On January 22, 2022 a
Order to Show Cause
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
Electronically
Bart I. Ring, CA State Bar No. 126235 by Superior Court of California, County of San Mateo
THE RING LAW FIRM APLC ON 12/12/2022
Woodland
Telephone:
th ills,818.587.9299
5550 Top: an} a Canyon Blvd., Ste 200
CA 91367 By /sLAnthony Berini
Facsimile: 818-587-9292
email: bart@bartringlaw.com
Attorneys for Plaintiff,
ADRIANA J. QUINTERO
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN MATEO
ADRIANA J. QUINTERO, CASE NO. 22-CIV-00190
10
[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
15 STEVEN A. WEINKAUF, TRUSTEE OF
THE STEVEN A. WEINKAUF Complaint Filed: JANUARY 24, 2022
16 IRREVOCABLE LIVING TRUST; ALL Trial Date: NONE SET
PERSONS UNKNOWN CLAIMING ANY
17
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
20 PLAINTIFFS’ TITLE, OR ANY CLOUD CTRM: H
ON PLAINTIFFS’ TITLE TO THAT
21 PROPERTY, and DOES 1 through 50
inclusive,
22
23 Defendants.
24
25
26
27
28 1
DECLARATION OF BART I. RING RE: OSC
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
thereto.
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
11
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
15
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 and 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
DECLARATION OF BART I. RING RE: OSC
STATE OF CALIFORNIA.
BAR . RING,
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
PROOF OF SERVICE - 1013A{3}, 2015.5 C.C.P.
AdrianaJ. Quintero, et al. v. Leonard W. Stone III, et al.
San Mateo Superior Court —
Case No. 22-CIV-00190
STATE OF CALIFORNIA )
) SS.
COUNTY OF LOS ANGELES)
Tam 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
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
12
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 o VIA FIRST-CLASS MAIL (Code of Civil Procedure §§1013 and 1013(a))
17 oO VIA EXPRESS MAIL OR OTHER OVERNIGHT DELIVERY SERVICE (Code of Civil
Procedure §§1013(c) and (d))
18
Oo Via CERTIFIED MAIL (Code of Civil Procedure §§1013 and 1013(a))
19
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
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 unsuccessful. electronic
was My service address is:
25 BART@BARTRINGLAW.COM
26 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
DECLARATION OF BART I. RING RE: OSC
transmission, any electronic message or other indication that the transmission was
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.
(Code of Civil Procedure §1010.6 and California Rules of Court, Rule 2.251.)
a
VIA ELECTRONIC FILING SERVICE: Complying with Code of Civil Procedure
§1010.6, my electronic business address is: BART@BARTRINGLAW.COM and I
caused such document(s) to be electronically served through
system for the above-entitled case to
those parties on the attached Service List maintained on its website for this case. The
file transmission was reported as complete and a copy of the Filing/Service Receipt will
be maintained with the original document(s) in our office.
———— |
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
copy of the sent e-mail will be maintained with the document(s) in our office. (Code of
12 Civil Procedure §1010.6 and California Rules of Court, Rule 2.251.) 1 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
| §1010.6(a)(2), the party(ies) have agreed to receive electronic service via this method.
15
16 I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.
17
Executed on December 9, 2022, in Woodland Hills, California.
18
19
/S/ BART I. RING
20
BART I. RING
21
22
23
24
25
26
27
28 5
DECLARATION OF BART I. RING RE: OSC
PARTIES SERVED
Scott D. Long
FIDELITY NATIONAL LAW GROUP
The Law Division of Fidelity National Title Group, Inc.
1550 Parkside Drive, Ste 200
Walnut Creek, CA 94596
Telephone: 925.280.3362
Facsimile: 925.930.9588
Email: Scott.Long@fnf.com
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28 6
DECLARATION OF BART I. RING RE: OSC
Preview
Electronically Bart I. Ring, CA State Bar No. 126235 by Superior Court of California, County of San Mateo THE RING LAW FIRM APLC ON 12/12/2022 Woodland Telephone: th ills,818.587.9299 5550 Top: an} a Canyon Blvd., Ste 200 CA 91367 By /sLAnthony Berini Facsimile: 818-587-9292 email: bart@bartringlaw.com Attorneys for Plaintiff, ADRIANA J. QUINTERO SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN MATEO ADRIANA J. QUINTERO, CASE NO. 22-CIV-00190 10 [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 15 STEVEN A. WEINKAUF, TRUSTEE OF THE STEVEN A. WEINKAUF Complaint Filed: JANUARY 24, 2022 16 IRREVOCABLE LIVING TRUST; ALL Trial Date: NONE SET PERSONS UNKNOWN CLAIMING ANY 17 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 20 PLAINTIFFS’ TITLE, OR ANY CLOUD CTRM: H ON PLAINTIFFS’ TITLE TO THAT 21 PROPERTY, and DOES 1 through 50 inclusive, 22 23 Defendants. 24 25 26 27 28 1 DECLARATION OF BART I. RING RE: OSC 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 thereto. 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 11 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 15 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 and 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 DECLARATION OF BART I. RING RE: OSC STATE OF CALIFORNIA. BAR . RING, 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 PROOF OF SERVICE - 1013A{3}, 2015.5 C.C.P. AdrianaJ. Quintero, et al. v. Leonard W. Stone III, et al. San Mateo Superior Court — Case No. 22-CIV-00190 STATE OF CALIFORNIA ) ) SS. COUNTY OF LOS ANGELES) Tam 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 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 12 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 o VIA FIRST-CLASS MAIL (Code of Civil Procedure §§1013 and 1013(a)) 17 oO VIA EXPRESS MAIL OR OTHER OVERNIGHT DELIVERY SERVICE (Code of Civil Procedure §§1013(c) and (d)) 18 Oo Via CERTIFIED MAIL (Code of Civil Procedure §§1013 and 1013(a)) 19 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 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 unsuccessful. electronic was My service address is: 25 BART@BARTRINGLAW.COM 26 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 DECLARATION OF BART I. RING RE: OSC transmission, any electronic message or other indication that the transmission was 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. (Code of Civil Procedure §1010.6 and California Rules of Court, Rule 2.251.) a VIA ELECTRONIC FILING SERVICE: Complying with Code of Civil Procedure §1010.6, my electronic business address is: BART@BARTRINGLAW.COM and I caused such document(s) to be electronically served through system for the above-entitled case to those parties on the attached Service List maintained on its website for this case. The file transmission was reported as complete and a copy of the Filing/Service Receipt will be maintained with the original document(s) in our office. ———— | 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 copy of the sent e-mail will be maintained with the document(s) in our office. (Code of 12 Civil Procedure §1010.6 and California Rules of Court, Rule 2.251.) 1 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 | §1010.6(a)(2), the party(ies) have agreed to receive electronic service via this method. 15 16 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 17 Executed on December 9, 2022, in Woodland Hills, California. 18 19 /S/ BART I. RING 20 BART I. RING 21 22 23 24 25 26 27 28 5 DECLARATION OF BART I. RING RE: OSC PARTIES SERVED Scott D. Long FIDELITY NATIONAL LAW GROUP The Law Division of Fidelity National Title Group, Inc. 1550 Parkside Drive, Ste 200 Walnut Creek, CA 94596 Telephone: 925.280.3362 Facsimile: 925.930.9588 Email: Scott.Long@fnf.com 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 6 DECLARATION OF BART I. RING RE: OSC