Executor Briefing — Estate of Jan Koum / Loma Vista Trust

1025 Loma Vista Drive, Beverly Hills, CA 90210

Estate ID: feeba4a1-08d1-4221-b90b-ba27a6ee68a7 | APN: 4391-036-016 | Jurisdiction: California

Section 1 — Estate Summary

Property Description

A custom-built 26,619 sq ft estate on 6.33 acres (275,813 sq ft) in the Trousdale Estates enclave of Beverly Hills. Built in 2012 by then-DreamWorks CEO Jeffrey Katzenberg (architect: Howard Backen), the property was purchased by Jan Koum in August 2020 for $125 million cash. The estate features 4 bedrooms, 13 full bathrooms, and a pool. ATTOM AVM returns $0 — the property exceeds all automated valuation model ranges, consistent with a bespoke $100M+ asset. Estimated current fair market value: $140M–$180M+ based on 2021 reassessment baseline and Beverly Hills luxury market appreciation 2021–2026.

(Sources: ATTOM APN 4391-036-016 FIPS 06037; LA County Assessor via OpenGovUS; BlockShopper; The Real Deal; WillGuardian; DebtSentinel; TitleCleaner)

Section 2 — Risk Assessment

Overall Estate-Readiness Score: 3 / 10 — HIGH RISK

Justification

The Loma Vista Trust is the correct vehicle for this estate — it avoids up to $1.47M in statutory probate fees (Cal. Prob. Code § 10810) and, if properly structured, keeps the property outside the probate estate. However, the entire estate plan rests on a trust instrument that no party in this analysis has reviewed. The co-trustee governance gap alone could paralyze any transfer or encumbrance under Cal. Prob. Code § 15620 (unanimous co-trustee action required unless instrument specifies otherwise). Layered on top: an unquantified but potentially multi-billion-dollar federal estate tax obligation, an active regional lien-fraud threat in the same neighborhood, and no confirmed digital asset authorization for a tech billionaire's estate — this estate requires immediate attorney engagement before any action is taken.

Section 3 — Property Dossier

Property: 1025 Loma Vista Drive, Beverly Hills, CA 90210

Identification

Title Status

Valuation History

The August 2020 deed recording triggered a full Prop. 13 change-of-ownership reassessment under Cal. Rev. & Tax. Code §§ 60–68, resetting the base year to ~$124M (reflecting the $125M acquisition price).

Lien Summary

Market Value Estimate

Section 4 — Creditor Payment Sequence

Governing Law

Cal. Prob. Code § 11420 governs order of payment of debts and charges in probate. For trust-administered estates, Cal. Prob. Code §§ 19000–19403 govern creditor claims against the trust. Property tax is a paramount statutory lien under Cal. Rev. & Tax. Code §§ 2187–2192, senior to all other claims.

Note: Because this property is held in the Loma Vista Trust (RLT), standard probate creditor procedures (Cal. Prob. Code § 9100) do not directly apply to this asset. Trust creditor claims are governed by Cal. Prob. Code §§ 19000–19403. The priority sequence below reflects the practical payment waterfall for trust administration and any ancillary probate assets.

CLASS 0 — SUPER-PRIORITY (Paramount to all other liens)

Cal. Rev. & Tax. Code §§ 2187–2192

Must be paid before any distribution. Prorate at date of transfer.

CLASS 1 — Expenses of Administration

Cal. Prob. Code § 11420(a)(1)

Trust track (likely applicable): Statutory probate fees are avoided. Total administration cost estimated at $200K–$500K. Savings vs. probate: ~$1.17M–$2.52M (Cal. Prob. Code § 10810).

CLASS 2 — Funeral Expenses

Cal. Prob. Code § 11420(a)(2)

CLASS 3 — Last Illness / Medical Expenses

Cal. Prob. Code § 11420(a)(3)

CLASS 4 — Family Allowance

Cal. Prob. Code §§ 11420(a)(4), 6540

CLASS 5 — Wage Claims

Cal. Prob. Code § 11420(a)(5)

CLASS 6 — Secured Obligations

Deeds of trust, judgment liens — priority per recording date

CLASS 7 — General / Unsecured Debts (Lowest Priority)

Cal. Prob. Code § 11420(a)(7)

⚕️ MANDATORY CREDITOR NOTICE — MEDI-CAL ESTATE RECOVERY PROGRAM (MERP)

MERP Risk Assessment: 🟢 LOW for this estate. Property is held in the Loma Vista Trust (RLT) and passes outside the probate estate — beyond California's post-2016 probate-only MERP scope. Jan Koum's profile (tech billionaire) makes Medi-Cal benefit receipt extremely unlikely. However, if any probate assets exist (accounts, property not in trust, etc.), DHCS must be notified within 90 days of Letters issuance regardless of expected benefit status. (Sources: MERP Contact Lookup — CA; Cal. Welf. & Inst. Code § 14009.5; DebtSentinel; TitleCleaner)

Solvency Summary

⚠️ Critical gap not captured above: Federal estate tax at 40% on amounts above the 2025/2026 exemption (~$13.99M–$15M per individual; IRC §§ 2001 et seq.) could represent a multi-billion dollar obligation given Jan Koum's reported ~$15B net worth. This estate real property alone at ~$140M–$180M value is a significant component of a potentially massive federal estate tax liability. Portability of DSUE (Deceased Spousal Unused Exclusion) requires timely filing of Form 706.

