Declaration of Sandra Will in Support of Amended Petition for Ancillary Proceeding (Will-Darnall)

Summary

In this declaration supporting her amended petition, Sandra Will states that Cassie Will-Darnall is her daughter and only child. She states that she and her husband Robert Will bought the Almaden house in 1991, that she has lived there full time since 1995, and that she became sole owner after Robert Will died in 2005. She describes giving Cassie money, funded by a Bank of America home equity line of credit of approximately $500,000 and a later loan, to buy out an ex's share of the Belwood house and pay off its mortgage. She states that Cassie signed a promissory note, sent monthly checks of approximately $4,600 from January 2018 to March 2020, and in May 2020 sent a check covering the balance. Sandra Will states she would not accept money she knew had been obtained by fraud. It is executed November 11, 2025.

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“Declaration of Sandra Will in Support of Amended Petition for Ancillary Proceeding (Will-Darnall).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-104-1-5881780c9a/, SHA-256 c4cdb9c2e99336a088402a9f92ce27e25e67f8e96a6588e22af853f88f815225.

Full text

Case 5:24-cr-00292-PCP Document 104-1 Filed 11/11/25 Page 1 of 4

1 MOEEL LAH FAKHOURY LLP
Hanni M. Fakhoury (State Bar No. 252629)
2 2006 Kala Bagai Way, Suite 16
Berkeley, CA 94704
3 Telephone: (510) 500-9994
Email: hanni@mlf-llp.com
4

5 Attorneys for Third Party Claimant Sandra Will

7 IN THE UNITED STATES DISTRICT COURT
8 FOR THE NORTHERN DISTRICT OF CALIFORNIA
9 SAN JOSE DIVISION
10

11 UNITED STATES OF AMERICA, Case No.: 5:24-CR-00292-PCP

12 Plaintiff, DECLARATION OF SANDRA WILL IN
SUPPORT OF AMENDED PETITION
13 v. FOR ANCILLARY PROCEEDING
14 CASSIE WILL-DARNALL,

15 Defendant.

17 SANDRA WILL,

18 Third Party Claimant.

20 I, Sandra Will, hereby declare as follows:
21 1. I am making the declaration of my own free will and based on my best knowledge and
22 recollection.
23 2. I am 86 years old and a retired public school teacher.
24 3. The defendant in this criminal case, Cassie Will-Darnall, is my daughter and only child.
25 4. In 1991, my husband, Robert Will, who was also a public school teacher, and I purchased
26 the home at 306 Los Gatos Almaden Way, Los Gatos, CA 95032, Santa Clara County, APN
27 527-46-002.
28

AMENDED DECLARATION OF SANDRA WILL
United States v. Will-Darnall, 5:24-CR-00292-PCP
1
Case 5:24-cr-00292-PCP Document 104-1 Filed 11/11/25 Page 2 of 4

1 5. We originally rented the house to tenants after we bought it. In 1995, we moved into the
2 house and I have lived there full time since.
3 6. Since Robert and I purchased the home, it has always been under our control. We have
4 never sold the house, though we did change the title a few times.
5 7. In 1995, we changed the title to put the house in the name of a trust we established.
6 8. In 2004, I am informed that the title was placed in the name of a company called Westward
7 Properties, Inc. for about a month. I do not have any memory or recollection of why the title
8 was changed or what Westward Properties was.
9 9. At some point, the title was placed back in the name of Robert and I in 2004.
10 10. Robert passed away in 2005; after his death, I became the sole owner and title holder of the
11 house.
12 11. In 2012, Cassie got married. She and her then-wife purchased a home at 111 Belwood
13 Gateway, Los Gatos CA 95032, Santa Clara County, APN 527-31-019.
14 12. Cassie, her then-wife, and their child—my grandson—lived in that house after it was
15 purchased.
16 13. In 2016, Cassie and her wife separated. In the separation, I was told that Cassie and her ex
17 agreed that Cassie would get the house and buy out her ex’s share of the home.
18 14. At the time of the divorce proceedings, Cassie asked me to help her buy out her ex’s share
19 of the home at Belwood Gateway.
20 15. Sometime in April or May 2016, I can’t remember exactly when, I took out a home equity
21 line of credit (“HELOC”) of approximately $500,000 from Bank of America secured by my
22 Los Gatos Almaden home.
23 16. I gave about $550,000 to obtain the equity in the Belwood Gateway house; I believe
24 $400,000 came from the HELOC and $150,000 came from cash I had saved. Cassie gave
25 the money to her ex to buy out her share of the house at Belwood Gateway. I cannot find
26 records that show the exact amount paid, or how I gave Cassie the money to pay her ex.
27 17. Sometime later, I learned Cassie may have refinanced the mortgage on the house at
28 Belwood Gateway and took out a loan in her name alone.

AMENDED DECLARATION OF SANDRA WILL
United States v. Will-Darnall, 5:24-CR-00292-PCP
2
Case 5:24-cr-00292-PCP Document 104-1 Filed 11/11/25 Page 3 of 4

1 18. In January 2018, I applied for a $1 million loan with Bank of America, to pay off the loan
2 Cassie had taken on the Belwood Gateway house. The bank issued me a loan secured by
3 my Los Gatos Almaden home.
4 19. Before I received any proceeds from the $1 million loan, Bank of America repaid the
5 HELOC, which by then had a balance of approximately $488,000. Bank of America also
6 repaid another loan I had on another property I owned with a balance of approximately
7 $163,000. Bank of America ended up giving me approximately $348,000 in cash. I gave
8 that cash, along with other money I had saved, to Cassie to pay off the existing loan on the
9 Belwood Gateway property and the title was transferred to me.
10 20. In all, I gave Cassie well over $1 million: I bought out her ex’s share of the Belwood
11 Gateway house and then paid off her remaining mortgage balance on that same property.
12 21. To document the multiple loans I made to Cassie, she signed a promissory note in the
13 amount of $1 million. We agreed that she would make rent payments roughly equal to the
14 amount I had to pay Bank of America monthly. She also placed a deed of trust on the
15 Belwood Property.
16 22. From January 2018 to March 2020, Cassie sent me a check every month of approximately
17 $4,600, which was roughly what I had to pay Bank of America every month for the $1
18 million loan. In essence, Cassie was my tenant and I was her landlord.
19 23. Cassie lives at the house in 111 Belwood Gateway to this day. Because she splits custody of
20 her son with her ex, my grandson also lives at 111 Belwood Gateway at least part of the
21 time.
22 24. In May 2020, Cassie sent me a check that covered the outstanding balance on the Bank of
23 America loan. I asked her where she got the money and she told me she got a loan. I did not
24 ask her any further questions about it.
25 25. I have since learned that Cassie obtained money through fraud. It is an understatement to
26 say how deeply disappointed and mad I am at Cassie for that foolish decision.
27 26. I would not accept money from Cassie, or anyone else, that I knew had been obtained by
28 fraud or other criminal activity.

AMENDED DECLARATION OF SANDRA WILL
United States v. Will-Darnall, 5:24-CR-00292-PCP
3
Case 5:24-cr-00292-PCP Document 104-1 Filed 11/11/25 Page 4 of 4

1 I declare under penalty of perjury that the foregoing is true and correct to the best of my
2 knowledge.
3 Executed on November 11, 2025, in Los Gatos, California.
4

5 /s Sandra Will
SANDRA WILL
6

AMENDED DECLARATION OF SANDRA WILL
United States v. Will-Darnall, 5:24-CR-00292-PCP
4

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