
October 6, 1993 ("Lisa's Irrevocable Trust") (collectively, "Riley"), Michael Lockwood
("Lockwood"), in his capacity as Guardian Ad Litem for Harper Lockwood ("Harper") and Finley
Lockwood ("Finley"), on the one hand; and Priscilla Presley, individually, as a Trustee of Lisa's
Irrevocable Trust, (collectively, "Priscilla"), on the other hand. Riley, Lockwood, and Priscilla are
referred to in this Settlement Agreement individually as a "Party" and collectively as the "Parties."
This Settlement Agreement is made with reference to the following facts:

RECITALS

A. On January 29, 1993, Lisa Marie Presley ("Lisa") executed the Promenade Trust dated
January 29, 1993, as Grantor, and naming Priscilla as a Trustee.

B. The beneficiaries of the Promenade Trust are Riley, Harper, and Finley.

C. The Promenade Trust was amended and completely restated on January 27, 2010.

D. Riley is the named Trustee of the Promenade Trust pursuant to an amendment thereto dated
March 11, 2016, the validity of which is in dispute.

E. Priscilla contends she is still serving as a Trustee of the Promenade Trust because she
contends the March 11, 2016 Amendment is invalid. On January 26, 2023, Priscilla filed
a Petition For Order: (1) Determining The Validity Of A Trust "Provision; (2) Instructing
The Trustee; and (3) Disapproving Modification of Trust with the Los Angeles Superior
Court, Case No. 23STPB000893 (the "Petition").

F. Riley contends the March 11, 2016 Amendment is valid and that she is the sole Trustee of
the Promenade Trust.

G. On October 6, 1993, Lisa executed Lisa's Irrevocable, as Settlor, and naming Priscilla as a
Trustee.

H. The beneficiaries of Lisa's Irrevocable Trust are Navarone Garibaldi Garcia ("Navarone")
as to a one-ninth {I/9 th ) interest; and Riley, Harper, and Finley, equally, as to the remaining
eight-ninths (819 th ) interest.

I. Navarone's one-ninth (119 th ) interest in Lisa's Irrevocable Trust is to be held in Trust and
administered in accordance with certain terms and conditions as set forth in Lisa's
Irrevocable Trust. That Trust is referred to as "Navarone's Trust."

J. As of the date of this Settlement Agreement, the Trustees of Lisa's Irrevocable Trust are
Riley and Priscilla.

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K. The Parties wish to avoid the time and expense associated with litigation and wish to enter
into this Settlement Agreement to settle all disputes as a family.

AGREEMENT

NOW THEREFORE, in consideration of the foregoing Recitals and the mutual promises
contained in this Settlement Agreement, and for good and valuable consideration, the receipt and
sufficiency of which are hereby acknowledged, the Parties agree, covenant, and represent as
follows:

1. Recitals lncorporated By Reference. The Recitals are incorporated at this point by

reference and shall be binding parts of this Settlement Agreement.

2. Agreement ubject to Co Ltrt Approval. The Settlement Agreement shall be subject

to Court approval in both the pending Promenade Trust action (Los Angeles Superior Court case
number 23STPB00893) as well as a new case number for Lisa's Irrevocable Trust This Agreement,
however, is binding upon the Parties unless the Court refuses to grant the Petitions for Approval
of Settlement Agreement that will be filed. Riley and Lockwood shall jointly file an ex parte
Petition for Approval of Settlement Agreement in both actions. The parties shall seek Court
permission to file the Settlement Agreement under seal and shall seek to have the Settlement
Agreement maintained under seal.

3. Final.ity Date. The "Finality Date" of this Settlement Agreement shall be the date
upon which the Order Approving the Settlement Agreement becomes final. As used herein, the
term "final" or "finality" means the day the Court enters the last of the two Orders Approving the
Settlement Agreement if there is no objection to either Petition, or, ifthere is any objection, sixty-
five (65) days after Notice of Entry of the last of the two Orders Approving the Settlement
Agreement are served on all interested parties and no appeal is taken.

4. Resignations and indemnification. This Settlement Agreement, among other

things, clarifies the identity of the Trustee of various Trusts, and to effectuate such a result:

a. Priscilla immediately and irrevocably resigns as Trustee of Lisa's Irrevocable

Trust, with the exception ofNavarone's Trust as specified in Paragraph 4(d) below.
For the avoidance of doubt, this resignation takes effect immediately upon
execution of this Settlement Agreement by Priscilla, and not upon the Finality Date.

b. Priscilla immediat ly and irrevocably confirms that Riley is the sole Trustee of the
Promenade Trust and, to the extent she is serving as a Trustee of the Promenade
Trust, irrevocably and immediately resigns as a Trustee of the Promenade Trust.
For the avoidance of doubt, this confirmation and resignation takes effect
immediately upon execution of this Settlement Agreement by Priscilla, and not
upon the Finality Date.

c. Riley, as Trustee of the Promenade Trust and as Trustee of Lisa's Irrevocable Trust,
shall defend, indemnify, and hold Priscilla harmless from and against all losses,
liabilities, proceedings, judgements, assessments, public charges, or contracts of
any kind whatsoever, in any case, whether known or unknown, whether fixed,
actual accrued or contingent liquidated or unliquidated and whether or not
asserted by a third party (including reasonable attorneys', consultants , and
experts fees and expenses and all amounts paid in investigation defense or
settlement of any of the foregoing and enforcement of its rights hereunder whether

