Preview
'—
CM-110
ATI’ORNEY OR PARTY WITHOUT ATI'ORNEY (Name, Stale Bar number, and address). FOR COURT USE ONLY
'John Jefferey Carter (SBN 079857)
Carter Law Ofce
P.O. Box 3606, Chico, CA 95927 .
(530) 342-61 96
TELEPHONE No.; (530) 342-61 95
FAX N0. (Optional):
EMAIL ADDRESS (Opt/onao:
ATTORNEY FORIName): See attached Exhibit "A"
SUPERIOR COURT OF CALIFORNIA, COUNTY OF
STREEr ADDRESS:655 Oleander Avenue
Same as Above
MAILING ADDRESS:
Chico, CA 95926
CITY AND ZIP CODE:
BRANCH NAME: Butte County Superior Court
PLAINTIFF/PETITIONER: Steven and Robert Meline, et al.
DEFENDANT/RESPONDENT: Randall c. Meline, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER
(Check one): UNLIMITED CAsE E LIMITED CASE 127180 B
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: January 21, 2014 Time: 8:30 a.m. Dept: Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name):
INSTRUCTIONS: All applicable boxes must be checked, and the specied information must be
provided.
1.
a
b.
-
Party or parties (answer one):
This statementIs submitted by party (name): Edward
This statement'Is submitted jointly by parties (names):
Richard Meline and Charlene Meline ("Plaintiffs")
2. Complaint and cross-complaint (to be answered by plaintiffs and cross—complainants only)
a. The complaint was led on (date): March 6, 2002
b. E The cross-complaint. if any, was led on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. E The following parties named in the complaint or cross-complaint
(1) E have not been served (specify names and explain why not):
(2) E have been served but have not appeared and have not been dismissed (specify names):
(3) have had a default entered against them (specify names):
D The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
3- Type 0f 0339 "1 - complaint E cross-complaint (Describe, including causes of action):
See attached Exhibit "A"
Page1of 5
Form Adopted for Mandatory Use
Judicial Council of Calitomla
CASE MANAGEMENT STATEMENT Cal. Rules of Court.
3720-3730
rules
CM-1 1 0 [Rev. July 1. 201 1]
www.courls.w.gov
4/
«I
CM-1 1 0
CASENUMBER:
_ PLAINTIFF/PHITIONER; Steven andRobert Meline, et aI.
. 127180 B
DEFENDANT/RESPONDENT: Randall C. Mellne. et al-
4. b. Provide a brief statement of the case, including any damages. (prersonal 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.)
See attached Exhibit "A"
(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 a jury trial a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
See attached Exhibit "A"
6. Trial date
a. The tn'al has been setfor (date):APT“ 7'1 1. 2014
b. E No trial date has been set. This case will be ready for tn'al within 12 months of the date of the ling
of the complaint (if
not, explain):
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 tn'al will take (check one):
a. days (specify number): 5
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number. f. Fax numben
e. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
9. Preference
This case CCP § 36 and
is entitled to preference (specify code section): pursuant to order entered herein 6/1 3/03
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADRprocesses are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel has has not provided the ADR information package identied
in rule 3.221to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party has E has not reviewed the ADR information package identied in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is sub'ect to mandatoryjudicial arbitration under Code of Civil Procedure section 1141 .11 or to civil action
under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
mediationl
statutory imit.
(2) E Civil Procedure section 1141 .1 1.
in Code of
Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specied
(3) This case of the California Rules of Courtor from civil action
is exempt from judicial arbitration under rule 3.811
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM-“OIRWU'Y 1-2°11] CASE MANAGEMENT STATEMENT
$
CM-110
_ PLAINTIFF/PETITIONER: Steven and Robert Meline, et al.
CASE NUMBER:
127180 B
DEFENDANT/RESPONDENT: Randall C_ Meline, et al.
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in. or
have already participated in (check all that apply and provide the speciedinformation):
The party or parties completing have agreed to
If the party or parties completing this form in the case
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the patties’ ADR
processes (check all that apply): stipulation):
DUDE
Mediation session not yet scheduled
(1) Mediation
m Mediation session scheduled for (date):
Agreed to complete mediation by (date):
Mediation completed on (date):
DUDE
Settlement conference not yet scheduled
Jan 27, 2014
(2) Settlement
conference
m Settlement conference scheduled for (date):
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
DUDE
Neutral evaluation not yet scheduled
(3) Neutral evaluation E Neutral evaluation scheduled for (date):
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
DUDE
Judicial arbitration not yet scheduled
(4) Nonbinding judicial
arbitration
E Judicial arbitration scheduled for (date):
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
DUDE
Private arbitration not yet scheduled
(5) Binding private
arbitration
E Private arbitration scheduled for (date):
Agreed to complete pn'vate arbitration by (date):
Private arbitration completed on (date):
DUDE
ADR session not yet scheduled
(6) Other (specify): E ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. July 1 . 201 1] Pages of5
CASE MANAGEMENT STATEMENT
w
CM-JJQ
CASE ”UMBER:
—
PLAINTIFF/PETITIONER: Steven and Robert Meline, et al.
