The Law Offices of Robert P. Bergman serves Stallion Springs and the surrounding Kern County communities with practical, client-focused estate planning services. Our approach centers on understanding family goals, protecting assets, and creating clear, enforceable documents such as revocable living trusts, wills, powers of attorney, and healthcare directives. We help clients navigate California rules and timelines while keeping communication straightforward. This guide explains the common estate planning tools, differences between limited and comprehensive strategies, and when each approach may fit your situation. Contact our office in San Jose at 408-528-2827 for a consultation tailored to your needs.
Estate planning can feel overwhelming, but thoughtful preparation brings peace of mind and effective protection for loved ones. Our firm assists Stallion Springs residents with trust administration, pour-over wills, pet trusts, special needs planning, and trust modification petitions when circumstances change. We focus on creating documents that reflect your priorities while minimizing future disputes and administrative burdens. Whether you are updating existing documents or starting a new plan, we outline options in clear terms, explain likely costs and timelines, and provide practical steps so you can make informed decisions for your family and assets.
A well-crafted estate plan preserves your wishes, streamlines asset transfers, and reduces the stress families face after a death or incapacity. In California, comprehensive planning can help avoid probate delays, protect minor children, and ensure incapacity plans are in place for financial and healthcare decision-making. Using trusts and related documents can also provide privacy and smoother administration compared with probate court proceedings. For Stallion Springs residents, having these plans in place means loved ones can focus on healing rather than resolving legal or financial complications, and that your intentions are respected and enforceable under state law.
The Law Offices of Robert P. Bergman provides estate planning services across California with a focus on clear communication and practical solutions. Our team prepares revocable living trusts, wills, powers of attorney, and health care directives, and assists with trust funding, trust administration, and modifications. We prioritize understanding each client’s family dynamics and financial picture to design plans that minimize conflict and administrative burden. Our approach balances legal requirements with real-world considerations so Stallion Springs clients have reliable, understandable plans that protect their interests and those of their loved ones.
Estate planning involves arranging your affairs so your property, finances, and personal care are handled according to your wishes if you become incapacitated or after you pass away. Common components include a revocable living trust to manage assets during life and after death, a last will and testament to address any assets outside the trust, financial powers of attorney for managing money and property, and advance health care directives to designate medical decision-makers. Additional tools such as special needs trusts and pet trusts address particular family circumstances and ensure continued care aligned with your intentions.
The planning process also covers related filings and actions like creating certification of trust documents for financial institutions, drafting pour-over wills that funnel assets into a trust, and preparing HIPAA authorizations to allow medical record access for appointed agents. For clients with life insurance or retirement accounts, irrevocable life insurance trusts and retirement plan trusts can preserve benefits and help with tax or distribution considerations. Each element is tailored to the client’s assets, family structure, and goals so that the final plan functions smoothly when needed.
Each estate planning document serves a distinct purpose. A revocable living trust holds and manages assets during your lifetime and provides instructions for distribution after death without the need for probate. A last will and testament names guardians for minor children, disposes of any assets not placed in a trust, and can clarify final wishes. Financial powers of attorney designate someone to manage finances and property if you cannot, while advance health care directives name a person to make medical decisions and state your treatment preferences. Together, these documents create a coordinated plan for incapacity and after-death administration.
Creating an effective estate plan involves inventorying assets, naming beneficiaries and fiduciaries, choosing trustees and agents, and preparing clear written documents. Funding a trust by retitling accounts and updating beneficiary designations is an important step to ensure assets are governed by the trust. Regular reviews are needed after life events such as marriage, divorce, births, deaths, or significant changes in finances. When circumstances change, trust modifications or filing petitions such as Heggstad or trust modification petitions may be necessary to address transfer issues or correct technical problems.
Understanding common estate planning terms helps you make informed choices. This glossary summarizes important concepts used throughout the planning process, from documents like revocable living trusts and pour-over wills to procedural terms such as probate and trust administration. Clear definitions remove ambiguity and help you compare options. If a term remains unclear, our team can explain how it applies to your circumstances and suggest the most appropriate documents and strategies to meet your goals while following California law and local court practices.