2
 or not litigation has commenced), and the cost of enforcing any right to
indemnification hereunder (collectively, "Loss") from March 11, 2016, through the
Finality Date that Priscilla incurs or suffers arising out of, resulting from, relating
to, or in connection with any action or inaction of Priscilla as a Trustee of the
Promenade Trust and as a Trustee of Lisa's Irrevocable Trust; and any Loss of the
Promenade Trust or Lisa's Irrevocable Trust, including, but not limited to those
involving any Governmental Entity (herein defined as (i) any foreign, domestic,
federal, territorial, state, provincial, or local government; (ii) governmental,
administrative, regulatory, quasi-governmental, monetary, fiscal or judicial
authority, body, court, tribunal, arbitral body, commission, board, bureau, agency,
or instrumentality; or (iii) any political or other department, agency, subdivision,
department or branch of any of the foregoing, including any regulatory or oversight
organization or association.) unless the same are caused by the gross negligence or
willful misconduct of Priscilla.

d. Riley resigns as Trustee ofNavarone's Trust and confirms that Priscilla is the sole
Trustee of Navarone's Trust. Riley further confirms she has no objection to
Navarone or Priscilla naming Brigitte Kruse as a Co-Trustee ofNavarone's Trust.

5. Funding of Navarone' Trust. Riley, as sole Trustee of Lisa's Irrevocable Trust

shall collect the insurance money due to Lisa s l.rrevocable Trust and within ten (10) days after
Riley 's receipt of the life insurance proceeds, Riley shall distribute one-ninth (119 th ) of the life
insurance proceeds to Priscilla as Trustee of Navarone s Trust. Priscilla shall provide or shall
cause to be provided wiring instructions to Riley for an account titled in the name ofNavarone's
Trust, as well as the Tax ID number for that Trust, within ten (10) days after Riley's receipt of the
life insurance proceeds. The funding of Navarone's Trust shall occur after the "Payment to
Priscilla" referenced in Paragraph 6, below, is made off the top of the insurance proceeds. In the
event that Priscilla or Navarone do not have a power to appoint an individual Co-Trustee or
Successor Trustee of Navarone's Trust, Priscilla and/or Navarnne shall have the right to petition
the Court to modify Navarone's Trust pursuant to the applicable California Probate Code sections
to appoint Co-Trustees and/or name Successor Trustees.

6. Payment to Psiscilla. In exchange for Priscilla's resignation as Trustee, and in

consideration for the legal fees that are being avoided in any action relating to Lisa's Irrevocable
Trust, Riley, in her capacity as Trustee of Lisa's Irrevocable Trust, shall pay to Priscilla the sum
of one million dollars ($1,000,000.00). This payment shall be made within ten days after Riley's
receipt of the life insurance proceeds. Riley shall apply for life insurance benefits within ten (10)
days of the date when Priscilla accomplishes the resignations and confumations in paragraph 4
above. This one million dollar payment shall be made off the top of the funds received by Riley as
Trustee of Lisa s lrrevocable Trust and be borne by all beneficiaries of Lisa s Irrevocable Trust in
proportion to their respective interests.

7. Graceland Burial. Riley, as Trustee of the Promenade Trust, is the owner of

Graceland. Riley and Priscilla desire for Priscilla to be buried at Graceland. To the extent of her
authority, Riley agrees to allow Priscilla to be buried upon her death in the Meditation Garden of
Graceland. The burial location will be at the location closest to Elvis Presley without moving any
existing gravesite. To the extent of her authority Riley agrees to include in the planning of any
memorial service at Graceland, Navarone, any person Priscilla names as her executor, and any
person Priscilla names in her will as a person Priscilla desires to participate in planning her
memorial service. To the extent of her authority, Rjley agrees that Brigitte Kruse and Kevin Fialko
may attend any memorial service for Priscilla unless Prisci.lla in writing states that she does not
want either or both of them to attend.

3
 8. Dismissal Of The Action By Petitioners. Within ten (l 0) days after the Finality
Date, Priscilla shall withdraw/dismiss the Petition with prejudice.

9. Reimbursement of Legal Fees. Riley shall pay to Priscilla the sum of Three
Hundred Thousand Dollars and No/100 ($300,000.00) for legal fees and costs relating to the
Petition. Riley, as Trustee of the Promenade Trust and/or Trustee of Lisa's Irrevocable Trust shall
pay $300,000.00 to an account, per Priscilla's instruction, as reimbursement of legal fees and costs
incurred by her. In the event Priscilla incurred more than $300,000.00 in legal fees and costs, then,
in such event, Priscilla will provide Riley with an accounting with receipts totaling said additional
sums and Riley agrees to reimburse Priscilla up to a total of Four Hundred Thousand Dollars
($400,000.00) in legal fees and costs. This payment shall be made at the same time as the one
million dollar payment is made as stated in Paragraph 6 of this Agreement; provided, however,
that this payment shall be made no later than six months of the Finality Date. Riley shall pay the
first $50,000 of this payment within twenty days of the date of execution of this Settlement
Agreement by Priscilla. Riley shall pay a further $25,000 of this payment within ten days after
the Finality Date.

