On December 11, 2020 a
Party Notice
was filed
involving a dispute between
Help Unlimited Inc,
Morin, Rebecca,
Sellars, Mark,
and
Coles, Channe,
Help Unlimited,
Help Unlimited Inc,
Honor Home Care Services California Inc,
Leahy, Patrick,
Reynolds, Susan,
The Law Office Of Channe G Coles,
Wollum, Patricia,
for Unlimited Other Complaint (Not Spec) (42)
in the District Court of Santa Barbara County.
Preview
SUPERIOR COURT of CALIFORNIA
LAW OFFICES OF COUNTY of SANTA BARBARA.
McCARTHY & KROES
125 E. VICTORIA STREET, SUITEA
SANTA BARBARA, CA 93101
APR 2 4 2024
(805) 564-2085 Darrel E arker, Executive Officer
ta
R. Chris Kroes, SBN 134935 Gabriel Moreno, Deputy Clerk
chris@mcecarthykroes.com
Attorneys for Defendants: CHIANNE COLES,
THE LAW OFFICE OF CHANNE G. COLES, a California corporation
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SANTA BARBARA
10
11 MARK SELLARS, individually and as CASE NO.: 20CV04132
Trustee of the Rosemary Free Trust u/d/t é aw °
12
<2
Aug dated September 13, 2000, and REBECCA LODGING FOR:
MORIN, Conservator of the Estate and DEFENDANTS CHANNE COLES’ AND
Bao
13 TH LAW OFFICE OF CHANNE G.
Person of Rosemary Free Leahy,
23s COLES’ EXHIBIT “B” and EXHIBIT
14
zc
ZzeS “C” IN SUPPORT OF MOTION FOR
Plaintiffs, TERMINATING SANCTIONS AND
£56 15
MONETARY SANCTIONS
az
a2< VS.
16 [Filed concurrently with Supplemental
Declarations of R. Chris Kroes and
17 Esmeralda Murillo In Support of Motion for
PATRICK LEAHY; CHANNE COLES, THE
Terminating Sanctions]
18 LAW OFFICE OF CHANNE G. COLES, a
California corporation; PATRICIA Date: May 15, 2024
19 WOLLUM; SUSAN REYNOLDS: HELP Time 0:00 a.m.
UNLIMITED, a California corporation; and Dept: 3
20
DOES 1 -10, inclusive,
[Assigned to the Hon. Thomas Anderle,
21 in Department 3.]
Defendants.
22
Complaint Filed: 12/11/20
23 Third Amended Complaint Filed: 1/12/24
24
25 TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
26 PLEASE TAKE NOTICE: Defendants Channe Coles and The Law Office of Channe G.
27 Coles’ Exhibit “B” and Exhibit “C” are being produced on a thumb drive. Due to the individual
28
1
LODGING FOR: DEFENDANTS CHANNE COLES’ AND TH LAW OFFICE OF CHANNE G. COLES’ EXHIBIT “B”
and EXHIBIT “C” IN SUPPORT OF MOTION FOR TERMINATING SANCTIONS AND MONETARY SANCTIONS
1 sizes of Exhibit B and c, the documents are too large to electronically file. Therefore, the thumb
>
2 drive containing both Exhibit B and C are being lodged with this court.
3 || Dated: April 23, 2024 McCARTHY & KROES
4
5
R. CHRIS KROES
6 Attorneys for Defendants
CHANNE COLES, and THE
LAW OFFICE OF CHANNE G.
COLES, a California corporation
10
11
Document Filed Date
April 24, 2024
Case Filing Date
December 11, 2020
Category
Unlimited Other Complaint (Not Spec) (42)
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