A revocable living trust is a legal arrangement where a person transfers ownership of assets into a trust during life, designates a trustee to manage those assets, and sets rules for distribution after death. Because it is revocable, the creator retains control and can modify or revoke the trust while alive. Properly funded trusts can avoid probate, maintain privacy, and allow for continuous management if the creator becomes incapacitated. Trusts often work alongside pour-over wills and other documents to create a complete estate plan.
A power of attorney is a legal document that appoints an agent to manage financial matters or legal affairs if you are unable to do so. It can be general or limited in scope and becomes effective either immediately or upon a specified event, such as incapacity. Financial powers of attorney ensure bills are paid, investments managed, and property matters are handled without court intervention, while health care directives address medical decision-making and treatment preferences separately but in coordination with financial planning documents.
A last will and testament is a written instrument that expresses how you want property distributed at death, names an executor to administer your estate, and can nominate guardians for minor children. Wills cover assets not included in trusts and provide a clear plan for distribution that the probate court oversees. While wills are a fundamental element of estate planning, combining a will with a funded trust can reduce the probate required for most assets and simplify administration for heirs.
An advance health care directive states your preferences for medical treatment and appoints someone to make health-related decisions if you cannot. A HIPAA authorization allows designated individuals to access medical records, facilitating informed decision-making for your health care agent. Together, these documents ensure that medical providers and family members have the legal authority and necessary information to act in accordance with your wishes, reducing uncertainty during medical crises and ensuring continuity of care.
Choosing between a limited approach and a comprehensive estate plan depends on your assets, family complexity, and long-term goals. A limited plan might consist of basic wills and powers of attorney for someone with modest assets and straightforward family circumstances. A comprehensive plan typically includes trusts, beneficiary coordination, and detailed incapacity planning to address potential tax, creditor, or family issues. This section outlines when a minimal approach may suffice and when a full plan offers protection and administrative advantages that justify the additional planning and funding steps.
A limited estate plan can be appropriate when assets are minimal, ownership and beneficiary designations are straightforward, and family relationships are uncomplicated. In these situations, a will and powers of attorney may adequately address final distributions and incapacity planning without the need for trust funding and ongoing trust administration. Clients in Stallion Springs with basic household assets, retirement accounts with named beneficiaries, and no need for guardianship directives may prefer a simpler plan for cost and administrative ease, while retaining the option to expand the plan as circumstances evolve.
If most assets pass directly to beneficiaries through account beneficiary designations or joint ownership and the estate value is low, probate risks and associated delays may be minimal. A limited plan can address guardianship, medical powers, and basic distribution instructions without the added steps of trust creation and funding. However, even smaller estates can benefit from reviewing beneficiary designations and ensuring documents align, so that the intended recipients receive assets efficiently and without unintended legal obstacles or family disputes.
Comprehensive planning is often advisable when family relationships, asset structures, or beneficiary needs are complex. Examples include blended families, heirs with special needs, significant real estate holdings, business interests, or complicated retirement and insurance arrangements. In these situations, trusts, trust administration planning, and tailored distribution provisions can reduce conflict and ensure continued financial support for designated beneficiaries. A full plan also allows for greater control over timing and conditions of distributions and can address long-term care and incapacity planning more robustly.
A comprehensive plan that includes a funded revocable living trust can avoid probate, preserve privacy, and make administration faster and less costly for heirs. Trusts allow assets to be managed by a successor trustee and distributed according to your instructions without court oversight, which helps maintain confidentiality and reduce public filings. For individuals who value discretion or who want to ease the administrative tasks for family members after death, a full trust-based plan is often the most effective option to streamline transitions and limit the court’s involvement.
A comprehensive, trust-centered plan offers several practical benefits including avoidance of probate for trust assets, continuity of asset management if incapacity occurs, and clearer instructions that reduce family conflict. Trusts can be structured to address specific needs such as long-term care funding, protecting assets from mismanagement, and ensuring continued support for beneficiaries who require oversight. By coordinating beneficiary designations, titles, and trust provisions, the plan can achieve smoother transitions and help family members focus on recovery and remembrance rather than legal hurdles.
Additionally, a comprehensive plan provides flexibility to respond to future changes through modification provisions and review processes. It can include specific provisions like special needs trusts, irrevocable life insurance trusts, or retirement plan trusts to address unique goals or tax considerations. For families in Stallion Springs who own real property, businesses, or accounts across different institutions, a coordinated plan reduces administrative work and avoids common pitfalls that lead to delays or disputes, providing a clearer path for trustees and heirs when the time comes.