10. Priscilla s Waiver Of All Rights To The Trusts. As consideration for the terms of
this Settlement Agreement as well as the covenants, promises and releases being provided by Riley
and Lockwood herein, and in addition to the remaining covenants, promises and releases being
provided by Priscilla under the terms of this Settlement Agreement, Priscilla hereby waives and
release any and all claims, rights, or interests in the Promenade Trust and/or Lisa's Irrevocable
Trust, including but not limited to any claim, right, or interest in any and all assets owned by either
Trust at any time, now or in the future, and any right to any portion of the residue of the Trust,
distributed or undistributed. Priscilla further agrees that she has received any and all benefits to
the Trust to which she is entitled and that she no longer has any interest in either Trust, or the
Estate of Lisa Marie Presley, whatsoever. Nothing in this Settlement Agreement shall constitute
a waiver by Priscilla to claim that some of her personal belongings, whether said belongings are
owned by her individually or jointly owned with another person or entity which remain at
Graceland, or are located in any storage facility controlled by Graceland, and Priscilla reserves her
right to take any necessary legal action as to her claim for such personal property free of any
restrictions in this Settlement Agreement. FLLrther Riley, as a member of the Presley Family and
as Trustee of the Promenade Trust, agrees to reasonably cooperate consistent with her legal and
equitable obligations, assist Priscilla in retrieving all of Priscilla's personal belongings whether
owned by her individually or jointly owned with another person or entity which remain at
Grnceland or at any storage facility controlled by Graceland· provided however, Riley shall have
no obligati.on to commence or otherwise participate in any litigation involving the ownership of
such items. Nothing in this provision requires Riley to agree that any property claimed by Priscilla
actually belongs to Priscilla, and to the extent Riley believes in good faith that Priscilla does not
own any particular property she claims to own, she shall have no obligation to assist Priscilla with
any such retrieval, but shall assist in good faith to facilitate a line of communications between
Priscilla and Graceland in the event of a dispute as to the ownership of any particular property.

11. Special Advisor. Riley agrees to retain Priscilla to serve as her "Special Advisor"
of the Promenade Trust related to its shareholder interest in Elvis Presley Enterprises, Inc.,
including any successors thereof. Riley, as Trustee of the Promenade Trust, shall pay to Priscilla
the sum of One Hundred Thousand Dollars ($100,000.00) per annum payable in monthly
installments, for her role as Special Advisor to the Trust, which shall be a non-fiduciary role. Riley
shall have sole discretion to determine what Priscilla's duties are. Riley reserves the right to
terminate Priscilla as Special Ad isor at any time for any reason. Priscilla shall receive the
$100,000.00 annual payment for a guaranteed term of ten ( 10) years or until her death, , hichever
is sooner and regardless of whether Riley ever terminates Priscilla s role as Special Advisor. For

4
avoidance of doubt, in the event Priscilla dies during the ten-year period, the final Special Advisor
payment shall be pro-rated for the year which the death occurred.

Further, Riley, as Trustee of the Promenade Trust agrees to indemnify Priscilla and Priscilla
Releasees (defined below) as Special Advisor for or from any Loss that the Promenade Trust, its
Trustee(s) and its beneficiaries incurs or suffers arising out of, resulting from, relating to, or in
connection with any action or inaction of Priscilla in solely her capacity as pecial Advisor which
arises from any action or inaction she took or purported to take as Special Advisor of the
Promenade Trust.

12. Pl'iscila' s Name, Image, and Likeness. Riley agrees to use her best efforts to ask
Elvis Presley Enterprises, Inc. ("EPE" and/or Authentic Brands Group ("ABG")), or any successor
thereof, not to pursue litigation against Priscilla related to her name, image, and likeness. Priscilla
and her agents or representatives understand that Riley has no power to control EPE or ABG, and
is not making any warranty or representation regarding the success of such a request.

13. [Intentionallv omitted.]

14. Tax Treatment. The Parties agree that they are each personally responsible for their
own tax liabilities and those tax liabilities that flow from this Settlement Agreement. Each Party
will prepare for themselves or engage their own tax professional(s) at their own expense.

15. Releases of Claims.

(a) Releases Provided by Priscilla. Except for the obligations created by or arising out
of this Settlement Agreement Priscilla individually as Trustee of the Promenade Trust to the
extent she served in such capacity and as a Trustee of Lisa s Irrevocable Trust on behalf of
herself, and each of her heirs, executors, trustees, administrators, attorneys, successors, assigns,
authorized representatives, agents, and any person or entity making or authorized to make any
claim by, through, or on behalf of, or for any of them, including, but not limited to Brigitte Kruse
and Kevin Fialko (collectively, the "Priscilla Releasors"), hereby release and absolutely discharge
Riley, individually, as Trustee of the Promenade Trust and as Trustee of Lisa's Irrevocable Trust;
Lockwood, on behalf of Harper, and Finley; and their respecti.ve heirs, executors, trustees,
administrators, attorneys, assigns, authorized representatives, and agents, and any person or entity
making or authorized to make any claim, by, through or on behalf of, or for any of them but
specifically excluding EPE and ABG (collectively, the "LMP Releasees ) of and from any and all
claims, demands, damages, debts, liabilities, accounts, obligations costs, expenses, actions and
causes of action of every nature, character and description whether known or unknown, suspected
or unsuspected, asserted or unasserted, fixed or contingent that Priscilla now owns or bolds or at
any time heretofore have owned or held, from the beginning of time through the Finality Date of
the Settlement Agreement.

