Declaration of Sandra Will (Document 65-1)

Summary

In Document 65-1, filed 06/06/25, Sandra Will declares that defendant Cassie Will-Darnall is her daughter and only child. She states that she and her husband bought the Almaden home in 1991 and she has lived there since 1995. She says she took out a home equity line of credit of approximately $500,000 secured by that home, then applied in January 2018 for a $1 million Bank of America loan to pay off the loan on the Belwood house. She says her daughter signed a promissory note for $1 million, paid about $4,600 a month from January 2018 to March 2020, and sent a check in May 2020 covering the balance. She says she later learned her daughter obtained money through fraud.

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“Declaration of Sandra Will (Document 65-1).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-65-1-3d1dc15a3b/, SHA-256 cdf2e51733163db0b42ead6fa4bb45f83525f27ef4bb408328eb3904a79d7fc5.

Full text

Case 5:24-cr-00292-PCP Document 65-1 Filed 06/06/25 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

13 v.

14 CASSIE WILL-DARNALL,

15 Defendant.

17 I, Sandra Will, hereby declare as follows:
18 1. I am making the declaration of my own free will and based on my best knowledge and
19 recollection.
20 2. I am 86 years old and a retired public school teacher.
21 3. The defendant in this criminal case, Cassie Will-Darnall, is my daughter and only child.
22 4. In 1991, my husband, Robert Will, who was also a public school teacher, and I purchased
23 the home at 306 Los Gatos Almaden Way, Los Gatos, CA 95032, Santa Clara County, APN
24 527-46-002.
25 5. We originally rented the house to tenants after we bought it. In 1995, we moved into the
26 house and I have lived there full time since.
27 6. Since Robert and I purchased the home, it has always been under our control. We have
28 never sold the house, though we did change the title a few times.

DECLARATION OF SANDRA WILL
United States v. Will-Darnall, 5:24-CR-00292-PCP
1
Case 5:24-cr-00292-PCP Document 65-1 Filed 06/06/25 Page 2 of 4

1 7. In 1995, we changed the title to put the house in the name of a trust we established.
2 8. In 2004, I am informed that the title was placed in the name of a company called Westward
3 Properties, Inc. for about a month. I do not have any memory or recollection of why the title
4 was changed or what Westward Properties was.
5 9. At some point, the title was placed back in the name of Robert and I in 2004.
6 10. Robert passed away in 2005; after his death, I became the sole owner and title holder of the
7 house.
8 11. In 2012, Cassie got married. She and her then-wife purchased a home at 111 Belwood
9 Gateway, Los Gatos CA 95032, Santa Clara County, APN 527-31-019.
10 12. Cassie, her then-wife, and their child—my grandson—lived in that house after it was
11 purchased.
12 13. In 2016, Cassie and her wife separated. In the separation, I was told that Cassie and her ex
13 agreed that Cassie would get the house and buy out her ex’s share of the home.
14 14. At the time of the divorce proceedings, Cassie asked me to help her buy out her ex’s share
15 of the home at Belwood Gateway.
16 15. Sometime in April or May 2016, I can’t remember exactly when, I took out a home equity
17 line of credit (“HELOC”) of approximately $500,000 from Bank of America secured by my
18 Los Gatos Almaden home.
19 16. I gave about $550,000 for Cassie to obtain the equity in the Belwood Gateway house; I
20 believe $400,000 came from the HELOC and $150,000 came from cash I had saved. Cassie
21 gave the money to her ex to buy out her share of the house at Belwood Gateway. I cannot
22 find records that show the exact amount paid, or how I gave Cassie the money to pay her
23 ex.
24 17. Sometime later, I learned Cassie may have refinanced the mortgage on the house at
25 Belwood Gateway and took out a loan in her name alone.
26 18. In January 2018, I applied for a $1 million loan with Bank of America, to pay off the loan
27 Cassie had taken on the Belwood Gateway house. The bank issued me a loan secured by
28 my Los Gatos Almaden home.

DECLARATION OF SANDRA WILL
United States v. Will-Darnall, 5:24-CR-00292-PCP
2
Case 5:24-cr-00292-PCP Document 65-1 Filed 06/06/25 Page 3 of 4

1 19. Before I received any proceeds from the $1 million loan, Bank of America repaid the
2 HELOC, which by then had a balance of approximately $488,000. Bank of America also
3 repaid another loan I had on another property I owned with a balance of approximately
4 $163,000. Bank of America ended up giving me approximately $348,000 in cash. I used
5 that cash, along with other money I had saved, to Cassie to pay off the existing loan on the
6 Belwood Gateway property and the title was transferred to me.
7 20. In all, I lent Cassie well over $1 million: I bought out her ex’s share of the Belwood
8 Gateway house and then paid off her remaining mortgage balance on that same property.
9 21. To document the loan I made to Cassie, she signed a promissory note in the amount of $1
10 million. We agreed that she would pay the loan in installments equal to the amount I had to
11 pay Bank of America monthly. She also placed a deed of trust on the Belwood Property as
12 security for the loan.
13 22. From January 2018 to March 2020, Cassie sent me a check every month of approximately
14 $4,600, which was roughly what I had to pay Bank of America every month for the $1
15 million loan. Because there was no formal mortgage on the Belwood Gateway property, in
16 essence, Cassie was my tenant and I was her landlord.
17 23. Cassie lives at the house in 111 Belwood Gateway to this day. Because she splits custody of
18 her son with her ex, my grandson also lives at 111 Belwood Gateway at least part of the
19 time.
20 24. In May 2020, Cassie sent me a check that covered the outstanding balance on the Bank of
21 America loan. I asked her where she got the money and she told me she got a loan. I did not
22 ask her any further questions about it.
23 25. I have since learned that Cassie obtained money through fraud. It is an understatement to
24 say how deeply disappointed and mad I am at Cassie for that foolish decision.
25 26. I would not accept money from Cassie, or anyone else, that I knew had been obtained by
26 fraud or other criminal activity.
27

DECLARATION OF SANDRA WILL
United States v. Will-Darnall, 5:24-CR-00292-PCP
3
Case 5:24-cr-00292-PCP Document 65-1 Filed 06/06/25 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 June 6, 2025, in Los Gatos, California.
4

5 /s Sandra Will
SANDRA WILL
6

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

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