On January 22, 2022 a
No Value
was filed
involving a dispute between
Quintero, Adriana J.,
Stone, Jessica L,
Stone, Leonard W, Iii,
and
All Persons Unknown, Claiming Any Legal Or Equitable Right, Title, Stake, Lien Or Interest In The Property Described In The Complaint Adverse To Plaintiffs Title, Or Any Cloud On Plaintiffs' Title To That Property,
Does 1 Through 50, Inclusive,
Steven A Weinkauf, Trustee Of The Steven A Weinkauf Irrevocable Living Trust,
Stone, Jessica L,
Stone, Leonard W, Iii,
Weinkauf, Steven A,
for (16) Unlimited Fraud
in the District Court of San Mateo County.
Preview
1 |)Bart I. Ring, CA State Bar No, 126235 |
THE RING LAW FIRM APLC |
2 ||5550 Topanga Canyon Blvd., Ste 200
Woodland Hills, CA 91367
3 |/Telephone: 818.587.9299 |
Facsimile: 818-587-9292
4 || email: bart@bartringlaw.com
> || Attorneys for Plaintiff,
6 |ADRIANA J. QUINTERO
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA |
8
FOR THE COUNTY OF SAN MATEO
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19 | ADRIANA J. QUINTERO, | CASE NO. 22-CIV-00190
[CASE ASSIGNED TO NANCY L. |
11 Plaintiff, FINEMAN- JUDGE PRESIDING- :
DEPT. 4] |
12 VS.
13 DECLARATION OF BART I. RING RE: |
|LEONARD W. STONE III; JESSICA L. ORDER TO SHOW CAUSE RE: |
14 || STONE; STEVEN A. WEINKAUF; SANCTIONS
1s ||STEVEN A. WEINKAUF, TRUSTEE OF |
THE STEVEN A. WEINKAUF Complaint Filed: JANUARY 24, 2022 |
16 ||IRREVOCABLE LIVING TRUST; ALL | Trial Date: NONE SET |
17_ ||PERSONS UNKNOWN CLAIMING ANY | |
|LEGAL OR EQUITABLE RIGHT, TITLE,
18 ||STAKE, LIEN OR INTEREST IN THE DATE OF HEARING: March 9, 2023
PROPERTY DESCRIBED IN THE TIME: 9:00AM
19 ||COMPLAINT ADVERSE TO DEPT.: 35
>9_||PLAINTIFFS’ TITLE, OR ANY CLOUD | CTRM: H
ON PLAINTIFFS’ TITLE TO THAT
21 |/PROPERTY, and DOES 1 through 50 |
77 __||inclusive, |
23 Defendants. |
24 | — | |
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_ DECLARATION OF BART I.RING RE: OSC a |
DECLARATION OF BART I. RING
I, BART I. RING, DECLARE AS FOLLOWS:
| 1. Iam an attorney at law duly licensed in the state of California since 1985. Iam
| counsel of record herein for Plaintiff Adriana J. Quintero. I am readily familiar with the
| facts as set forth herein and if called as a witness could and would competently testify
el thereto.
7 2. A Case Management Conference (“CMC”) was scheduled for December 5, 2022
10 }in this matter. I had previously calendared the scheduled hearing on my calendar and
My fully intended to appear remotely. I had been in recent contact with defendant Leonard W.
12 |Stone and Jessica L. Stone’s counsel of record, Scott D. Long, in advance of the CMC.
13 | We have discussed proceeding to private mediation and who should serve as the mediator.
14 | 3. On December 3 and 4, 2022 I was ill. I had simply forgotten about the scheduled
S| CMC and arrived at my office December 5, 2022 at around 11am. I received an email
16 |}from Mr. Long advising the CMC had proceeded as scheduled and told the court set an
17 |! Order to Show Cause for March 9, 2023.
18 4. In almost forty years of practicing law I cannot remember the last time I missed
19 any court hearing for any reason. I would kindly request the court accept my apologies
20 |land discharge the Order to Show Cause without having to pay any monetary sanctions. |
21 |
22 | THIS DECLARATION IS EXECUTED THIS NINTH DAY OF DECEMBER,
23 ||2022 AT WOODLAND HILLS, CALIFORNIA.
24 |
25 | THIS DECLARATION IS EXECUTED PURSUANT TO THE LAWS OF THE |
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27 | |
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7 DECLARATION OF BART I.RING RE: OSC
STATE OF CALIFORNIA.
5 BART I.RING, <
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~ _____________ DECLARATION OF BART I. RING RE: OSC __ |
1
PROOF OF SERVICE - 1013A{3], 2015.5 C.C.P.
