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  • Meline, Edward Richard et al vs Jessee, Nelda F et al(26) Unlimited Other Real Property document preview
  • Meline, Edward Richard et al vs Jessee, Nelda F et al(26) Unlimited Other Real Property document preview
  • Meline, Edward Richard et al vs Jessee, Nelda F et al(26) Unlimited Other Real Property document preview
  • Meline, Edward Richard et al vs Jessee, Nelda F et al(26) Unlimited Other Real Property document preview
  • Meline, Edward Richard et al vs Jessee, Nelda F et al(26) Unlimited Other Real Property document preview
  • Meline, Edward Richard et al vs Jessee, Nelda F et al(26) Unlimited Other Real Property document preview
  • Meline, Edward Richard et al vs Jessee, Nelda F et al(26) Unlimited Other Real Property document preview
  • Meline, Edward Richard et al vs Jessee, Nelda F et al(26) Unlimited Other Real Property document preview
						
                                

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7/16/2020 Aaron W. Moore, State Bar No.: 248566 Collin M. Bogener, State Bar No.: 272560 Michael L. Ricks, Jr., State Bar No.: 314687 MOORE & BOGENER, INC. 1600 West Street Redding, California (530) 605-0355 / (530) 605-3693 (Fax) Email: amooreAa,mooreandboaener.cont Jeffery J. Swanson, State Bar No.: 155118 SWANSON LAW OFFICE 2515 Park Marina Drive, Ste. 102 Redding, CA 96001 (530) 225-8773 / 232-2882 (fax) 10 Attorneys for Plaintiffs STEPHEN MELINE, IV, ROBERT J. MELINE, NELDA F. JESSEE, 12 MELANIE G. EDGINGTON 13 IN THE SUPERIOR COURT FOR THE STATE OF CALIFORNIA 15 IN AND FOR THE COUNTY OF BUTTE 16 17 STEPHEN MELINE IV, CASE NO.: 127180 18 ROBERT J. MELINE, 19 NELDA F. JESSEE, STIPULATION TO CONTINUE TRIAL MELANIE G. DATE AND [PROPOSEDj ORDER 20 EDGINGTON Plaintiffs, TRIAL DATE: July 27,2020 21 DEPT.: 10 22 vs. 23 24 RANDALL C. MELINE, et al. Defendants. 25 26 AND RELATED CROSS-ACTIONS. 27 PageI sTIPULATIoiv To coRTPILIE TRIAL DATE ARD lPRDPDSEDl oRDL'R Plaintiffs, STEPHEN MELINE, IV, an individual, ROBERT J. MELINE, an individual, NELDA F. JESSEE, an individual, and MELANIE G. EDGINGTON, an individual; Defendants, RANDALL C. MELINE and JOAN STONER, Co-Trustees of the Edward Richard Meline and Charlene M. Meline Irrevocable Trust dated December 30, 1992; Cross-Defendant LINDA G. CARLSON, Trustee of the Jack Meline 1994 Irrevocable Trust; and Cross-Defendants RONALD RABO, MICHAEL RABO, FREDERICK RABO, MARY ANN RABO SCHWEIGER, NICK RABO, SUSAN R. MILLER, (collectively referred herein as "parties") by and through their respective counsel of record do hereby stipulate as follows: The parties, by and tltrough their respective attorneys of record, hereby stipulate that the Pre-Trial Conference of July 24, 2020 and the Trial date currently scheduled to commence on 10 July 27, 2020 in the above-referenced matter be vacated, and that a Pre-Trial Conference be held 11 on July 27, 2020 in order to discuss extensive pre-trial matters required to commence trial and reset trial within the next 3-4 months. The parties stipulate that good cause exists for the 12 continuance for the following reasons: 13 Counsel for all parties believe that a live trial is necessary given the anticipated number 14 of visual exhibits. Given the uncertainty over the ability to conduct a lengthy live trial at this 15 point due to COVID-19 and the difficulty in ensuring witness safety and availability during this pandemic, the parties request that the trial be postponed in order to prevent unnecessary trial 17 preparation expenses; Counsel for all parties have concern over the scope and nature of the trial given that trial had previously commenced but was suspended pending a conditional settlement. After two years of attempting to resolve the conditions set forth in the settlement, the parties were unable to finalize the agreement. Accordingly, the parties seek directions as to the nature of the treatment of the previous trial as well as direction regarding the treatment of any alleged changed 22 circumstances 23 In addition to the above, Plaintiff, NELDA F. JESSEE, is scheduled for a necessary 24 surgical procedure on July 27, 2020 and is unable to reschedule at this time and counsel for LINDA G. CARLSON has indicated that she may seek substitution as counsel for personal 26 reasons; 27 Page 2 STIPE EA'floN To coNTINTIE TRIAI. DATE AND lPRDPosEDl oRDER Vacating the current trial date is warranted under the current circumstances and will serve to promote trial convenience and judicial economy. In the event that the Court does not execute the Order, the parties agree that the first day of trial will be used as a trial readiness conference to present briefs, exhibits, motions in limine, 4 and discuss matters generally determined in a pretrial conference. The parties further agree that Aaron W. Moore, counsel for plaintiffs, may discuss the 6 contents of this stipulation with the Court on an ex parte basis should the Court have any questions. This Stipulation may be executed in counterparts. IT IS SO STIPULATED: 10 11 Dated: July 15,2020 MOORE k BOGENER, INC. 12 13 By: AARON W. MOORE 14 Attorney for Plaintiffs STEPHEN MELINE, IV 15 ROBERT J. MELINE 16 NELDA F. JESSEE MELANIE G. EDGINGTON 17 18 19 Dated: July 2020 RY CARTER LAW OFFICE 20 21 JOAN JEFFERY j2AR'fER 7~ 22 Attorney for Defendants 23 RANDALL C. MELINE and JOAN STONER, Co-Trustees of the 24 Edward Richard Meline and Charlene M. Meline Irrevocable Trust dated December 25 1992 30, 26 27 Page 3 sTIPULATIDN To OONTINUE TRIAL DATE AND lPRoPosEDI oRDER 2 Dated: July t J 2020 CHRIS I'ENSEN IL SCHWARZ, LLP 3 / NELS A. CI-IRISTENSEN Attorney for Cross-Defendant LINDA G. CARLSON, Trustee of the Jack Meline 1994 Irrevocable Trust 8 Dated: July I5, 2020 LENAHAN, LEE, SLATER, PEARSIA & MAJERNIK, LLP 10 12 CHARLETON S. PEARSE 13 Attorney for Cross-Defendants RONALD RABO, MICIIAEL RABO, 14 FREDERICK ILABO, MARY ANN 15 RAI30 SCHWEIGER, NICK RABO, SUSAN R. MILLER 16 17 18 19 20 21 22 23 24 25 26 27 STIPI LATIOV TO CORTIRL E TRIAL DATE ASD ]I" ROPOSED] Page 4 ORDER 1 [PROPOSEDj ORDER Upon stipulation of the parties, and good cause appearing therefore, IT IS HEREBY ORDERED that: 1. The Trial date currently scheduled to commence on July 27, 2020 is vacated; 2. The Pre-Trial Conference currently scheduled for July 24, 2020 is vacated and continued to July 27, 2020 at ,in Department 10. IT IS SO ORDERED. Dated: 10 JUDGE OF THE SUPERIOR COURT 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Page 5 STIPLILATION To coNTINDE TRIAL DATE AND [PROPOSEDf ORDER