One of the primary benefits of a trust-centered plan is the potential to avoid probate for assets properly transferred into the trust. Avoiding probate reduces court involvement, shortens timelines for distribution, and keeps sensitive financial details out of the public record. This can be especially important for families concerned about privacy or who wish to shield asset details from public scrutiny. Trust administration still requires careful documentation, but the trustee can generally carry out distributions according to your instructions without the delays and visibility of probate court proceedings.
A comprehensive plan ensures that someone you trust can manage finances and property if you become incapacitated, without the need for court-ordered conservatorship. Through well-drafted powers of attorney and trust provisions, successor trustees and agents step into their roles seamlessly, pay bills, manage investments, and handle property matters. This continuity helps maintain financial stability, avoid missed payments or lapses in insurance, and protect the value of assets. Clear instructions and updated records make it easier for appointed individuals to act promptly and responsibly on your behalf.
Begin by compiling a thorough inventory of your assets, including real estate, bank and investment accounts, retirement plans, life insurance policies, and business interests. Review and update beneficiary designations on retirement accounts and insurance policies to ensure they match your overall plan. Misaligned beneficiary designations can override wills and trusts, leading to unintended distributions. Keeping an updated list and copies of key documents in a secure place accessible to your designated agents helps avoid delays. Regular reviews after major life events ensure that asset lists and beneficiary choices remain current and effective.
Drafting a trust is only part of the process—funding it by retitling accounts and updating ownership or beneficiary designations is essential for the plan to work as intended. Regularly review and update documents after major changes such as marriage, divorce, births, deaths, or significant financial shifts. Periodic checks ensure that assets align with the trust and that named fiduciaries remain appropriate. Maintaining clear records and providing trusted contacts with access to critical information reduces delays and confusion during administration.
Estate planning protects your family’s financial future and ensures that your wishes are followed regarding asset distribution and medical decisions. For households in Stallion Springs, planning addresses local property ownership, potential real estate transfers, and state-specific requirements for incapacity and probate. Having a coordinated plan minimizes the administrative and emotional burden on loved ones, clarifies responsibilities, and allows you to choose who manages assets and health care decisions. These protections are especially important when adult children, blended families, or heirs with special needs are involved.
Another motivating reason to create or update an estate plan is to reduce the risk of family disputes and court delays after a death. Clear instructions in trusts and wills, designate fiduciaries, and documented powers of attorney help reduce ambiguity that can lead to disagreements. Estate planning also enables you to articulate preferences about funerals, guardianship for minor children, and ongoing care arrangements for dependents or pets. With timely planning, you can preserve your legacy and make transitions easier and more dignified for those you leave behind.
People typically seek estate planning when they experience life events such as marriage, divorce, the birth of a child, acquiring significant property, retirement, or a change in health. Other triggers include starting or selling a business, inheriting assets, or having a beneficiary with special needs. These circumstances make it important to update documents, designate guardians, and ensure beneficiary designations and trust funding reflect current wishes. Addressing these matters proactively reduces the likelihood of unintended consequences and keeps your plan aligned with your evolving priorities.
Marriage and the arrival of children often require revisiting estate plans to include new spouses and to name guardians and trustees for minor children. Without updated documents, state laws may dictate portions of your estate, which can conflict with your intentions. Establishing trust provisions and clear beneficiary designations helps ensure loved ones are provided for according to your wishes. Discussing these changes with a legal advisor ensures that guardianship nominations and asset distribution mechanisms reflect your current family structure and objectives.
Purchasing real estate or experiencing significant changes in assets such as inheritances or investment gains should prompt a review of your estate plan. New property needs to be accounted for in trusts or beneficiary designations to avoid probate or unintended outcomes. Financial changes can affect distribution strategies and may require adjustments to tax planning, trust provisions, or the selection of fiduciaries. Periodic reviews ensure documents remain aligned with your asset profile and that funding steps are completed so the plan functions as intended.
Changes in health or increased risk of incapacity emphasize the importance of advance health care directives, HIPAA authorizations, and durable powers of attorney. These documents empower designated agents to make timely medical and financial decisions aligned with your preferences, reducing the need for court intervention. Addressing incapacity planning early ensures continuity of care and protection of your assets, allowing appointed individuals to act without delay. Clear documentation and conversations with family members help ensure your wishes are understood and followed.
