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ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state,
nber, and addrass): FOR COURT USE ONLY
-
e Raymond L. Sandelman SBN 078020
Attorney at Law
13075 Cohasset Road, Suite 1
Chico, CA 95973-0970
TELEPHONE No.: (530) 343-5090 (530) 343-5091
FAX N0.(0pziona/); F F
E-MAIL ADDREssmpt/onal): sandelmanlaw@sbcglobal.net E
upenor ,ourt
'
.Ron Rabo et al.
ATrORNEY F0R(Name):
BUTTE L
SUPERIOR COURT OF CALIFORNIA, COUNTY 0F N V [15 2001i
STREETADDRESS; 655 Oleander Avenue " '
Tar
655 Oleander Avenue
MAILING ADDRESS:
l i k D
Chico, CA 95926
r\1
CITY AND ZIP CODE:
BRANCH NAME:
PLAINTIFF/PETITIONER: EDWARD RICHARD MELINE et a]. \
DEFENDANT/RESPONDENTJACK MELINE, et a].
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE D LIMITED CASE 127180
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 11/19/04 Time: 10:30 a.m. Dept: -
Div.: Room:
Address of court (if different from the address above):
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one) :
a. D This statement is submitted by party (name) :
b. This statement is submittedjointly by parties (names) :
Ron Rabo, Michael Rabo, Frederick Rabo, Mary Rabo Schweiger, and Sue Miller
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date) :
b. D The cross-complaint, if any, was led on (date) :
3. Service (to be answered by plaintiffs and cross—complainants only)
a. D All parties named in the complaint and cross-complaint have been sewed, or have appeared, or have been dismissed.
b. D The following parties named in the complaint or cross-complaint
(1) D have not been served (specify names and explain why not):
(2) D have been served but have not appeared and have not been dismissed(specify names):
(3) D have had a default entered against them (specify names):
c. D The following additional parties may be added (specify names, nature of involvement in case, and the date by which
they may be served) :
4. Description of case
a. Type of case in complaint cross-complaint (describe, including causes of action):
Partition of real property, request for an injunction tobar termination of employment.
Page1of 4
Use
Form Ado ted for Mandala
ounCII of CalIlorn a
JudICIaI
CASE MANAGEMENT STATEMENT Cal. Rules of Court,
rule 212
CM-I 10 [New July 1, 2002]
Martin Dean's Essential FormsTM
| V
I
PLAINTIFF/PETITIONER: EDWARD R ARD MELINE NUMBER:
-- .180
LDEFENDANT/RESPONDENTIJACK MELINE
4. b. Provide a brief statement of the case, including any damages.(lfpersonal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiffs and Cross Complainants seek partition of real property. Plaintiffs also seek an injunction barring the
termination of employment of Edward Meline.
D (If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request D a jury
trial a nonjury trial (if more than one party, provide the name of each party
requesting a jury trial) :
6. Trial date
a. D The trial has been set for (date) :
b. a No trial date has been set. This case will be ready for trial within 12 months of the date of the ling
Unknown.
of the complaint (if
not, explain) : Present counsel for Ron Rabo et al. is awaiting the appellate court review of the order
disqualifying counsel.
c. Dates on which parties or attorneys will not be available for trial(specify dates and explain reasons for unavailability):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one)
:
a. days (specify number): 6
b. D hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial
Attorney:
by the attorney or party listed in the caption D by the following:
Firm:
Address:
Telephone number:
Fax number:
E-mail address:
. Party represented:
D Additional representation is described in Attachment 8.