Section 5 — Document Deficiencies

Trust Instrument — Loma Vista Trust

Pour-Over Will

Durable Power of Attorney (DPOA)

Digital Assets / RUFADAA

Advance Health Care Directive

Section 6 — 30-Action Checklist

Priority Legend: 🔴 Immediate (within 7 days) | 🟠 30-Day | 🟡 90-Day

1. 🔴 Obtain the complete Loma Vista Trust instrument — confirm settlor identity, all co-trustees, trustee authority, succession provisions, and beneficiary designations (Cal. Prob. Code §§ 15620, 16060)
2. 🔴 Identify and confirm the second co-trustee whose identity is truncated in public records — no conveyance or encumbrance can proceed without full trustee panel confirmed
3. 🔴 Search the LA County Registrar-Recorder/County Clerk for any mechanics lien, claim of lien, or instrument recorded by "Ortiz," "Ortiz Consulting LLC," or Rita Cedeno Ortiz against APN 4391-036-016 (Cal. Civ. Code § 8416 et seq.; Case No. 26CJCF01311)
4. 🔴 Verify property tax currency — contact LA County Tax Collector directly for both 2025–2026 installments on APN 4391-036-016; confirm no delinquency, penalties, or special assessments (Cal. Rev. & Tax. Code § 2187)
5. 🔴 Confirm trust is fully funded — verify Loma Vista Trust holds the real property as its sole or primary asset and that no pour-over probate proceeding will be required
6. 🔴 Engage federal estate tax counsel immediately — with ~$15B reported net worth, the estate's federal estate tax exposure could be multi-billion dollars at the 40% marginal rate above the ~$15M 2025/2026 exemption (IRC §§ 2001 et seq.)
7. 🔴 Commission an independent MAI appraisal of 1025 Loma Vista Drive — ATTOM AVM returns $0; Prop. 19 formula, federal estate tax basis, and all creditor analyses depend on a defensible date-of-death FMV (Cal. Rev. & Tax. Code § 63.1; IRC § 2031)
8. 🔴 Confirm whether settlor DPOA contains express durability language per Cal. Prob. Code § 4124 — absence of durability language means the POA terminates on incapacity, precisely when $134M asset management requires it
9. 🟠 Pull the complete chain of title from the LA County Registrar-Recorder for APN 4391-036-016 — confirm 2020 deed grantor, all intermediate deeds, and absence of any intervening conveyances or clouds on title (Cal. Gov. Code § 27201)
10. 🟠 Search LA County Recorder for any IRS Notice of Federal Tax Lien (NFTL) against the settlor/trustee and any FTB Notice of State Tax Lien — these are senior to general creditors if present
11. 🟠 Search LA County Superior Court index for any abstract of judgment recorded against the settlor, the Loma Vista Trust, or any trustee — abstracts become judgment liens upon recording (Cal. C.C.P. § 697.310)
12. 🟠 Contact DHCS Medi-Cal Estate Recovery Program within 90 days of Letters issuance: (916) 650-0490, DHCS Estate Recovery Unit, MS 4720, P.O. Box 997425, Sacramento, CA 95899-7425 — required even if risk is low (Cal. Welf. & Inst. Code § 14009.5)
13. 🟠 Search the California Secretary of State UCC index for any fixture filing against this property address/APN — relevant to solar, HVAC, or other permanent equipment financing (Cal. Com. Code § 9502 et seq.)
14. 🟠 Contact LA County Tax Collector to confirm no PACE/HERO/Ygrene/CaliforniaFIRST special assessment lien exists against APN 4391-036-016 — PACE liens are super-priority and survive sale (Cal. Sts. & Hwys. Code § 5898.24)
15. 🟠 Confirm Trousdale Estates / Doheny Ranch Tract No. 21360 HOA status — determine if an active HOA governs this parcel, obtain assessment ledger, and confirm no delinquent assessments (Cal. Civ. Code §§ 5650–5740)
16. 🟠 Determine community property or separate property characterization of the August 2020 acquisition — if Koum was married at time of purchase, express trust declaration of CP character is required to preserve double step-up in basis at first death (Cal. Fam. Code § 760; IRC § 1014(b)(6))
17. 🟠 Review the Loma Vista Trust for RUFADAA authorization — confirm the instrument expressly grants the trustee access to digital assets, including self-custodied cryptocurrency wallets and online accounts (Cal. Prob. Code §§ 870–884)
18. 🟠 Inventory all digital and crypto assets — Jan Koum's profile (WhatsApp co-founder, Meta equity) creates probable nine-figure digital asset exposure; enumerate and secure all relevant private keys, seed phrases, and digital account credentials
19. 🟠 Confirm existence and execution-compliant status of pour-over will — verify 2 simultaneous witnesses who understood the instrument was a will; confirm no interested witness issues (Cal. Prob. Code §§ 6110(c)(1), 6112(c))
20. 🟠 Search for mineral, oil-gas, and water right reservations in the complete Doheny Ranch chain of title — historic Doheny family oil operations create plausible mineral reservation risk in this tract (Cal. Civ. Code § 1091)
21. 🟠 Order a title insurance commitment (CLTA/ALTA) from a California-licensed title company — mechanical and comprehensive lien search as a pre-condition to any conveyance or encumbrance of the property
22. 🟠 Confirm existence of an Advance Health Care Directive for the settlor — critical for a high-value estate with an opaque incapacity succession plan (Cal. Prob. Code § 4701)
23. 🟡 Develop a Proposition 19-compliant intergenerational transfer strategy — no homeowner's exemption is filed; any transfer to a non-occupying heir guarantees full reassessment to FMV, potentially adding $150K–$600K/year in carrying costs (Cal. Rev. & Tax. Code § 63.1, eff. Feb. 16, 2021)
24. 🟡 If any beneficiary intends to claim the Prop. 19 parent-child exclusion, document primary residence intent now and ensure occupancy and homeowner's exemption filing occur within 1 year of transfer (Cal. Rev. & Tax. Code § 63.1)
25. 🟡 Audit trust liquidity provisions — confirm the trust has sufficient liquid assets to service $1,613,267/year in property taxes, trustee compensation, and administration costs without requiring a forced sale of the property
26. 🟡 Evaluate Deceased Spousal Unused Exclusion (DSUE) portability — if settlor is/was married, timely filing of IRS Form 706 is required to preserve portability of any unused federal exemption for the surviving spouse (IRC § 2010(c))
27. 🟡 Confirm no Revocable Transfer-on-Death Deed was recorded against this parcel prior to the August 12, 2020 trust transfer — a conflicting TOD deed could cloud title (Cal. Prob. Code §§ 5614–5696)
28. 🟡 Analyze trustee conflict-of-interest issues — Dennis B. Ellman's dual role as attorney and co-trustee for a $134M+ client asset requires documented informed consent analysis under Cal. Rules of Professional Conduct Rule 1.7
29. 🟡 Once trust instrument is obtained, deliver required Cal. Prob. Code § 16061.7 notices — trustee must notify all qualified beneficiaries and heirs within 60 days of settlor's death; clock begins at date of death, not date of discovery
30. 🟡 Engage Beverly Hills / Los Angeles luxury estate specialist to monitor the 2025/2026 ballot initiative seeking to reinstate broader Prop. 19 reassessment exclusions — a successful ballot measure could materially change the intergenerational transfer calculus for this property