(b) Releases Provided by Ril.ey and Lockwood. Except for the obligations created by
or arising out of this Settlement Agreement, Riley individually as Trustee of the Promenade Trust
as Trustee of Lisa's Irrevocable Trust, and Lockwood on behalf of Harper and Finley on behalf
of themselves, and their respective heirs, executors, trustees, administrators, attorneys, successors,
assigns, authorized repr sentatives, agents and any person or entity making or authorized to make
any claim by, through or on behalf of, or for them (collectively, the "LMP Releasors ) hereby
release and absolutely discharge Priscilla individually and in any fiduciary capacity regarding the
subject matter of this Settlement Agreement, and each of her heirs executors, trustees,
administrators attorneys, assigns authorized representatives, business partners stockholders,

5
business entities, partners, members, appointees, and agents, including, but not limited to Brigitte
Kruse and Kevin Fialko and their respective family members (collectively, the "Priscilla
Releasees"), of and from any and all claims, demands, damages, debts, liabilities, accounts,
obligations, costs, expenses, actions, and causes of action of every nature, character and
description, whether known or unknown, suspected or unsuspected, asserted or unasserted, fixed
or contingent, that Priscilla now owns or holds, or at any time heretofore has owned or held, from
the beginning of time through the Finality Date of the Settlement Agreement.

(c) Waiver of California Civil Code ection 1542. The Parties are aware that they may
have claims against one another of which they have no present knowledge or suspicion, and which
will be released by this agreement. Each Party takes these possible claims into account in entering
into this Settlement Agreement, and agrees that this Settlement Agreement is intended to be a full
and final release of these claims. With respect to such claims, this constitutes a waiver to the
fullest extent legally possible of each and all of the provisions of California Civil Code Section
1542. The Parties herein acknowledge that the effect and import of the provisions of California
Civil Code Section 1542 have been explained to them by their own counsel, which provides:

A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS

THAT THE CREDITOR OR RELEASING PARTY DOES NOT
KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT
THE TIME OF EXECUTING THE RELEASE AND THAT, IF
KNOWN BY HIM OR HER, WOULD HA VE MATERIALLY
AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR
OR RELEASED PARTY.

16. Covenant Not to Sue. The Priscilla Releasors and the LMP Releasors agree to
refrain and forbear forever from commencing, instituting, prosecuting, or directly or indirectly
participating in, or filing any claim for damages or demand in connection with, any lawsuit, action,
or proceeding against the respective Releasees, or any of them, based upon any of the released
claims.

GENERAL PROVISIONS

17. No Admission of Liability. This agreement does not constitute an admission by

any of the Parties of any liability or wrongdoing whatsoever.

18. Successors in Interest. This agreement, including the releases contained herein,
shall be binding upon and inure to the benefit of the Parties and each of their successors-in-interest,
including, without limitation, heirs, permitted assigns, and beneficiaries.

19. Non-Assignment. The Parties represent and warrant that they have not assigned or
otherwise transferred any interest in any claim which is the subject of this agreement.

20. Mutually Drafted Settlement Agreement. Each of the Parties has been fully and
competently represented by counsel of their own choosing in the negotiations and drafting of this
agreement. Accordingly, the Pa1ties agree that any rule of construction of contracts resolving any
ambiguities against the drafting Party shall be inapplicable to this agreement. Each term of this
agreement is contractual, not a mere recital , and is the result of negotiations between the Parties.

21. Final Written Expression. This Settlement Agreement is integrated and once
accepted according to its terms is intended by the Parties as a final and complete expression of
their agreement with respect to the subject matter addressed herein. This Settlement Agreement
6
supersedes any and all prior or contemporaneous agreements, negotiations, or understandings,
written or oral, between the Parties regarding the subject matter addressed herein. The Parties
hereto, and each of them, acknowledge that no other Party nor any agent or attorney for any other
Party has made any promise, representation, or warranty whatsoever, express or implied, written
or oral, not contained herein, concerning the subject matter hereof to induce the execution of this
Settlement Agreement, and each of the Parties acknowledges that it has not executed this
Settlement Agreement in reliance on any promise, representation, or warranty not contained
herein.

22. Amendment. This Settlement Agreement may not be amended, modified, or

terminated, in whole or in part, except by an instrument in writing duly executed by the Parties or
their authorized representatives.

23. Waiver. Any waiver of any term of this Settlement Agreement must be in writing
and signed by the Party waiving its rights hereunder. Conduct that is arguably or actually
inconsistent with rights granted under this Settlement Agreement shall not constitute a waiver
unless an intent to waive rights under this Settlement Agreement is clearly expressed in writing as
required by this paragraph. The waiver of any term or condition contained in this Settlement
Agreement shall not be construed as a waiver of any other term or condition contained in this
Settlement Agreement.

24. Warranty of Independent Advice. Each Party warrants and represents that it has
received independent legal advice from such Patty s attorney with respect to the rights and
obligations arising from and the advisability of executing, this Settlement Agreement and with
respect to the waiver of Section 1542 of the California Civil Code.

25. Warranty of Due Authorization. Each Party warrants and represents that such Party
is fully entitled and duly authorized to enter into and deliver this Settlement Agreement. In
particular, subject to any restrictions in California law, including the Probate Code or any order of
a court of competent jurisdiction, and without limiting the generality of the foregoing, each Party
warrants and represents that it is fully entitled to grant the releases and undertake the obligations
set forth herein, no other person or entity has any interest in the claims demands, allegations or
causes of action released .in this Agreement that the Parties have neither assigned nor transferred
to a person or entity any claim released herein, or a portion thereof or interest therein, and that the
Parties each have the sole right and exclusive authority to execute this Settlement Agreement on
their own behalf and to release all claims they are releasing herein. The Parties further warrant
and represent that there is no legal lien or other lien against the claims released herein.