2 Adriana J. Quintero, et al. v.Leonard W. Stone Il. et al.
3 San Mateo Superior Court —
Case No. 22-CIV-00190 |
4 |
5 STATE OF CALIFORNIA ) |
6 ) SS. |
7 COUNTY OF LOS ANGELES)
8 I am employed in the County of Los Angeles, State of California. I am over the age of
eighteen (18) and not a party to the within action; my business address is 5550 Topanga Canyon
9 Blvd., Ste 200 — Woodland Hills, California 91367.
10 |}On December 9, 2022, I served, in the manner indicated below, the foregoing document
11 | described as DECLARATION OF BART I. RING RE: ORDER TO SHOW CAUSE
RE: SANCTIONS |
13 oO VIA PERSONAL SERVICE: I caused such envelope(s) to be delivered by hand to |
the above address(es) listed on this page or the attached service list. |
14
O VIA UNITED STATES POSTAL SERVICE: By placing a copy thereof for delivery
15 in a separate envelope addressed to each addressee, respectively as follows:
16 | [1 | VIA FirSsT-CLAss MAIL (Code of Civil Procedure §§1013 and 1013(a))
17 C VIA EXPRESS MAIL OR OTHER OVERNIGHT DELIVERY SERVICE (Code of Civil | |
18 Procedure §§1013(c) and (d)) |
| O VIA CERTIFIED MAIL (Code of Civil Procedure §§1013 and 1013(a)) |
19 Eel
1 oO | VIA FACSIMILE TRANSMISSION: (Code of Civil Procedure §§1013(e) and (f)): |
20 | from facsimile number: 818.301.5131 to the facsimile number(s) listed on the attached
21 service list.The facsimile machine I used complied with California Rules of Court,
| Rule 2.306 and no error was reported by the machine.
22 | ee—_—_—
i VIA ELECTRONIC MAIL: I caused the Document(s) to be sent to the person(s) at
23 the e-mail address(es) listed on the attached service list. I did not receive, within a |
| reasonable time after transmission, any electronic message or other indication that the
24 transmission was unsuccessful. My _ electronic service address is:
5 BART@BARTRINGLAW.COM
. seme) a ews innate bi inenhieetonttint intitle
enone nrrn ettesnemmernaciennamnmteimtnennieid
i
i
26 O VIA ELECTRONIC TRANSMISSION: Complying with an agreement with all | |
| parties, I caused the Document(s) to be sent to the person(s) at the e-mail address(es) | |
27 listed on the attached service list.I did not receive, within a reasonable time after
28 : 4 |
: |
I / "transmission, ‘any electronic 1 message or other indication that the transmission was
2 unsuccessful. My electronic service address is: BART@BARTRINGLAW.COM. A
| | copy of the sent e-mail will be maintained with the original document(s) in our office.
3 | | (Code of Civil Procedure §1010.6 and California Rules of Court, Rule 2.251.)
45 ; O | VIA ELECTRONIC FILING SERVICE: Complying with Code of Civil Procedure
5 yi §1010.6, my electronic business address is: BART@BARTRINGLAW.COM and I |
|| caused such document(s) to be electronically served through
6 | _ oo system for the above-entitled case to |
those parties on the attached Service List maintained on its website for this case. The
7 file transmission was reported as complete and a copy of the Filing/Service Receipt will
3 | be maintained with the original document(s) in our office.
9 O VIA SHAREFILE: Complying with Code of Civil Procedure §1010.6(a)(1)(c), I |
caused an electronic notice to be sent to the person(s) at the e-mail address(es) listed |
10 | on the attached Service List. This notice contained a secure link that permits the |
person(s) individual access to download the above-listed document(s). Notification is
11 | provided via counsel’s secure ShareFile system’s administrative e-mail account, _.A
vp | copy of the sent e-mail will be maintained with the document(s) in our office. (Code of
| Civil Procedure §1010.6 and California Rules of Court, Rule 2.251.) I did not receive,
13 | within a reasonable time after transmission, any electronic message or other indication |
| that the transmission was unsuccessful. This link will expire after 60 days and access
14 | | will no longer be permitted to the document(s). Pursuant to Code of Civil Procedure
15 | | §1010.6(a)(2), the party(ies) have agreed toreceive electronic service via this method. ;
16 | I declare under penalty of perjury under the laws of the State of California that the above
7 | istrue and correct.
18 Executed on December 9, 2022, in Woodland Hills, California.
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0 Il /S/ BART I.RING
BART I.RING
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|| = DECLARATION OF BART I.RING RE: OSC
PARTIES SERVED
5 || Scott. Long |
FIDELITY NATIONAL LAW GROUP
‘ The Law Division of Fidelity National Title Group, Inc.