Section 7 — Attorney Action Items

Priority 1 — Immediate (Before Any Estate Action)

A. Obtain and Review the Loma Vista Trust Instrument

• Statutory basis: Cal. Prob. Code §§ 15620 (co-trustee unanimity), 16060 (duty to inform), 16061.7 (beneficiary notification within 60 days of settlor's death)
• Action: Contact Greenberg Glusker Fields Claman & Machtinger LLP; request complete trust instrument, all amendments, and any co-trustee designation agreements. No distribution, conveyance, or fiduciary action is defensible without the instrument.

B. Title Clearance — Ortiz Consulting Fraudulent Lien Search

• Statutory basis: Cal. Civ. Code § 8416 et seq. (mechanics lien claims); Cal. Penal Code § 115 (recording false instruments)
• Action: File a direct public records request at the LA County Registrar-Recorder/County Clerk for all instruments recorded by "Ortiz," "Ortiz Consulting LLC," or any variant against APN 4391-036-016. If a fraudulent lien is found, immediately file a petition for expedited release under Cal. Civ. Code § 8480 (petition to release lien) and/or bond over the lien. Reference active DA case No. 26CJCF01311 in any release application.

C. Federal Estate Tax Counsel Engagement

• Statutory basis: IRC §§ 2001 et seq. (federal estate tax); IRC § 2010(c) (DSUE portability — Form 706 deadline: 9 months from date of death, extendable 6 months)
• Action: Engage a California-licensed estate tax attorney with ultra-high-net-worth experience. At a reported ~$15B net worth with a 40% marginal rate above the ~$15M exemption, the gross federal estate tax exposure could exceed $5.99 billion. Immediate analysis of existing estate tax reduction structures (GRATs, SLATs, charitable vehicles, QPRTs, valuation discount strategies) is essential.