The Law Offices of Robert P. Bergman provides accessible estate planning services tailored to Stallion Springs and Kern County residents. We explain California requirements and practical steps for trust preparation, wills, powers of attorney, and health care directives. Our team works with clients to understand family dynamics, locate necessary documents, and coordinate with financial institutions to fund trusts. If your situation requires petitions such as Heggstad or trust modification petitions, we can guide you through the appropriate proceedings. Our aim is practical, well-documented plans that protect your family and property.
Clients choose the Law Offices of Robert P. Bergman for clear communication, practical planning, and attention to detail. We focus on producing documents that reflect personal goals and anticipate common administrative challenges. From drafting revocable living trusts to preparing pour-over wills and HIPAA authorizations, we tailor plans to your family’s needs and ensure critical steps like trust funding are completed. Our goal is to leave clients with understandable, functional plans that reduce future burdens and provide continuity for managing assets and making health care decisions.
We also assist with trust administration tasks and related filings when a trust becomes active or requires modification. This includes preparing documentation for financial institutions, assisting with trustee transitions, and helping file petitions if issues arise. Whether you need a basic update or a comprehensive plan that includes irrevocable life insurance trusts or special needs provisions, we provide clear guidance about likely timelines and practical steps. We aim to keep the process manageable and supportive for you and your family during decision-making and implementation.
Our office serves clients across California, and we are familiar with the particular considerations that apply to Kern County property and local administration practices. We help clients identify the documents they need, explain funding and titling issues, and recommend updates after major life changes. Communication and responsiveness are central to our service, and we prioritize making the planning process comprehensible and aligned with your priorities so that your family benefits from a durable, thought-out plan when it is needed most.
Our estate planning process begins with a focused consultation to identify assets, family considerations, and planning goals. From there we recommend a tailored set of documents and explain steps for funding trusts or updating beneficiary designations. Draft documents are reviewed and revised until they reflect your intentions, then executed following California signing and witnessing requirements. We provide guidance on storing documents, notifying financial institutions, and next steps for trustee and agent roles. Post-execution reviews are encouraged to keep plans current as life circumstances evolve.
The first step is gathering information about assets, family relationships, beneficiary designations, and any existing estate planning documents. We discuss your goals for distribution, guardianship nominations for minor children, and preferences for incapacity planning. Understanding the full picture allows us to recommend whether a trust, will, or combination of documents best meets your needs. This phase also identifies potential complications such as out-of-state property or tax concerns so that the plan addresses those factors from the outset.
Collecting documents and details includes listing bank accounts, investment accounts, retirement plans, life insurance policies, real property deeds, business interests, and any existing beneficiary forms. We also record contact information for family members, proposed trustees, and agents. A clear inventory helps us design documents that align with your asset ownership and beneficiary choices. This preparation enables us to identify which assets require titling changes or beneficiary updates to make sure your final plan functions as intended without unintended gaps.
During goal-setting we discuss how you want assets distributed, timing preferences for inheritances, and plans for special circumstances such as long-term care or beneficiaries with additional needs. We explore guardianship choices for minor children, pet care arrangements, and whether any trusts should include oversight or staggered distributions. Clear priorities help shape the trust provisions, powers of attorney, and health directives so that documents not only comply with law but also reflect your values and practical concerns for the future.
Once information is collected and goals are clear, we prepare draft documents tailored to your plan. Drafts typically include trusts, wills, powers of attorney, advance health care directives, and any specialized trusts like special needs or pet trusts. We review each document with you to ensure the language accurately reflects your intentions and to make adjustments as needed. This collaborative review process reduces ambiguity and helps ensure that fiduciary roles, distribution instructions, and incapacity provisions are clearly and practically stated.
Trust and will preparation focuses on identifying trustees, successor trustees, beneficiaries, and distribution terms. For trusts, we outline the procedures for managing assets in life and for distributions at death. Pour-over wills are drafted to capture assets not placed into the trust, and certification of trust documents are created to present to institutions without disclosing sensitive details of trust contents. Clear drafting and careful review prevent future misunderstandings and help transactions proceed smoothly after incapacity or death.