9. Preference
D This case is entitled to preference (spec/r
code section):
10. Alternative Dispute Resolution (ADR)
a. Counsel D has E has not
reviewed ADR options with the client.
provided the ADR information package identied in rule 201 .9 to the client and has
b. D All parties have agreed to a form of ADR. ADR will be completed by (date) :
c. D The case has gone to an ADR process (indicate status) :
CM'110 [New JU'Y 1- 20°21
Man/n Dean's Essential Forms TM
CASE MANAGEMENT STATEMENT Page 2 of 4
\
t
PLAINTIFF/PETITIONER: EDWARD R ARD MELINE NUMBER:
127180
—DEFENDANT/RESPONDENTJACK MELINE
’
10. d. The party or parties are willing to participate in (check all that apply):
(1) Mediation
(2) D to close 15 days before
Nonbinding judicial arbitration under Code of Civil Procedure section 1141 .12 (discovery
arbitration under Cal. Rules of Court, rule 1612)
(3) D order under Cal. Rules of rule
to remain open until 30 days
Nonbinding judicial arbitration under Code of Civil Procedure section 1141 .12 (discovery
before trial; required Court. 1612)
(4) D Binding judicial arbitration
(5) D Binding private arbitration
(6) D Neutral case evaluation
(7) D Other (specify) :
e. D This matter is subject to mandatory judicial arbitration because the amountincontroversy does not exceed the statutory limit.
f. D elects
Plaintiff to referthiscase tojudicial and
arbitration agrees to recovery to the amount specied
limit inCode of Civil
Procedure section 1141 .1 1.
g. D This case is exempt from judicial arbitration under rule 1600.5 of the California Rules of Court (specify exemption):
11. Settlement conference
a The party or parties are willing to participate in an early settlement conference(specify when)
z
12. Insurance
a. D this statement(name)
Insurance carrier, if any. for party ling :
b. Reservation of rights: D Yes D No
c. D Coverage issues will signicantly affect resolution of this case(exp/ain)
:
13. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case, and describe the status.
a Bankruptcy D Other (specify):
Status: .
14. Related cases, consolidation, and coordination
a. D There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
D Additional cases are described in Attachment 14a.
b. D A motion to D '
consolidate D coordinate will be filed by (name party):
15. Bifurcation
D The party or parties intend to lea motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
16. Other motions ~
D The party or parties expect to le the following motions before trial(specify moving party, type ofmotion, and issues):
CM-“O [New July 1- 20021 CASE MANAGEMENT STATEMENT Page 3 of 4
Martin Dean's Essential Forms TM
S
l'
PLAINTIFF/PETITIONER: EDWARD R ARD MELINE NUMBER:
”.180
‘7) EFENDANT/RESPONDENTJACK MELINE
17. Discovery _ .
a. D The party or parties have completed all discovery.
b. a The following discovery will be completed by the date specied(descn'be
Description
all anticipated discovery):
D_at§
Ea
All discovery is on hold until the
disqualication issue is resolved
c. D The following discovery issues are anticipated (specify)
:
18. Economic Litigation
a. D This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90 through 98 will apply to this case.
b. D This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be led (if checked, explain specically why economic litigation procedures relating to discovery or trial
should not app/y to this case) :
19. Otherissues
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify): Other parties have suggested the appointment of Judge Watkins as a referee. The appointment
of a referee should be delayed until the Court determines if the real property isto be sold or divided
(CCP section 873.010(a)). Appointment of a former mediator as a referee is problematical.
20. Meet and confer
a. The party or parties have met and conferred with all parties on all subjects required by rule 212 of the California Rules of
,
Court (if not, explain): Counsel for Plaintiffs and Cross Complainants have not made any contact regarding the
subjects specified in the Court Rule.
b. After meeting and conferring as required by rule 212 of the California Rules of Court, the parties agree on the following
(specify) :
21. Case management orders
D
I
Previous case management orders in this case are (check one) : none attached as Attachment 21.
22. Total number of pages attached (if any) : 0
am completely familiar with this case and will be fully prepared to discuss the status of discovery and ADR, as well as other issues
l
raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case
management
conference, including the written authority of the party where required.