. 127180 B
DEFENDANT/RESPONDENT: Randall C. Mellne. et al.
1 1.Insurance
a. this statement (name):
Insurance carn'er, if any, for party ling
b. Reservation of rights: Yes No
c. E Coverage issues will signicantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
Bankruptcy E Other (specify):
Status:
13. Related cases, consolidation, and coordination
a_ E There are companion, underlying. or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
Additional cases are described in Attachment 133.
b. E A motion to E consolidate coordinate will be led by (name party):
14. Bifurcation
E 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):
15. Other motions
E The party or parties expect to lethe following motions before tn'al (specify moving pan‘y, type of motion, and issues):
16. Discovery
a. The party or parties have completed all discovery.
b. The following discovery will be completed by the date specied (describe all anticipated discovery):
Pam Description
As to percipient witness March 10, 2014
As to expert witness March 24, 2014
c, The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM—110 [Rem
July
1. 2011]
CASE MANAGEMENT STATEMENT Page 4 of 5
CM-1 1 0
CASE NUMBER
PLAINTIFF/PETITIONER: Steven and Robert Meline, et al.
_ . 1271 8O B
DEFENDANT/RESPONDENT: Randa" C- Me'me: et a'-
17. Economic litigation
a. 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 90-98 will apply to this case.
b. E 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 specicallywhy economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19 Meet and confer
a - The party or parties have met and conferred with all parties on all subjects required by rule 3. 724 of the California Rules
of Court (if not, explain):
The parties have engaged and continue to engage in numerous substantive meetings and negotiations
regarding the actions. The "C" action tentatively has been resolved. The "B" action has not.
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any): 2
and will be fully prepared to discuss the
l am completely familiar with this case of discovery and alternative dispute resolution.
as well as otherIssues raised by this statement and will possess the authori status 'to stipulations on these'Issues at the time of
the case management conference, including the written authority of the =
Date: January 2, 2014
JOHN JEFFERY CARTER
(TYPE OR PRINT NAME)
/ , [/— // OR ATTORNEY)
(SIGNATUREyPARTY
(TYPE OR PRINT NAME) (SIGNATURE 0F PARTY 0R ATTORNEY)
Additional signatures are attached.
CM-110 (Rev. July 1. 2011]
CASE MANAGEMENT STATEMENT Page 5 of5
Exhibit “A”
Attorney Representation: Randall C. Meline and Daniel P. Jeffers, Co-Trustees of the Edward
Richard Meline and Charlene M. Meline Irrevocable Living Trust Agreement No. Two dated December
30, 1992.
4.a. The action is for partition of certain Butte County real property known as the “Range
Property.”
4.b. The parties to this action are four branches of the same family who wish to partition the
Range Property owned in varying percentages by them. The action has been generally consensually
referred to the Hon. Noel H. Watkins, Judge (Ret’d) as referee by stipulation of the parties and order
entered thereon on November 5, 2013, and he is now presiding over it.
5. See Section 4.b. above.
PROOF OF SERVICE
Meline v. Meline, et al.
Butte County Superior Court Case No. 127180 B
I am a citizen of the United States and am a resident of the County of Butte. I am over the age of 18
years and not a party to the within action; my business address is CARTER LAW OFFICE, 329 Flume
Street, Chico, California 95928.
On this date, I served the foregoing document(s) described as:
Case Management Statement
On the parties below by placing a true copy thereof in a sealed envelope and served same on the
parties/counsel, addressed as follows:
Nels A. Christensen Hon. Noel H. Watkins, Judge (Ret’d)
Christensen & Schwarz, LLP P.O. Box 33
l Governors Lane Red Bluff, CA 96080
Chico, CA 95926
10 Charleton S. Pearse Jody Burgess
Lenahan, Lee, Slater & Pearse, LLP Maire & Burgess
11 1030 Fifteenth Street, Suite 300 PO Drawer 994607
Sacramento, CA 95814 Redding, CA 96099-4607
12
13
The following is the procedure in which service of this document was effected:
14
X U.S. Postal Service (placing such envelope(s) with postage thereon illy prepaid in the
15 designated area for outgoing mail in accordance with this ofce’s practice, whereby the
mail is deposited in the U.S. mailbox in the City of Chico, California aer the close of the
16 day’s business).
17 Federal Express
18 Express Mail
19 Personal Service
20 Facsimile
21
I declare under penalty of perjury that the foregoing is true and correct and that this document is
22 executed at Chico, California on January 2, 2014.