26. Warranty of Power. Each Pa1ty warrants and represents that it is duly organized
and validly existing under the laws of the state or nation of its incorporation or formation and that
it has full power and authority to enter into this Settlement Agreement and carry out the provisions
hereof.

27. o Third Party Beneficiaries. No person or entity shall be considered a third party
beneficiary of, or otherwise entitled to any rights or remedies under this Settlement Agreement
except with respect to the releases expressly provided for herein.

28. Governing Law. This Settlement Agreement shall be governed by, construed, and
enforced in accordanc with the laws of the State of California, without giving effect to its choice
of law provisions.

29. Jurisdiction. The Parties agree that the court in the Actions reserves jurisdiction to
enforce the terms and conditions of the Settlement Agreement pursuant to California Civil
Procedure Code Section 664.6 upon noticed motion of any party. The Parties agree to timely

7
execute all notices of settlement, stipulations, and/or other documents as shall be reasonably
necessary to authorize the Court to retain jurisdiction under Code of Civil Procedure Section 664. 6.

30. Mutual Cooperation. The Parties mutually agree to cooperate and participate in
any acts necessary to carry out the provisions, duties, and responsibilities identified in this
agreement, including, but not limited to, the signing of pleadings or other documents as necessary.
Furthermore, Priscilla expressly agrees to cooperate with any request by Riley to sign any further
documents related to any life insurance policy on Lisa's life, including, but not limited to, applying
to collect the proceeds of any such life insurance policy.

31. everability. If any provision of this Settlement Agreement is declared invalid by

any tribunal, then such provision shall be deemed automatically adjusted to the minimum extent
necessary to conform to the requirements for validity as declared at such time and, as so adjusted,
shall be deemed a provision of this Settlement Agreement as though originally included herein. In
the event that the provision invalidated is of such a nature that it cannot be so adjusted the
provision shall be deemed deleted from this Settlement Agreement as though such provision had
never been included herein. In either case, the remaining provisions of this Settlement Agreement
shall remain in full force and effect.

32. Gender/Plural/Connectives. Whenever in this Settlement Agreement the context

may require, the masculine gender shall be deemed to include the feminine and/or neuter, and vice
versa, the singular to include the plural, and vice versa, and (to give the releases herein the broadest
interpretation and scope, as is desired by the Parties hereto) the connectives "and" and "or" to
mean "and/or."

33. Attorneys Fees/Costs for Underlying Dispute. All Parties shall bear their own
attorneys' fees, expenses, and costs in connection with, related to, or arising from the Action and
the preparation and negotiation of this Settlement Agreement.

34. Headings. Headings as used in this Settlement Agreement are for convenience only
and are not a pa11 of thjs Settlement. Agreement. The Parties acknowledge that they have read the
full substance of each paragraph and are not relying upon the headings.

35. Breach; Attorneys' Fees for Enforcement of Agreement. In the event of an alleged
breach of this Settlement Agreement the Pa11ies shall attempt to resolve their dispute through
mediation with Judge Roy Paul of Signature Resolution the cost of which shall be borne equally
by the Parties. If the Parties are unable to resolve the dispute through mediation, the Parties may
address any such alleged breach through the Probate Division of the Los Angeles Superior Court.
In the event that a dispute arises concerning the enforcement of this Settlement Agreement, the
prevailing party in said dispute, as determined by a court of competent jurisdiction or other trier
of fact, shall be entitled to recover its reasonable attorneys' fees and costs arising from such
dispute.

36. Execution in Counterparts. This Settlement Agreement may be executed in two (2)
or more counterparts, each of which shall be deemed an original and all of which together shall
constitute one and the same instrument. Counterparts may be deli ered via facsimile, electronic
mail (including PDF or any electronic signature complying with the U.S. federal ESTGN Act of
2000, e.g., www.docusign.com) or other transmjssion method and any counterpart so delivered
shall be deemed to hav been duly and validly delivered and be valid and effective for all purposes.

37. Survival. All agreements obligations, representations covenants, and warranties

on the part of the Patties contained in this Settlement Agreement or any amendment modification
or supplement hereto shall survive this Settlement Agreement.

8
 IN WITNESS WHEREOF, the Parties have each approved and executed this Settlement
Agreement on the dates set forth below.

Dated: May_, 2023 Danielle Riley Keough, individually, as Trustee of the

Promenade Trust, and as Trustee of Lisa's Irrevocable
Trust

By :_ __ __ __ _ _ _ __ __

Dated: May \? ,2023 Michael Lockwood, Guardian Ad Litem for Harper

Lockwo an individual, and · nl Lockwood, an

inj"d]a £.

By:---.1--=--+-4+--'d--'-'-'---'-<-'1 ----->....+----- --

Dated: May_, 2023 Priscilla Presley, individually, Trustee of Lisa's Irrevocable

Trust, Trustee of the Promenade Trust, and as Trustee of
Navarone's Trust

By:
- - - - - -- - -- - - - --

AS TO SECTION 15 "RELEASE OF CLAIMS" ONLY:

Dated: May_, 2023 Brigitte Kruse, individually, and as a fiduciary of Priscilla

Presley

By:

Dated: May_, 2023 Kevin Fialko, individually

By:

9
CALIFORNIA ACKNOWLEDGMENT CIVIL CODE § 1189

A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document
to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.

State of California }
\)_
County of ___ E_J-)
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Name(s) of Signer(s)

who proved to me .on the basis of satisfactory eviden:7.:'!~-be the perso_gis}-whose nam~l>are subscribed
to the withi n Instrument and acknow,I dged to me tha~he/they executed·the same ~/her/their
authorized ca pacity{[es};-and that b hi er/the ir signature(s-}-o11 the instrument the person(sr;-or the entity
upon behalf of which the person(~cted, executed the instrument.

