SURROGATES COURT OF THE STATE OF NEW YORK

COUNTY OF KINGS
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Probate Proceeding

File No. :
OBJECTIONS TO
PROBATE

Will of THEODORE VLAHAKIS

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The answer of DONNA VLAHAKIS aka DONNA VLAHAKIS HANNA, pro se
interested as a distributee in property disposed of or affected by the paper writing offered
for probate as the last will of THEODORE VLAHAKIS, the above-named decedent,
respectfully shows to this court, upon information and belief:
FIRST: That the alleged will was not duly executed by the said THEODORE
VLAHAKIS, deceased, that he did not publish the same as his will in presence of the
witnesses whose names are subscribed thereto, that he did not request the said two
witnesses to be witnesses thereto, and that the alleged witnesses did not sign as witnesses
in his presence or in the presence of each other.
SECOND: That said signature of THEODORE VLAHAKIS, deceased, was altered in
that some part was scratched out.
THIRD: The signature, last name, is written in cursive and the first name is in print. The
signature was altered and is not the signature of THEODORE VLAHAKIS, deceased.
FOURTH: That the said paper writing was not freely or voluntarily made or executed
by the said THEODORE VLAHAKIS, as his last will and testament, but that the said
paper writing purporting to be his will was obtained and the subscription and publication
thereof if it was in fact subscribed or published by him, were procured by fraud and
undue influence practiced upon the decedent by a person or persons acting in concert or

privity with them, whose name or names are at the present time unknown to these
contestants.
FIFTH: That the name "Zinovia" is incorrectly spelled and THEODORE
VLAHAKIS, deceased was aware of the correct spelling of his wife, Zenovia's name.
SIXTH: That provisions THIRD and FOURTH of the propounded instrument,
purporting to give the entire estate to "Zinovia" Vlahakis was the product of undue
influence exercised by the aforesaid persons and/or others acting in concert with them or
on their behalf.
SEVENTH: That provision SEVENTH of the propounded instrument, purporting to
nominate, constitute and appoint "Zinovia" Vlahakis as Executrix person in a
confidential relationship to the decedent, was the product of undue influence exercised by
the aforesaid person or others acting in concert with her or on her behalf.
EIGHTH: That by reason thereof the said FOURTH, THIRD, and SEVENTH will
provisions do not form part of the decedents will, should be held inoperative and should
be excised therefrom (if said instrument is otherwise admitted to probate).
A trial by jury of the issues raised by this answer is hereby demanded.
WHEREFORE, the above-named contestants pray that this proceeding may be
dismissed, with attorney fees and costs.

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DONNA VLAHAKIS, PRO SE
7504 Fifth Avenue
Brooklyn, New York 11209
Tel: (718) 680-8400

INDIVIDUAL VERIFICATION
STATE OF NEW YORK
COUNTY OF KINGS

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DONNA VLAHAKIS, PRO SE, being duly sworn, deposes and says:
I am the Objectant in the within action. I have read the Objections and know the contents
thereof. The contents of the Objections are true to my own knowledge, except as to those
matters therein stated to be alleged upon information and belief, and as to those matters I
believe them to be true.

_________________________
DONNA VLAHAKIS, PRO SE
Sworn to before me July 30, 2015

NOTARY PUBLIC