° 1550 Parkside Drive, Ste 200
© | walnut Creek, CA 94596
a _ Telephone: 925.280.3362
8 Facsimile: 925.930.9588
7 | Email: Scott.Long@fnf.com
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nn | DECLARATION OF BART I. RING RE: OSC _ |
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1 |)Bart I. Ring, CA State Bar No, 126235 | THE RING LAW FIRM APLC | 2 ||5550 Topanga Canyon Blvd., Ste 200 Woodland Hills, CA 91367 3 |/Telephone: 818.587.9299 | Facsimile: 818-587-9292 4 || email: bart@bartringlaw.com > || Attorneys for Plaintiff, 6 |ADRIANA J. QUINTERO 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA | 8 FOR THE COUNTY OF SAN MATEO 9 19 | ADRIANA J. QUINTERO, | CASE NO. 22-CIV-00190 [CASE ASSIGNED TO NANCY L. | 11 Plaintiff, FINEMAN- JUDGE PRESIDING- : DEPT. 4] | 12 VS. 13 DECLARATION OF BART I. RING RE: | |LEONARD W. STONE III; JESSICA L. ORDER TO SHOW CAUSE RE: | 14 || STONE; STEVEN A. WEINKAUF; SANCTIONS 1s ||STEVEN A. WEINKAUF, TRUSTEE OF | THE STEVEN A. WEINKAUF Complaint Filed: JANUARY 24, 2022 | 16 ||IRREVOCABLE LIVING TRUST; ALL | Trial Date: NONE SET | 17_ ||PERSONS UNKNOWN CLAIMING ANY | | |LEGAL OR EQUITABLE RIGHT, TITLE, 18 ||STAKE, LIEN OR INTEREST IN THE DATE OF HEARING: March 9, 2023 PROPERTY DESCRIBED IN THE TIME: 9:00AM 19 ||COMPLAINT ADVERSE TO DEPT.: 35 >9_||PLAINTIFFS’ TITLE, OR ANY CLOUD | CTRM: H ON PLAINTIFFS’ TITLE TO THAT 21 |/PROPERTY, and DOES 1 through 50 | 77 __||inclusive, | 23 Defendants. | 24 | — | | 25 26 | | 27 28 1 _ DECLARATION OF BART I.RING RE: OSC a | DECLARATION OF BART I. RING I, BART I. RING, DECLARE AS FOLLOWS: | 1. Iam an attorney at law duly licensed in the state of California since 1985. Iam | counsel of record herein for Plaintiff Adriana J. Quintero. I am readily familiar with the | facts as set forth herein and if called as a witness could and would competently testify el thereto. 7 2. A Case Management Conference (“CMC”) was scheduled for December 5, 2022 10 }in this matter. I had previously calendared the scheduled hearing on my calendar and My fully intended to appear remotely. I had been in recent contact with defendant Leonard W. 12 |Stone and Jessica L. Stone’s counsel of record, Scott D. Long, in advance of the CMC. 13 | We have discussed proceeding to private mediation and who should serve as the mediator. 14 | 3. On December 3 and 4, 2022 I was ill. I had simply forgotten about the scheduled S| CMC and arrived at my office December 5, 2022 at around 11am. I received an email 16 |}from Mr. Long advising the CMC had proceeded as scheduled and told the court set an 17 |! Order to Show Cause for March 9, 2023. 18 4. In almost forty years of practicing law I cannot remember the last time I missed 19 any court hearing for any reason. I would kindly request the court accept my apologies 20 |land discharge the Order to Show Cause without having to pay any monetary sanctions. | 21 | 22 | THIS DECLARATION IS EXECUTED THIS NINTH DAY OF DECEMBER, 23 ||2022 AT WOODLAND HILLS, CALIFORNIA. 24 | 25 | THIS DECLARATION IS EXECUTED PURSUANT TO THE LAWS OF THE | 26 | | 27 | | 28 2 7 DECLARATION OF BART I.RING RE: OSC STATE OF CALIFORNIA. 5 BART I.RING, < 6 7 8 9 10 11 | 12 13 | 14 | 15 16 17 18 19 | 20 | 21 22 23 24 | 25 | 26 - 27 28 3 ~ _____________ DECLARATION OF BART I. RING RE: OSC __ | 1 PROOF OF SERVICE - 1013A{3], 2015.5 C.C.P. 2 Adriana J. Quintero, et al. v.Leonard W. Stone Il. et al. 3 San Mateo Superior Court — Case No. 22-CIV-00190 | 4 | 5 STATE OF CALIFORNIA ) | 6 ) SS. | 7 COUNTY OF LOS ANGELES) 8 I am employed in the County of Los Angeles, State of California. I am over the age of eighteen (18) and not a party to the within action; my business address is 5550 Topanga Canyon 9 Blvd., Ste 200 — Woodland Hills, California 91367. 