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{|GARY, TILL, BURLINGHAM & LYNCH
STEVEN R. BURLINGHAM, SB# 88544
| 5330 Madison Avenue, SuiteF Pon. i. =
WON
| Sacramento; California 95841 ee | Sure OF caltronnin on
\\'Telephone:. (916) 332-8122 0 a ar COUNTY DEPPLACER
F acsimile: Or), 332-8153.
&
Email: . - Steveb@gtblaw. com
ies CLERK
NOa
. Attorney for
fi J OSEPH MONTANEZ and
JESSENIA RIVERA-HINOJOS oot Deputy - ©
SUPERIOR COURT OF * CALIFORNIA,
oO
COUN TY OF PLACER |
Oo
|=
BS
NY
JOSEPH E. MONTANEZ, and CASE NO. scvooao742
: JESSENIA RIVERA-HINOJOS,
Be
ee
DECLARATION oF “SvEVEN R.
wo
eee
. Plaintiffs
SB
KR
ee
Bo
a
FAMILY. ‘LAW DEPARTMENT “e
ee
se
| THE: FAMILY NETWORK, INC.
YO
a
And
wo
ao
BILLY DeVORE and LISA GRIJALVA,
Oo
a
befendants
(Mo MS86
e
i
SY
nh
N
I, Steven R. Burlingham, declare:
w&
ON
an. ‘attorney at law, duly admitted to, practice before af
1. it am
NY
Courts oe ‘the State of california and ‘the attorney. of record
all the
NON
on
Plaintiffs, Jessenia Rivera- Hinojos and Joseph Montanez, herein.
|| for
Defendants have filed: an Adoption Request. in ‘this case
"Be
oN
aon
me
é “ «
(SAD-0003574) and the Request should be heard with Plaintiffs’
Complaint to- Rescind Relinquishments. The facts to-.be addressed are
DN
the same, namely: the manner in which and the circumstances
WO
BRB
surrounding the taking of Plaintiffs’ Relinquishments.
of .Thé Family
Oo
Bye Opposing’ counsel, David Karabinus, oft behalf
DO
Network, Inc., and Marc Gradstein, on behalf of. Billy DeVore and
An
Lisa Grijalva, agreed that the hearing of the Adoption, Request and
of the Complaint to Rescind Relingquishments (the Complaint herein)
oo
should:be consolidated arid the matter referred to the Family Law
Department. — Sée Emails attached as Exhibit “A”. We. believe
assignment to the Family law. Department is .appropriate, as’. that
is most conversant with issues. involving children and
department
visitation.
4, David Karabinus, on behalf of -The Family Network, .Inc.,
requested consolidation of the Petition for Writ of Mandate
also
into the other two matters; howéver, I oppose this, as
(SCV0040741)
addressed in the Petition for Writ. of Mandate arose after
the facts
Relinguishments (the facts underlying the Complaint to Rescind
the
Request arose. before the signing of the
and’ the Adoption
and the relief sought, namely the vacating of The
Relinguishments)
Inc.’s decision of February 14, 2018 and the
Family Network,.
of a-neutral decision-maker for the Plaintiffs’ Request
appointment
LIVILLETAT ITTL ATT ET
STLETLETAT ATAT ETAT
to Rescind Reélinguishments (CDSS form 508) is different from and
should precede the hearing.of the adoption matter.
I declare under penalty of perjury under the laws of the State
of California that the foregoing is true and correct.
Dated: February 20, 2018
STEVEN R. BURLINZHAM
Attorney for Plaintiffs
‘Steve Burlingham 3 eo oa om ;
From: Steve Burlingham
Sent: Tuesday, February 20, 2018 2:52 PM
To: ‘mhgradstein@gmail.com’; 'dkfamilylaw@yahoo.com'
Subject: DeVore-Grijalva-Montanez-Rivera Agreement to Consolidate and Assign to Family Law
Dept
Good afternoon, David and Marc!
This isto confirm our agreement this morning that:
1. Twillobtain an Order Shortening Time’on February 21, hopefully to obtain orders:
A. consolidating for hearing and trial the Complaint inthe referenced case (S-CV-0040742) with the Adoption
Request (SAD-0003574). David would like the Petition for Writ of Mandate
also consolidated which I oppose.
B. Requesting that the court assign all matters to the Family Law
Department;
C. Staying the adoption process except for supervisory visits, our
motion for visitation and Indian Child Welfare Act matters.
I will endeavor to have this matter set on Thursday, March 15.