Powers of attorney and advance health care directives are drafted to grant authority to trusted agents to make financial and medical decisions when you cannot. We ensure HIPAA authorization language is included so agents can access necessary medical records. Documents specify agent powers, successions, and any limitations you wish to impose. Providing express instructions and designating alternates helps agents act confidently and reduces the need for court intervention in urgent situations, preserving your control over medical and financial affairs.
After documents are finalized, we guide you through execution that meets California signing and witness requirements. For trusts, we assist with funding by retitling accounts, updating beneficiary forms, and preparing certification of trust documents for institutions. Following execution, we recommend storing originals securely and providing copies to trusted agents and advisors. Periodic reviews are important to address life events, changes in law, or shifts in financial situations. Ongoing review ensures the plan continues to accomplish your objectives over time.
Executing documents correctly is essential for their validity. We explain witness and notary requirements and provide checklists to ensure assets are properly retitled into trusts when intended. Funding may involve changing account ownership, transferring deeds, or updating beneficiary designations. We also prepare certification of trust paperwork that financial institutions often request to accept trust authority without seeing sensitive trust details. Proper execution and funding minimize the risk that assets will still need probate or that trustees will face administrative hurdles.
Estate plans should be reviewed after major life events and periodically to ensure they remain aligned with your goals. Changes such as marriage, divorce, births, deaths, or changes in asset ownership may require trust modifications, new petitions, or updated beneficiary designations. When necessary, we assist with trust modification petitions or Heggstad filings to correct technical transfer issues. Keeping documents and asset titles current reduces ambiguity and ensures that your intended administration and distributions occur when they are needed.
A revocable living trust holds assets during your lifetime and provides instructions for their management and distribution after death without the need for probate when assets are properly funded into the trust. It also allows for a successor trustee to manage the trust assets if you become incapacitated. A last will and testament directs how assets not placed in a trust should be distributed, names an executor, and can nominate guardians for minor children. Wills must typically go through probate for distribution under court supervision. Choosing between a trust and a will depends on your goals and asset structure. Trusts offer privacy and can streamline administration for many assets, while wills remain useful for items not transferred into a trust or for naming guardians for minors. Both documents often work together in a coordinated plan, and careful attention to funding the trust and updating beneficiary designations ensures the chosen approach functions as intended for your family.
Yes, funding a trust is a critical step in making it effective. Funding generally means retitling bank and investment accounts, transferring property deeds into the name of the trust, and updating beneficiary designations where appropriate. Without funding, assets intended for the trust may still be subject to probate, which undermines the primary benefit of a trust-centered plan. For Stallion Springs property, transferring real estate into the trust may involve recording new deeds and ensuring mortgage and tax considerations are addressed. Funding can be straightforward, but it requires attention to detail. Some accounts, like retirement plans, may be better handled through beneficiary designations rather than retitling. We help clients identify which assets should be transferred and provide the documentation and steps to complete each transfer so that the trust functions as designed and reduces the likelihood of future administrative complications.
A financial power of attorney appoints an agent to manage monetary and property matters if you are unable to do so. It can be durable, meaning it remains effective during incapacity, and it can be tailored to grant wide or limited authority. An advance health care directive names a health care agent to make medical decisions according to your stated preferences and may include instructions about life-sustaining treatment. A HIPAA authorization often accompanies these documents to allow agents access to medical records necessary for informed decision-making. Together, these documents enable trusted individuals to act quickly when medical or financial decisions are required, avoiding the need for court-appointed conservatorship. Clear drafting of powers and alternates, along with communicated expectations, helps agents act confidently and in alignment with your wishes. Regular reviews ensure designations remain appropriate as family or health circumstances change.
A pour-over will works alongside a revocable living trust to ensure any assets not transferred into the trust during your lifetime are directed into the trust at your death. It acts as a safety net so that property accidentally left outside the trust is still governed by the trust’s terms, although assets covered by the pour-over will may still go through probate. The pour-over will is commonly used to capture personal property or newly acquired assets that were not retitled prior to death. Using a pour-over will in combination with a funded trust provides a comprehensive approach: the trust handles assets placed within it, while the pour-over will addresses any oversights. Regularly checking that assets are properly funded reduces the reliance on the pour-over mechanism, and our team assists clients in coordinating both documents to minimize probate exposure and administrative burdens for heirs.