=••·········~
,
A

~
DONA L. BERGSTROM
Notary Public • California
Los Anjeles County
I
•
I certify under PENALTY OF PERJURY under the
laws of the State of California that the foregoing
paragraph is true and correct.
° Commission # 2442060
"My Comm. ExplresApr 17, 2027 WITNESS my hand and official seal.

Place Notary Seal and/or Stamp Above

OPTIONAL
Completing this information can deter alteration of the document or
fraudulent reattachment of this form to an unintended document.
Description of Attached Document
Title or Type of Document: _ _ _ _ _ __ _ _ __ __ _ _ __ _ _ __ _ _ _ __ __
DocumentDate: _ _ __ _ __ _ _ _ __ _ _ _ _ __ _ _ _ Numberof Pages: _ __ __
Signer(s) Other Than Named Above: _ _ __ _ _ _ __ _ _ __ _ _ __ __ _ __ _ _

Capacity(ies) Claimed by Signer(s)

Signer's Name: _ _ __ _ _ _ _ _ __ __ Signer's Name: _ _ _ _ _ _ __ _ __ __
□ Corporate Officer - Title(s): _ _ _ _ __ _ □ Corporate Officer - Title(s): _ __ _ __ _

□ Partner - □ Limited □ General □ Partner - □ Limited □ General

□ Individual □ Attorney in Fact □ Individual □ Attorney in Fact
□ Trustee □ Guardian or Conservator □ Trustee □ Guardian or Conservator
□ Other: □ Other:
Signer is Representi.ng: _ _ _ _ _ _ _ __ _ Signer is Representing: _ _ _ __ __ _ __

©2018 National Notary Association

 IN WITNESS WHEREOF, the Parties have each approved and executed this Settlement
Agreement

Dated: .2023 Danielle Riley Keough, individually, as Trustee of the

Promenad Trust, and as Trustee of Lisa's Irrevocable

By:

Dated
we'? Michael Lockwood, Guardian Ad Litem for Harper
an individual, and Finley Lockwood, an
individual

By:

Dated: May__, 2023 Priscilla Presley, individually, Trustee of Lisa's Irrevocable

Trust. Trustee Promenade
Navarone's Trust

By:

AS TO SECTION 15 "RELEASE OF CLAIMS" ONLY:

Dated: May Brigitte Keyl, ofPriscilla

cy

By

Dated: Kevin Fialko, individually

By:

9
 IN WITNESS WHEREOF, the Parties have each approved and exccuted this Settlement
Agreement on the dates set forth below.

Dated: May___, 2023 Daniclle Riley Keough, individually,as Trustee of the

Promenade Trust, and as Trustee of Lisa's Irrevocable
Trust

By:

Dated: May__, 2023 Michael Lockwood, Guardian Ad Litem for Harper

Lockwood. an individual,-and Finley Lockwood, an
individual

By:

Dated: May___, 2023 Priscilla Presley, individually, Trustee of Lisa's Irrevocable

Trust, Trustee of the Promenade Trust, and as Trustee of
Navarone's Trust

By:

AS TO SECTION 15 "RELEASE OF CLAIMS" ONLY:

Dated: May .2023 Brigitte Kruse, individually, and as a fiduciary of Priscilla

Presley

By:

Dated: May 12, 2023 Kevin Fialko, individually

By:

9
 IN WITNESS WHEREOF, the Parties have each approved and executed this Settlement
Agreement on the dates set forth below.

Danielle Riley Keough, individually, as Trustee of the

Ai.
Dated: May \%, 2023
Promenade Trust, and as Trustee of Lisa's Irrevocable

BH
anor Trust

NO™~ rs,
AY
G
#21 4 'oad
Riche By:
N 326
Tel 604-44-0100
Dated: May .2023 Michael Lockwood, Guardian Ad Litem for Harper
Lockwood, an individual, and Finley Lockwood, an
individual

By:

Dated: May___, 2023 Priscilla Presley, individually, Trustee of Lisa's Irrevocable

Trust, Trustee of the Promenade Trust, and as Trustee of
Navarone's Trust

By:

AS TO SECTION 15 "RELEASE OF CLAIMS" ONLY:

Dated: May 2023 Brigitte Kruse, individually, and as a fiduciary of Priscilla

Presley

By7

Dated: May .2023 Kevin Fialko, individually

By

)
 IN WITNESS WHEREOF, the Parties have each approved and executed this Settlement
Agreement on the dates set forth below.

Dated: May___, 2023 Danielle Riley Keough, individually, as Trustee of the

Prontenade Trust, and as Trustee of Lisa's Irrevocable
Trust

By:

Dated: May 2023 Michael Lockwood, Guardian for Uarpcr

Lockwood, an individual, and Finley Lockwood, an
individual

By:

May/4, 2023
Dated: May Priscilla Presley, individually, Trustee of Lisa's Irrevocable
Trust, Trustee of the Promenade Trust, and as Trustee of
Navarone's Trust

AS TO SECTION 15 "RELEASE OF CLAIMS" ONLY:

Dated: May .2023 Brigitte

Preslcy
u individually, and as a fiduciary of Priscilla

By:

Dated: May __, 2023 Kevin Fialko, individually

By:

9
CALIFORNIA ALL-PURPOSE ACKNOWLEDGMENT Civit CODE § 1189

pier f lotiaat $s© cettete enfes only ing identi,

only the death, chop ads he gre Sire
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State of Cattorma
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May \2,202%
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Here Insert Name and Tile af
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personaly appeared Prise i\\ oN Pres \ey
Narpe(s} of Signerts)

who proved te mc on the basin of : yi ISTACTOrY evidence to be the person(s) whose

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becubedt to the within sastrument and acenowedaed
acenowiedged ta me that teyshpe h { ir Sone 34
nen Ly } and inat by p sthry tneir signature(s) an the instrument the person(s).
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ohne entty upan cehalt af which the pcrsots) acted, caecuted the instrument.
under PENALTY OF under the laws
ot th State of Calitornia that the foregoing paragraph
ig true and correct

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Exprac
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OPTIONAL
Though tus Sci
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reattachmant of tus for to an unintended dacument
Oescription of Attached Document
Tale or Type of Becument Yemens Aoytament one Release
Document Date Number of Pages
Other Toan Named Above

Capacity(ies) Claimed by Signer(s}

S gners Name Si
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 CALIFORNIA
JURAT CERTIFICATE
A Notary Public or other officer completing this certificate verifies only the identity of the individual who signed the
document ta which this certificate is attached. and not the truthfulness, accuracy. or validity of that document

State of California

County of Los Angeles

}2
Subscribed and sworn to (or affirmed ) before me on this
20.03 wy Priscilla
day of
May -

proved to me on the basis of satisfactory evidence to be the person(s) who appeared before me.
o> TEVA faFIT
Notary Pubile - California
WITNESS MY HAND AND OFFICIAL SEAL tos eles County E
Commission 2 2373817
My Comm. Expires Sep 4. 2025

Signature af Notary Publ (Notary Seal)

OPTIONAL INFORMATION
The purest contained astlon thes dec truce eu acconéauy ath Califor lac, Any affidamt satscnbed and swors to befor a
uotary shall ine
ihe preceding wording or substantially siunlar wordiusg prrauautt to Civil Code sections 1189 and §202. 4 jurat certificaie cannot be affixed
toa decument sent by mail at otherwise delivered to a nutory public, including electranie means, whereby the signer did not
perionally appear before the notary public, even if the signer is knows by the actary public. The seal and signature sannot be
affixed to a decument wiheut the correct notarial wording. Aa an addutonal qpiton an affiant can produce un affiduvis an the
some document as the natarial certificate wording to eliminate the use ofadditinnal documentation.

DESCRIPTION OF ATTACHED DOCUMENT CAPACITY CLAIMED BY THE SIGNER

Se Clitle of
Lease Individual
1) ~ Coroanate Officer
Partin:
Nuntbes of Pages (including jurus) Attornes-In-Faet
Trustee
Document Qate

(Additinaal Infunnation)

MMX V BAN2 $10.409,1334 wivw BavAreaNousy com

EXHIBIT 6
 AMENDMENT TO SETTLEMENT AGREEMENT AND RELEASE
This Amendment to the Settlement Agreement and Release (the "Settlement Agreement")
is made and entered into by and between Danielle Riley Keough, as Trustee of Lisa's Irrevocable
Trust dated October 6, 1993 ("Lisa's Irrevocable Trust") ("Riley"), Michael Lockwood
("Lockwood"), in his capacity as Guardian Ad Litem for Harper Lockwood ("Harper") and Finley
Lockwood ("Finley"), Navarone Garibaldi Garcia ("Navarone"), and Priscilla Presley,
individually, as a Co-Trustee of Lisa's Irrevocable Trust, (collectively, "Priscilla"). Riley,
Lockwood, and Priscilla are referred to in this Settlement Agreement individually as a "Party" and
collectively as the "Parties." This Amendment to the Settlement Agreement incorporates the
entirety of the Settlement Agreement executed on May 13, 2023, except as expressly stated in this
Amendment.

AMENDMENT TO AGREEMENT
Section 4(d) of the Agreement dated May 13, 2023 previously stated:

"Riley resigns as Trustee of Navarone's Trust and confirms that Priscilla is the sole
Trustee of Navarone's Trust. Riley further confirms she has no objection to
Navarone or Priscilla naming Brigitte Kruse as a Co-Trustee of Navarone's Trust."

Section 4(d) of the May 13, 2023 Agreement shall now provide:

"Riley resigns as Trustee of Navarone's Trust and confirms that Martin Singer shall
become the sole Trustee of Navarone's Trust."

Section 5 of the May 13, 2023 Agreement previously stated:

"Funding of Navarone's Trust. Riley, as sole Trustee of Lisa's Irrevocable Trust shall
collect the insurance money due to Lisa's Irrevocable Trust, and within ten (10) after
days
Riley's receipt of the life insurance proceeds, Riley shall distribute one-ninth (1/9") of the
lifeinsurance proceeds to Priscilla as Trustee of Navarone's Trust. Priscilla shall provide
or shall cause to be provided wiring instructions to Riley for an account titled in the name
of Navarone's Trust, as well as the Tax ID number for that Trust, within ten (10) days after
Riley's receipt of the life insurance proceeds. The funding of Navarone's Trust shall occur
after the "Payment to Priscilla" referenced in Paragraph 6, below, is made off the top of
the insurance proceeds. In the event that Priscilla or Navarone do not have a power to
appoint an individual Co-Trustee or Successor Trustee of Navarone's Trust, Priscilla
and/or Navarone shal] have the right to petition the Court to modify Navarone's Trust
pursuant to the applicable "California Probate Code sections to appoint Co-Trustees and/or
name Successor Trustees.