23
24
NICOLE HEINDELL
25
26
27
28
Preview
'— CM-110 ATI’ORNEY OR PARTY WITHOUT ATI'ORNEY (Name, Stale Bar number, and address). FOR COURT USE ONLY 'John Jefferey Carter (SBN 079857) Carter Law Ofce P.O. Box 3606, Chico, CA 95927 . (530) 342-61 96 TELEPHONE No.; (530) 342-61 95 FAX N0. (Optional): EMAIL ADDRESS (Opt/onao: ATTORNEY FORIName): See attached Exhibit "A" SUPERIOR COURT OF CALIFORNIA, COUNTY OF STREEr ADDRESS:655 Oleander Avenue Same as Above MAILING ADDRESS: Chico, CA 95926 CITY AND ZIP CODE: BRANCH NAME: Butte County Superior Court PLAINTIFF/PETITIONER: Steven and Robert Meline, et al. DEFENDANT/RESPONDENT: Randall c. Meline, et al. CASE MANAGEMENT STATEMENT CASE NUMBER (Check one): UNLIMITED CAsE E LIMITED CASE 127180 B (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: January 21, 2014 Time: 8:30 a.m. Dept: Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): INSTRUCTIONS: All applicable boxes must be checked, and the specied information must be provided. 1. a b. - Party or parties (answer one): This statementIs submitted by party (name): Edward This statement'Is submitted jointly by parties (names): Richard Meline and Charlene Meline ("Plaintiffs") 2. Complaint and cross-complaint (to be answered by plaintiffs and cross—complainants only) a. The complaint was led on (date): March 6, 2002 b. E The cross-complaint. if any, was led on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. E The following parties named in the complaint or cross-complaint (1) E have not been served (specify names and explain why not): (2) E have been served but have not appeared and have not been dismissed (specify names): (3) have had a default entered against them (specify names): D The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case 3- Type 0f 0339 "1 - complaint E cross-complaint (Describe, including causes of action): See attached Exhibit "A" Page1of 5 Form Adopted for Mandatory Use Judicial Council of Calitomla CASE MANAGEMENT STATEMENT Cal. Rules of Court. 3720-3730 rules CM-1 1 0 [Rev. July 1. 201 1] www.courls.w.gov 4/ «I CM-1 1 0 CASENUMBER: _ PLAINTIFF/PHITIONER; Steven andRobert Meline, et aI. . 127180 B DEFENDANT/RESPONDENT: Randall C. Mellne. et al- 4. b. Provide a brief statement of the case, including any damages. (prersonal 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.) See attached Exhibit "A" (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 a jury trial a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): See attached Exhibit "A" 6. Trial date a. The tn'al has been setfor (date):APT“ 7'1 1. 2014 b. E No trial date has been set. This case will be ready for tn'al within 12 months of the date of the ling of the complaint (if not, explain): 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 tn'al will take (check one): a. days (specify number): 5 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number. f. Fax numben e. E-mail address: g. Party represented: Additional representation is described in Attachment 8. 9. Preference This case CCP § 36 and is entitled to preference (specify code section): pursuant to order entered herein 6/1 3/03 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADRprocesses are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel has has not provided the ADR information package identied in rule 3.221to the client and reviewed ADR options with the client. (2) For self-represented parties: Party has E has not reviewed the ADR information package identied in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) This matter is sub'ect to mandatoryjudicial arbitration under Code of Civil Procedure section 1141 .11 or to civil action under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the mediationl statutory imit. (2) E Civil Procedure section 1141 .1 1. in Code of Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specied (3) This case of the California Rules of Courtor from civil action is exempt from judicial arbitration under rule 3.811 mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-“OIRWU'Y 1-2°11] CASE MANAGEMENT STATEMENT $ CM-110 _ PLAINTIFF/PETITIONER: Steven and Robert Meline, et al. CASE NUMBER: 127180 B DEFENDANT/RESPONDENT: Randall C_ Meline, et al. 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in. or have already participated in (check all that apply and provide the speciedinformation): The party or parties completing have agreed to If the party or parties completing this form in the case this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the patties’ ADR processes (check all that apply): stipulation): DUDE Mediation session not yet scheduled (1) Mediation m Mediation session scheduled for (date): Agreed to complete mediation by (date): Mediation completed on (date): DUDE Settlement conference not yet scheduled Jan 27, 2014 (2) Settlement conference m Settlement conference scheduled for (date): Agreed to complete settlement conference by (date): Settlement conference completed on (date): DUDE Neutral evaluation not yet scheduled (3) Neutral evaluation E Neutral evaluation scheduled for (date): Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): DUDE Judicial arbitration not yet scheduled (4) Nonbinding judicial arbitration E Judicial arbitration scheduled for (date): Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): DUDE Private arbitration not yet scheduled (5) Binding private arbitration E Private arbitration scheduled for (date): Agreed to complete pn'vate arbitration by (date): Private arbitration completed on (date): DUDE ADR session not yet scheduled (6) Other (specify): E ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. July 1 . 