Planning for a family member with special needs often involves creating a specialized trust that preserves the individual’s eligibility for public benefits while providing supplemental support. A special needs trust can pay for quality-of-life expenses not covered by government programs, and it can be structured to provide oversight and professional management if desired. Selecting an appropriate trustee and outlining clear distribution guidelines are important to meet the beneficiary’s long-term needs and to coordinate with available benefits programs. It is also important to coordinate guardianship nominations, powers of attorney, and health care directives so that caregivers and fiduciaries have the legal authority to act. Regular reviews ensure the trust and related documents remain aligned with evolving benefit rules and family circumstances. We work with families to design sustainable plans that balance immediate needs and future security for the beneficiary.
You should review and update your estate plan after major life events such as marriage, divorce, the birth or adoption of children, death of a beneficiary or fiduciary, significant changes in assets, or changes in health. Even without major events, periodic reviews every few years are advisable to account for legal changes or shifts in financial circumstances. Regular updates ensure that documents reflect current wishes, correct beneficiary designations, and maintain proper trust funding and titling. Updating also includes verifying that named agents, trustees, and executors remain appropriate and willing to serve. For clients with real estate or business interests, reviews are especially important to address property transfers and possible tax or administrative implications. We help clients establish a review cadence and make targeted updates when needed to keep plans functional and effective.
If a trust is not properly funded, assets intended to pass under the trust may instead be subject to probate, which can delay distribution and increase costs for heirs. Improper funding can also create confusion over which assets the trustee controls and which remain in the decedent’s probate estate. This can burden family members with additional procedures and court involvement that a funded trust was meant to avoid. To prevent these issues, it is important to follow through on retitling accounts, transferring deeds, and ensuring beneficiary designations are consistent with the trust’s goals. Our process includes a funding checklist and guidance for working with financial institutions to complete necessary transfers so the trust functions smoothly when it becomes active.
Yes, you can name a successor trustee who lives out of state, but practical considerations may affect the choice. Trustees who live farther away may face logistical challenges in managing real property, attending local court proceedings if needed, or meeting with local professionals. Travel and time zone differences can also affect responsiveness. For some clients, naming a local successor trustee or a trusted corporate fiduciary for administrative tasks provides practical benefits, while an out-of-state individual may still be named for overall oversight. When selecting a trustee, consider whether they can access local records, work with California institutions, and handle property matters in Kern County. Naming local co-trustees or specifying regional professional advisors can create a workable solution when a preferred successor lives elsewhere. We discuss these trade-offs and help craft provisions that accommodate practical administration needs.
Trustee transitions and trust administration involve notifying beneficiaries and financial institutions, gathering assets, paying debts and taxes, and distributing trust property according to the trust terms. The successor trustee must review the trust document, obtain certified copies, and follow any notice requirements. Proper documentation and clear instructions reduce disputes and support orderly administration, and trustees often benefit from checklists and templates to manage their duties effectively during this process. We assist trustees with the administrative steps, preparing required notices, assembling inventories, and advising on tax filings and creditor procedures. When legal filings are needed, such as probate or court petitions to resolve title issues, we provide guidance and representation. Our goal is to help trustees fulfill their duties efficiently and in a manner consistent with the trust creator’s stated intentions.
Common mistakes in estate planning include failing to fund a trust, neglecting beneficiary designations, not naming alternates for fiduciaries, and leaving documents outdated after major life changes. Other pitfalls include unclear distribution instructions, failure to coordinate documents, and inadequate incapacity planning. These oversights can lead to probate, delays, increased costs, and family disputes that could have been prevented with thorough planning and periodic review. Avoiding these mistakes requires a comprehensive approach: inventory assets, coordinate beneficiary forms with trust provisions, name appropriate fiduciaries and alternates, and review documents regularly. Working with a legal advisor to perform a funding review and to draft clear, coordinated documents helps ensure that your intentions are carried out smoothly and that loved ones are not burdened with unnecessary administrative tasks.
Criminal Defense
Homicide Defense
Manslaughter
Assault and Battery
Assault with a Deadly Weapon
Battery Causing Great Bodily Injury
Domestic Violence
Domestic Violence Protection Orders
Domestic Violence Restraining Order
Arson Defense
Weapons Charges
Illegal Firearm Possessions
Civil Harassment
Civil Harassment Restraining Orders
School Violence Restraining Orders
Violent Crimes Defense
Estate Planning Practice Areas