SIMON BERNSTEIN IRREVOCABLE
INSURANCE TRUST DTD 6/21/95,
by Ted S. Bernstein, its Trustee, Ted S.
Bernstein, an individual,
Pamela B. Simon, an individual,
Jill Iantoni, an individual and Lisa S.
HERITAGE UNION LIFE INSURANCE COMPANY
Kernals of TRUTH, WoW. Massive Fraud, Forgery, and putting the Eliot Bernstein Family under extreme and unnecessary duress. Oh and BREAKING THE LAW. I would say it's more than a "kernal" of truth.
Shirley Bernstein Estate Case Docket
Simon Bernstein Estate Case Docket
Policy proceeds are being brought in good faith, and are well grounded in fact and law. One of
the most important facts being that the Simon Bernstein Irrevocable Insurance Trust Dtd
6/21/1995 was actually named a beneficiary of the Policy proceeds pursuant to the Policy. (See
Beneficiary Designation attached to Adam Simon’s affidavit as Exhibit “A”, bates #BT000029-
030). ELIOT’s purported claims made either on his own behalf or that of his children fail to
include reference to any document recorded with the Insurer naming ELIOT, ELIOT’s children,
or any of Simon Bernstein’s grandchildren as beneficiaries of the Policy.
Most importantly, however, I shall demonstrate in this memorandum that ELIOT has
failed to assert any facts showing that a conflict exists with regard to my representation of my
clients in this case. Neither has ELIOT provided any factual record showing the existence of a
conflict or any misconduct on my part."