Date: November 5, 2004
Raymond L. Sandelman
(TYPE OR PRINT NAME)
m L SJ.“
(SIGNATURE 0F PARTY OR ATTORNEY)
b
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
D Additional signatures are attached
9M4“) [New JU'Y 1- 20°21 CASE MANAGEMENT STATEMENT Page 4 of 4
Martin Dean's Essential Forms TM
PROOF OF SERVICE BY MAIL
I, Linda Quinn, declare:
1. I am a resident of and employed in the County of Butte, State of California. I am, and
was at the time of the service hereinafter mentioned, over the age of 18 years and not a party to the
above-entitled cause.
2. On November
for
5
collection
, 2004, I served
in
the within
United
Case Management Statement, on the
parties by placing and deposit the States mail, a true copy thereof enclosed
in a sealed envelope with postage thereon fully prepaid, at the law ofce of Raymond L.
Sandelman, 3075 Cohasset Road, Suite 1, Chico, Butte County, California, addressed as follows:
Nels A. Christensen James Berglund
Christensen & Schwarz Attorney at Law
1 Governors Lane 1639 Bird Street
Chico, CA 95926 Oroville, CA 95965
95973-0970
William A. Ward Richard L. Crabtree
Attorney at Law Law Ofces of Richard L. Crabtree
(530) 343-5090 / (530) 343-5091 (FAX)
9 Williamsburg Lane 854 Manzanita Court Suite 110
3075 COHASSET ROAD, SUITE 1, CHICO, CA
RAYMOND L. SANDELMAN
Chico, CA 95926 Chico, CA 95926
ATTORNEY AT LAw
John Jeffery Carter
John Jeffrey Carter Law Ofce
P.O. Box 3606
Chico, CA 95927-3606
At that time there was regular delivery of United States mail between the place of deposit
and place of address.
3. I am familiar with the practice of the law ofce of Raymond L. Sandelman for the
collection and the processing of correspondence or mailing with the United States Postal
Service. In accordance with the ordinary course of business, the above-mentioned document
would have been deposited with the United States Postal Service on November 5/, 2004, the
same day on which it was placed at the law ofce of Raymond L. Sandelman for deposit.
I declare under penalty of perjury under the laws of the State of California that the
akw
foregoing is true and correct.
@333
[\J
Dated: November i) ,2004
Lida\Quinn\\
PROOF OF SERVICE
Preview
“‘ A :i ~ CM-11o § ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state, nber, and addrass): FOR COURT USE ONLY - e Raymond L. Sandelman SBN 078020 Attorney at Law 13075 Cohasset Road, Suite 1 Chico, CA 95973-0970 TELEPHONE No.: (530) 343-5090 (530) 343-5091 FAX N0.(0pziona/); F F E-MAIL ADDREssmpt/onal): sandelmanlaw@sbcglobal.net E upenor ,ourt ' .Ron Rabo et al. ATrORNEY F0R(Name): BUTTE L SUPERIOR COURT OF CALIFORNIA, COUNTY 0F N V [15 2001i STREETADDRESS; 655 Oleander Avenue " ' Tar 655 Oleander Avenue MAILING ADDRESS: l i k D Chico, CA 95926 r\1 CITY AND ZIP CODE: BRANCH NAME: PLAINTIFF/PETITIONER: EDWARD RICHARD MELINE et a]. \ DEFENDANT/RESPONDENTJACK MELINE, et a]. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE D LIMITED CASE 127180 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 11/19/04 Time: 10:30 a.m. Dept: - Div.: Room: Address of court (if different from the address above): INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one) : a. D This statement is submitted by party (name) : b. This statement is submittedjointly by parties (names) : Ron Rabo, Michael Rabo, Frederick Rabo, Mary Rabo Schweiger, and Sue Miller 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date) : b. D The cross-complaint, if any, was led on (date) : 3. Service (to be answered by plaintiffs and cross—complainants only) a. D All parties named in the complaint and cross-complaint have been sewed, or have appeared, or have been dismissed. b. D The following parties named in the complaint or cross-complaint (1) D have not been served (specify names and explain why not): (2) D have been served but have not appeared and have not been dismissed(specify names): (3) D have had a default entered against them (specify names): c. D The following additional parties may be added (specify names, nature of involvement in case, and the date by which they may be served) : 4. Description of case a. Type of case in complaint cross-complaint (describe, including causes of action): Partition of real property, request for an injunction tobar termination of employment. Page1of 4 Use Form Ado ted for Mandala ounCII of CalIlorn a JudICIaI CASE MANAGEMENT STATEMENT Cal. Rules of Court, rule 212 CM-I 10 [New July 1, 2002] Martin Dean's Essential FormsTM | V I PLAINTIFF/PETITIONER: EDWARD R ARD MELINE NUMBER: -- .180 LDEFENDANT/RESPONDENTIJACK MELINE 4. b. Provide a brief statement of the case, including any damages.