Plaintiffs Accuse Family Members Of Fraudulent Transfer Inheritance Dispute

Santa Clara County Superior Court
Santa Clara County Superior Court
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In a compelling legal battle, two daughters have taken to the courts to reclaim what they allege was fraudulently taken from their late father’s estate. Kelly Gamboa and Pamela J. Zopf filed a complaint in the Superior Court of California, County of Santa Clara, on February 23, 2026, against Wendy Rico, Fabian Martinez, and Alexis Uriel Martinez Olmos. The plaintiffs are seeking to set aside a voidable transaction involving a valuable family asset.

The case centers around the estate of John Ramirez Bueno, who passed away intestate on May 16, 2024. At the heart of the dispute is a manufactured home located at 510 Saddle Brook Drive in San Jose, California. This property was owned by John and his late wife Susan Lynn Bueno and is now claimed by their heirs under intestate succession laws. According to the complaint, after John’s death, his daughter Pamela attempted to transfer the title of this mobile home into her name on behalf of all heirs. However, she discovered that it had already been transferred fraudulently by her niece Wendy Rico.

The plaintiffs allege that Rico forged her mother’s signature—Wendy Torres (also known as Wendy Bueno)—to gain title to the mobile home without any consideration. This fraudulent transfer occurred on October 23, 2024. The complaint further states that Rico sold the mobile home for a mere $20,000 to defendants Fabian Martinez and Alexis Uriel Martinez Olmos in January 2025 despite its fair market value being approximately $350,000 at that time.

Kelly Gamboa and Pamela J. Zopf accuse Rico of intentionally hindering their rightful inheritance through deceitful means and claim that Martinez and Olmos were complicit in this conspiracy due to their knowledge of the undervalued sale price. As a result of these actions, they assert damages based on their proportionate share as heirs and seek significant financial compensation.

The plaintiffs are demanding several forms of relief from the court: setting aside both fraudulent transfers; general damages amounting to $500,000; special damages according to proof; punitive damages also totaling $500,000; costs incurred during litigation; an order declaring defendants hold ownership in trust for them; accounting for profits derived from or exchanged for said property; temporary restraining orders preventing further disposition or alteration regarding ownership status until resolution is reached within judicial proceedings themselves—all aimed at restoring justice concerning what they believe was unlawfully taken away from them.

Representing Kelly Gamboa and Pamela J. Zopf is attorney Gary W. Sullivan while Judge/Commissioner presides over Case No:26CV487627 filed under unlimited civil jurisdiction category where amount demanded exceeds $35k threshold mark set forth therein statute books governing such matters across state lines nationwide today!

Source: 26CV487627_Kelly_Gamboa_v_Wendy_Rico_Complaint_County_of_Santa_Clara_California.pdf


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