The probate exception to federal court jurisdiction applies only to cases in which the federal courts would be called on to “(1) probate or annul a will, (2) administer a decedent’s estate, or (3) assume in rem jurisdiction over property that is in the custody of the probate court.” Goncalves v. Rady Children’s Hosp. San Diego, 865 F.3d 1237, 1252 (9th Cir. 2017). Here, a California lawyer sued the estate of his former client for fees for estate planning services–with the fees measured as a percentage of the value of the estate’s property. The claim did not fall within any of the three categories of cases to which the probate exception applies. Valuing the property of the estate for purposes of computing the amount of attorney fees owed was not administering the estate, nor was the court required to assume in rem jurisdiction over any property. Though Bond died out-of-state, plaintiff presented a prima facie case sufficient to show that the court could exercise personal jurisdiction over his estate, as he had come to California to obtain a California citizen’s legal advice over a number of years, and the suit arose from those contacts.