(lfpersonal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiffs and Cross Complainants seek partition of real property. Plaintiffs also seek an injunction barring the termination of employment of Edward Meline. D (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request D a jury trial a nonjury trial (if more than one party, provide the name of each party requesting a jury trial) : 6. Trial date a. D The trial has been set for (date) : b. a No trial date has been set. This case will be ready for trial within 12 months of the date of the ling Unknown. of the complaint (if not, explain) : Present counsel for Ron Rabo et al. is awaiting the appellate court review of the order disqualifying counsel. c. Dates on which parties or attorneys will not be available for trial(specify dates and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the trial will take (check one) : a. days (specify number): 6 b. D hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial Attorney: by the attorney or party listed in the caption D by the following: Firm: Address: Telephone number: Fax number: E-mail address: . Party represented: D Additional representation is described in Attachment 8. 9. Preference D This case is entitled to preference (spec/r code section): 10. Alternative Dispute Resolution (ADR) a. Counsel D has E has not reviewed ADR options with the client. provided the ADR information package identied in rule 201 .9 to the client and has b. D All parties have agreed to a form of ADR. ADR will be completed by (date) : c. D The case has gone to an ADR process (indicate status) : CM'110 [New JU'Y 1- 20°21 Man/n Dean's Essential Forms TM CASE MANAGEMENT STATEMENT Page 2 of 4 \ t PLAINTIFF/PETITIONER: EDWARD R ARD MELINE NUMBER: 127180 —DEFENDANT/RESPONDENTJACK MELINE ’ 10. d. The party or parties are willing to participate in (check all that apply): (1) Mediation (2) D to close 15 days before Nonbinding judicial arbitration under Code of Civil Procedure section 1141 .12 (discovery arbitration under Cal. Rules of Court, rule 1612) (3) D order under Cal. Rules of rule to remain open until 30 days Nonbinding judicial arbitration under Code of Civil Procedure section 1141 .12 (discovery before trial; required Court. 1612) (4) D Binding judicial arbitration (5) D Binding private arbitration (6) D Neutral case evaluation (7) D Other (specify) : e. D This matter is subject to mandatory judicial arbitration because the amountincontroversy does not exceed the statutory limit. f. D elects Plaintiff to referthiscase tojudicial and arbitration agrees to recovery to the amount specied limit inCode of Civil Procedure section 1141 .1 1. g. D This case is exempt from judicial arbitration under rule 1600.5 of the California Rules of Court (specify exemption): 11. Settlement conference a The party or parties are willing to participate in an early settlement conference(specify when) z 12. Insurance a. D this statement(name) Insurance carrier, if any. for party ling : b. Reservation of rights: D Yes D No c. D Coverage issues will signicantly affect resolution of this case(exp/ain) : 13. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case, and describe the status. a Bankruptcy D Other (specify): Status: . 