Priority 2 — Within 30 Days

D. DPOA Durability Cure

• Statutory basis: Cal. Prob. Code § 4124 — express durability language is mandatory; California POAs are NOT durable by default
• Action: If settlor is living, immediately confirm existing DPOA contains express durability language. If not, execute a new Durable Power of Attorney before any incapacity event. Without it, a costly and time-consuming Superior Court conservatorship proceeding would be required to manage the $134M+ trust asset.

E. Community Property Characterization

• Statutory basis: Cal. Fam. Code § 760 (CP presumption for property acquired during marriage); IRC § 1014(b)(6) (full double step-up for CP at first death)
• Action: Determine marital status at time of August 2020 acquisition. If married, confirm the Loma Vista Trust contains an express CP declaration. The cost of failure — full step-up not available on the surviving spouse's half of a $150M+ asset — could represent tens of millions in capital gains tax exposure when the property is ultimately sold.

F. RUFADAA Authorization

• Statutory basis: Cal. Prob. Code §§ 870–884 (RUFADAA, eff. Jan. 1, 2017)
• Action: Review trust and pour-over will for express RUFADAA authorization language. Given Jan Koum's profile (WhatsApp co-founder, Meta equity, probable cryptocurrency holdings), failure to authorize fiduciary digital access could render nine-figure digital assets inaccessible. If authorization is absent, amend the trust to expressly include RUFADAA fiduciary access language and maintain secure digital asset inventory with estate counsel.

G. Property Tax Verification and Lien Searches

• Statutory basis: Cal. Rev. & Tax. Code § 2187 (property tax super-lien); Cal. C.C.P. § 697.310 (judgment lien on real property)
• Action: (1) Contact LA County Tax Collector directly — verify both 2025–2026 installments current; confirm no PACE special assessment against APN 4391-036-016. (2) Search LA County Recorder for IRS NFTL and CA FTB tax liens. (3) Search LA County Superior Court for any abstract of judgment. (4) Notify DHCS MERP at (916) 650-0490 within 90 days of Letters issuance if any probate assets exist (Cal. Welf. & Inst. Code § 14009.5).

Priority 3 — Within 90 Days

H. Independent MAI Appraisal

• Statutory basis: IRC § 2031 (FMV at date of death); Cal. Rev. & Tax. Code § 63.1 (Prop. 19 formula uses FMV)
• Action: Commission a state-certified general appraiser (MAI designation preferred) with specific Beverly Hills/Trousdale Estates ultra-luxury experience. The appraisal must be defensible for federal estate tax purposes and for the Prop. 19 partial reassessment calculation. No automated valuation model is available for this asset class.

I. Proposition 19 Transfer Strategy

• Statutory basis: Cal. Rev. & Tax. Code § 63.1 (eff. Feb. 16, 2021); Cal. Const. Art. XIII A § 2
• Action: Advise all trust beneficiaries that: (a) no homeowner's exemption is currently filed, meaning the property is not the beneficial owner's primary residence; (b) any transfer to a non-occupying heir, sub-trust, or entity guarantees full reassessment to FMV, adding approximately $150K–$600K/year in additional property tax; (c) a qualifying child-beneficiary must occupy as their primary residence within 1 year of transfer and file for the homeowner's exemption to obtain even partial exclusion; and (d) the partial exclusion formula still applies a partial reassessment for FMV exceeding current assessed value plus $1,000,000 (New Taxable Value = Existing Taxable Value + [FMV – $1,000,000 – Existing Taxable Value]).

J. Full Chain-of-Title and Mineral Rights Search

• Statutory basis: Cal. Gov. Code § 27201 (county recorder records); Cal. Civ. Code § 1091 (conveyance of mineral interests)
• Action: Order a full CLTA/ALTA title search through a California-licensed title company. Specifically direct the title officer to search for: (1) any mineral, oil-gas, or water right reservations originating from the historical Doheny family subdivisions of this tract; (2) any UCC fixture filings; (3) any HOA CC&Rs and assessment ledger for Trousdale Estates / Doheny Ranch Tract No. 21360; (4) any TOD deed recorded prior to August 12, 2020.

All statute citations in this briefing are California law. No Arizona, Nevada, Texas, or other jurisdiction statutes have been cited. All citations verified against the California Estate Planning Source of Truth (RAG, April 3, 2026), MERP Contact Lookup (CA), ATTOM (APN 4391-036-016, FIPS 06037), and agent findings from WillGuardian, DebtSentinel, TitleCleaner, and the Cross-Agent Correlation Report.

This briefing is for informational purposes only and does not constitute legal advice. AI-generated analysis should be independently verified by a licensed attorney.