201 1] Pages of5 CASE MANAGEMENT STATEMENT w CM-JJQ CASE ”UMBER: — PLAINTIFF/PETITIONER: Steven and Robert Meline, et al. . 127180 B DEFENDANT/RESPONDENT: Randall C. Mellne. et al. 1 1.Insurance a. this statement (name): Insurance carn'er, if any, for party ling b. Reservation of rights: Yes No c. E Coverage issues will signicantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Bankruptcy E Other (specify): Status: 13. Related cases, consolidation, and coordination a_ E There are companion, underlying. or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: Additional cases are described in Attachment 133. b. E A motion to E consolidate coordinate will be led by (name party): 14. Bifurcation E 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): 15. Other motions E The party or parties expect to lethe following motions before tn'al (specify moving pan‘y, type of motion, and issues): 16. Discovery a. The party or parties have completed all discovery. b. The following discovery will be completed by the date specied (describe all anticipated discovery): Pam Description As to percipient witness March 10, 2014 As to expert witness March 24, 2014 c, The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM—110 [Rem July 1. 2011] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-1 1 0 CASE NUMBER PLAINTIFF/PETITIONER: Steven and Robert Meline, et al. _ . 1271 8O B DEFENDANT/RESPONDENT: Randa" C- Me'me: et a'- 17. Economic litigation a. 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 90-98 will apply to this case. b. E 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 specicallywhy economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19 Meet and confer a - The party or parties have met and conferred with all parties on all subjects required by rule 3. 724 of the California Rules of Court (if not, explain): The parties have engaged and continue to engage in numerous substantive meetings and negotiations regarding the actions. The "C" action tentatively has been resolved. The "B" action has not. b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 2 and will be fully prepared to discuss the l am completely familiar with this case of discovery and alternative dispute resolution. as well as otherIssues raised by this statement and will possess the authori status 'to stipulations on these'Issues at the time of the case management conference, including the written authority of the = Date: January 2, 2014 JOHN JEFFERY CARTER (TYPE OR PRINT NAME) / , [/— // OR ATTORNEY) (SIGNATUREyPARTY (TYPE OR PRINT NAME) (SIGNATURE 0F PARTY 0R ATTORNEY) Additional signatures are attached. CM-110 (Rev. July 1. 2011] CASE MANAGEMENT STATEMENT Page 5 of5 Exhibit “A” Attorney Representation: Randall C. Meline and Daniel P. Jeffers, Co-Trustees of the Edward Richard Meline and Charlene M. Meline Irrevocable Living Trust Agreement No. Two dated December 30, 1992. 4.a. The action is for partition of certain Butte County real property known as the “Range Property.” 4.b. The parties to this action are four branches of the same family who wish to partition the Range Property owned in varying percentages by them. The action has been generally consensually referred to the Hon. Noel H. Watkins, Judge (Ret’d) as referee by stipulation of the parties and order entered thereon on November 5, 2013, and he is now presiding over it. 5. See Section 4.b. above. PROOF OF SERVICE Meline v. Meline, et al. Butte County Superior Court Case No. 127180 B I am a citizen of the United States and am a resident of the County of Butte. I am over the age of 18 years and not a party to the within action; my business address is CARTER LAW OFFICE, 329 Flume Street, Chico, California 95928. On this date, I served the foregoing document(s) described as: Case Management Statement On the parties below by placing a true copy thereof in a sealed envelope and served same on the parties/counsel, addressed as follows: Nels A. Christensen Hon. Noel H. Watkins, Judge (Ret’d) Christensen & Schwarz, LLP P.O. Box 33 l Governors Lane Red Bluff, CA 96080 Chico, CA 95926 10 Charleton S. Pearse Jody Burgess Lenahan, Lee, Slater & Pearse, LLP Maire & Burgess 11 1030 Fifteenth Street, Suite 300 PO Drawer 994607 Sacramento, CA 95814 Redding, CA 96099-4607 12 13 The following is the procedure in which service of this document was effected: 14 X U.S. Postal Service (placing such envelope(s) with postage thereon illy prepaid in the 15 designated area for outgoing mail in accordance with this ofce’s practice, whereby the mail is deposited in the U.S. mailbox in the City of Chico, California aer the close of the 16 day’s business). 17 Federal Express 18 Express Mail 19 Personal Service 20 Facsimile 21 I declare under penalty of perjury that the foregoing is true and correct and that this document is 22 executed at Chico, California on January 2, 2014. 23 24 NICOLE HEINDELL 25 26 27 28