Section 5 of the May 13, 2023 Agreement shall now provide:

Funding of Navarone's Trust. Riley, as sole Trustee of Lisa's Irrevocable Trust shall
collect the insurance money due to Lisa's Irrevocable Trust, and within ten (10) days after
the Court approves this Settlement Agreement, Riley shall distribute one-ninth (1/9") ofa

1
 the $25 million life insurance policy to Martin Singer as Trustee of Navarone's Trust.
Martin Singer shall provide or shall cause to be provided wiring instructions to Riley for
an account titled in the name of Navarone's Trust, as well as the Tax ID number for that
Trust, within ten (10) days after the Court approves the Settlement Agreement. The funding
of Navarone's Trust shall occur after the "Payment to Priscilla" referenced in Paragraph 6,
of the May 13, 2023 Agreement, is made off the top of the insurance proceeds."

By their signatures below, Priscilla Presley and Navarone Garibaldi Garcia hereby
nominate Martin Singer to serve as Trustee of Navarone's Trust created under Lisa's Irrevocable
Trust, and consent to his appointment as Trustee.

In all other respects, the May 13, 2023 agreement is ratified.

**% ***
Signatures on following page

2
 IN WITNESS WHEREOF, the Parties have each approved and executed this Amendment
to the Settlement Agreement on the dates set forth below.

Dated: October___, 2023 Danielle Riley Keough, as Trustee of Lisa's Irrevocable

Trust

By Rile
JL
eough (Oct 25, 2023 19:33 PDT

Dated: October 26 2023 Michael Lockwood, Guardian Ad Litem for Harper

Lockwood, an individual, and Finley Lockwood, an
individual

or

Dated: October, 4 2023 Priscilla Presley, individually, and as Trustee of Lisa's

Irrevocable Trust,

Dated: October___, 2023 Navarone Garibaldi Garcia

By:

CONSENT TO SERVE

I, Martin Singer, hereby consent to serve as Trustee of Navarone's sub-trust created under Lisa's
Irrevocable Trust.

Dated: October25, 2023 Martin Singer

By:

3
 i
IN WITNESS WHERI-OF, the Parties have cach approved and executed this Amendment
ta the Settlement Agreement on the dates set forth below. ;

Dated: Octob 2023 Danielle Riley Keough, as Trustee of Lisa's Irrevocable

Trust

By:

Dated: October, 2023 Mi chacl Lockwood, Guardian Ad Litem for tlarper

Lockwood. an individual, and Finley Lockwood, an
individual

By:

Dated: October, 2023 Pri scilla Presley, individually, and as Trustee of Lisa's
Irrevocable Trust,

By:

Dated: OctoberQ 2023 Na varone Garibaldi Garcia

By

CONSENT TO SERVE

|,Martin Singer, hereby consent to serve as Trustee of Navarone's sub-trust created under Lisa's
Imevocable Trust.
4
Dated: October_24 2023 Ma tin Singe

By!

WRT
Amendment to Sett. Agmt
Final Audit Report 2023-10-26

Created: 2023-10-26

By: Justin Gold ([email protected])

Status: Signed

Transaction ID: CBJCHBCAABAA-94yvBU053umADdQzxZ7yNqlIhPUWbJX

"Amendment to Sett. Agmt" History

5 Document created by Justin Gold ([email protected])
2023-10-26 2:15:19 AM GMT- IP address: 162.248.119.242
-

Document emailed to [email protected] for signature

2023-10-26 2:15:35 AM GMT
-

Email viewed by [email protected]

2023-10-26 2:33:19 AM GMT- IP address: 166.199.151.28
-

&@ Signer [email protected] entered name at signing as Riley keough

2023-10-26 2:33:42 AM GMT- IP address: 166.199.151.28
-

&@ Document e-signed by Riley keough ([email protected])

Signature Date: 2023-10-26 2:33:44 AM GMT Time Source: server- IP address: 166.199.151.28
- -

© Agreement completed.
2023-10-26 2:33:44 AM GMT
-

Adobe Acrobat Sign

EXHIBIT 7
 LIST OF INTERESTED PERSONS

In the Lisa’s Irrevocable Trust

Case No.:

Scott E. Rahn, Esq. (SBN: 222528) Ronson J. Shamoun, Esq. (226178)

RMO, LLP LAW OFFICE OF RONSON SHAMOUN
901 Bringham Avenue 303 A Street, Suite 400
Los Angeles, CA 90049 San Diego, CA 92101
Telephone: (424) 320-9440 Telephone: (619) 595-1655
Email: [email protected] Facsimile: (619) 595-1658
Attorneys for Michael Lockwood, GAL Email: [email protected]
Attorneys for Priscilla Presley

Michael Lockwood Michael Lockwood

c/o Scott E. Rahn, Esq. c/o Scott E. Rahn, Esq.
901 Bringham Avenue 901 Bringham Avenue
Los Angeles, CA 90049 Los Angeles, CA 90049
GAL for Harper Lockwood, Beneficiary GAL for Finley Lockwood, Beneficiary

Danielle Riley Keough Priscilla Presley

c/o Justin B. Gold, Esq. c/o Ronson J. Shamoun, Esq.
16133 Ventura Boulevard, Penthouse 303 A Street, Suite 400
Encino, CA 91436 San Diego, CA 92101
Beneficiary and Trustee

Navarone Garibaldi
15341 Leadwell Street
Van Nuys, CA 91406
Email: [email protected]