10 |}On December 9, 2022, I served, in the manner indicated below, the foregoing document 11 | described as DECLARATION OF BART I. RING RE: ORDER TO SHOW CAUSE RE: SANCTIONS | 13 oO VIA PERSONAL SERVICE: I caused such envelope(s) to be delivered by hand to | the above address(es) listed on this page or the attached service list. | 14 O VIA UNITED STATES POSTAL SERVICE: By placing a copy thereof for delivery 15 in a separate envelope addressed to each addressee, respectively as follows: 16 | [1 | VIA FirSsT-CLAss MAIL (Code of Civil Procedure §§1013 and 1013(a)) 17 C VIA EXPRESS MAIL OR OTHER OVERNIGHT DELIVERY SERVICE (Code of Civil | | 18 Procedure §§1013(c) and (d)) | | O VIA CERTIFIED MAIL (Code of Civil Procedure §§1013 and 1013(a)) | 19 Eel 1 oO | VIA FACSIMILE TRANSMISSION: (Code of Civil Procedure §§1013(e) and (f)): | 20 | from facsimile number: 818.301.5131 to the facsimile number(s) listed on the attached 21 service list.The facsimile machine I used complied with California Rules of Court, | Rule 2.306 and no error was reported by the machine. 22 | ee—_—_— i VIA ELECTRONIC MAIL: I caused the Document(s) to be sent to the person(s) at 23 the e-mail address(es) listed on the attached service list. I did not receive, within a | | reasonable time after transmission, any electronic message or other indication that the 24 transmission was unsuccessful. My _ electronic service address is: 5 BART@BARTRINGLAW.COM . seme) a ews innate bi inenhieetonttint intitle enone nrrn ettesnemmernaciennamnmteimtnennieid i i 26 O VIA ELECTRONIC TRANSMISSION: Complying with an agreement with all | | | parties, I caused the Document(s) to be sent to the person(s) at the e-mail address(es) | | 27 listed on the attached service list.I did not receive, within a reasonable time after 28 : 4 | : | I / "transmission, ‘any electronic 1 message or other indication that the transmission was 2 unsuccessful. My electronic service address is: BART@BARTRINGLAW.COM. A | | copy of the sent e-mail will be maintained with the original document(s) in our office. 3 | | (Code of Civil Procedure §1010.6 and California Rules of Court, Rule 2.251.) 45 ; O | VIA ELECTRONIC FILING SERVICE: Complying with Code of Civil Procedure 5 yi §1010.6, my electronic business address is: BART@BARTRINGLAW.COM and I | || caused such document(s) to be electronically served through 6 | _ oo system for the above-entitled case to | those parties on the attached Service List maintained on its website for this case. The 7 file transmission was reported as complete and a copy of the Filing/Service Receipt will 3 | be maintained with the original document(s) in our office. 9 O VIA SHAREFILE: Complying with Code of Civil Procedure §1010.6(a)(1)(c), I | caused an electronic notice to be sent to the person(s) at the e-mail address(es) listed | 10 | on the attached Service List. This notice contained a secure link that permits the | person(s) individual access to download the above-listed document(s). Notification is 11 | provided via counsel’s secure ShareFile system’s administrative e-mail account, _.A vp | copy of the sent e-mail will be maintained with the document(s) in our office. (Code of | Civil Procedure §1010.6 and California Rules of Court, Rule 2.251.) I did not receive, 13 | within a reasonable time after transmission, any electronic message or other indication | | that the transmission was unsuccessful. This link will expire after 60 days and access 14 | | will no longer be permitted to the document(s). Pursuant to Code of Civil Procedure 15 | | §1010.6(a)(2), the party(ies) have agreed toreceive electronic service via this method. ; 16 | I declare under penalty of perjury under the laws of the State of California that the above 7 | istrue and correct. 18 Executed on December 9, 2022, in Woodland Hills, California. 19 | 0 Il /S/ BART I.RING BART I.RING 21 22 |) 23 24 | 25 | 26 | 27 | | 28 | 5 || = DECLARATION OF BART I.RING RE: OSC PARTIES SERVED 5 || Scott. Long | FIDELITY NATIONAL LAW GROUP ‘ The Law Division of Fidelity National Title Group, Inc. ° 1550 Parkside Drive, Ste 200 © | walnut Creek, CA 94596 a _ Telephone: 925.280.3362 8 Facsimile: 925.930.9588 7 | Email: Scott.Long@fnf.com 10 | | | | 12 13 14 15 16 17 18 19 20 | 21 22 23 24 | 25 | 26 | 27 | 28 6 nn | DECLARATION OF BART I. RING RE: OSC _ |