14. Related cases, consolidation, and coordination a. D There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: D Additional cases are described in Attachment 14a. b. D A motion to D ' consolidate D coordinate will be filed by (name party): 15. Bifurcation D The party or parties intend to lea motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 16. Other motions ~ D The party or parties expect to le the following motions before trial(specify moving party, type ofmotion, and issues): CM-“O [New July 1- 20021 CASE MANAGEMENT STATEMENT Page 3 of 4 Martin Dean's Essential Forms TM S l' PLAINTIFF/PETITIONER: EDWARD R ARD MELINE NUMBER: ”.180 ‘7) EFENDANT/RESPONDENTJACK MELINE 17. Discovery _ . a. D The party or parties have completed all discovery. b. a The following discovery will be completed by the date specied(descn'be Description all anticipated discovery): D_at§ Ea All discovery is on hold until the disqualication issue is resolved c. D The following discovery issues are anticipated (specify) : 18. Economic Litigation a. D This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90 through 98 will apply to this case. b. D This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be led (if checked, explain specically why economic litigation procedures relating to discovery or trial should not app/y to this case) : 19. Otherissues The party or parties request that the following additional matters be considered or determined at the case management conference (specify): Other parties have suggested the appointment of Judge Watkins as a referee. The appointment of a referee should be delayed until the Court determines if the real property isto be sold or divided (CCP section 873.010(a)). Appointment of a former mediator as a referee is problematical. 20. Meet and confer a. The party or parties have met and conferred with all parties on all subjects required by rule 212 of the California Rules of , Court (if not, explain): Counsel for Plaintiffs and Cross Complainants have not made any contact regarding the subjects specified in the Court Rule. b. After meeting and conferring as required by rule 212 of the California Rules of Court, the parties agree on the following (specify) : 21. Case management orders D I Previous case management orders in this case are (check one) : none attached as Attachment 21. 22. Total number of pages attached (if any) : 0 am completely familiar with this case and will be fully prepared to discuss the status of discovery and ADR, as well as other issues l raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: November 5, 2004 Raymond L. Sandelman (TYPE OR PRINT NAME) m L SJ.“ (SIGNATURE 0F PARTY OR ATTORNEY) b (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) D Additional signatures are attached 9M4“) [New JU'Y 1- 20°21 CASE MANAGEMENT STATEMENT Page 4 of 4 Martin Dean's Essential Forms TM PROOF OF SERVICE BY MAIL I, Linda Quinn, declare: 1. I am a resident of and employed in the County of Butte, State of California. I am, and was at the time of the service hereinafter mentioned, over the age of 18 years and not a party to the above-entitled cause. 2. On November for 5 collection , 2004, I served in the within United Case Management Statement, on the parties by placing and deposit the States mail, a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, at the law ofce of Raymond L. Sandelman, 3075 Cohasset Road, Suite 1, Chico, Butte County, California, addressed as follows: Nels A. Christensen James Berglund Christensen & Schwarz Attorney at Law 1 Governors Lane 1639 Bird Street Chico, CA 95926 Oroville, CA 95965 95973-0970 William A. Ward Richard L. Crabtree Attorney at Law Law Ofces of Richard L. Crabtree (530) 343-5090 / (530) 343-5091 (FAX) 9 Williamsburg Lane 854 Manzanita Court Suite 110 3075 COHASSET ROAD, SUITE 1, CHICO, CA RAYMOND L. SANDELMAN Chico, CA 95926 Chico, CA 95926 ATTORNEY AT LAw John Jeffery Carter John Jeffrey Carter Law Ofce P.O. Box 3606 Chico, CA 95927-3606 At that time there was regular delivery of United States mail between the place of deposit and place of address. 3. I am familiar with the practice of the law ofce of Raymond L. Sandelman for the collection and the processing of correspondence or mailing with the United States Postal Service. In accordance with the ordinary course of business, the above-mentioned document would have been deposited with the United States Postal Service on November 5/, 2004, the same day on which it was placed at the law ofce of Raymond L. Sandelman for deposit. I declare under penalty of perjury under the laws of the State of California that the akw foregoing is true and correct. @333 [\J Dated: November i) ,2004 Lida\Quinn\\ PROOF OF SERVICE