Please confirm at your earliest convenience.
Steve Burlingham
Steven R. Burlingham
GARY, TILL & BURLINGHAM
Phone: (916) 332-8122 | Fax: (916) 332-8153 | SteveB@GTBilaw.com
5330 Madison Avenue, Suite F,
Sacramento, CA 95841 ,
CONFIDENTIALITY NOTICE: This is'a confidential
transinittal or may
communication be
otherwise are
If you
privileged.
legally nottheintended you.are
recipient,
you
that
notified
hereby havereceived in
transmittal
this and
error thatany dissemination,
review, of any
or copying
distribution in
contained.
information
of the orattached
to transmission
this have
If you
prohibited.
is strictly this communication
received please
in error, and
officé,
this
notify delete
immediately message
this and its
all
attachments.
TAX ADVICE DISCLOSURE: To compliance
ensure with by
imposed
requirements theIRS 20,we
in. Circular informyou we
unless
that, state
expressly in
otherwise this
any
(including
communication any
attachments), tax in
contained
advice is net
communication
this to
or written
intended be and
used, for
be used,
cannot purpose
the of (i)
under
penalties
avoiding the Revenue
Intemal Code or marketing,
(ii) promoting, party
to another
or recommending any or
transaction matter
other herein.
addressed
EXHIBIT A
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{|GARY, TILL, BURLINGHAM & LYNCH STEVEN R. BURLINGHAM, SB# 88544 | 5330 Madison Avenue, SuiteF Pon. i. = WON | Sacramento; California 95841 ee | Sure OF caltronnin on \\'Telephone:. (916) 332-8122 0 a ar COUNTY DEPPLACER F acsimile: Or), 332-8153. & Email: . - Steveb@gtblaw. com ies CLERK NOa . Attorney for fi J OSEPH MONTANEZ and JESSENIA RIVERA-HINOJOS oot Deputy - © SUPERIOR COURT OF * CALIFORNIA, oO COUN TY OF PLACER | Oo |= BS NY JOSEPH E. MONTANEZ, and CASE NO. scvooao742 : JESSENIA RIVERA-HINOJOS, Be ee DECLARATION oF “SvEVEN R. wo eee . Plaintiffs SB KR ee Bo a FAMILY. ‘LAW DEPARTMENT “e ee se | THE: FAMILY NETWORK, INC. YO a And wo ao BILLY DeVORE and LISA GRIJALVA, Oo a befendants (Mo MS86 e i SY nh N I, Steven R. Burlingham, declare: w& ON an. ‘attorney at law, duly admitted to, practice before af 1. it am NY Courts oe ‘the State of california and ‘the attorney. of record all the NON on Plaintiffs, Jessenia Rivera- Hinojos and Joseph Montanez, herein. || for Defendants have filed: an Adoption Request. in ‘this case "Be oN aon me é “ « (SAD-0003574) and the Request should be heard with Plaintiffs’ Complaint to- Rescind Relinquishments. The facts to-.be addressed are DN the same, namely: the manner in which and the circumstances WO BRB surrounding the taking of Plaintiffs’ Relinquishments. of .Thé Family Oo Bye Opposing’ counsel, David Karabinus, oft behalf DO Network, Inc., and Marc Gradstein, on behalf of. Billy DeVore and An Lisa Grijalva, agreed that the hearing of the Adoption, Request and of the Complaint to Rescind Relingquishments (the Complaint herein) oo should:be consolidated arid the matter referred to the Family Law Department. — Sée Emails attached as Exhibit “A”. We. believe assignment to the Family law. Department is .appropriate, as’. that is most conversant with issues. involving children and department visitation. 4, David Karabinus, on behalf of -The Family Network, .Inc., requested consolidation of the Petition for Writ of Mandate also into the other two matters; howéver, I oppose this, as (SCV0040741) addressed in the Petition for Writ. of Mandate arose after the facts Relinguishments (the facts underlying the Complaint to Rescind the Request arose. before the signing of the and’ the Adoption and the relief sought, namely the vacating of The Relinguishments) Inc.’s decision of February 14, 2018 and the Family Network,. of a-neutral decision-maker for the Plaintiffs’ Request appointment LIVILLETAT ITTL ATT ET STLETLETAT ATAT ETAT to Rescind Reélinguishments (CDSS form 508) is different from and should precede the hearing.of the adoption matter. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Dated: February 20, 2018 STEVEN R. BURLINZHAM Attorney for Plaintiffs ‘Steve Burlingham 3 eo oa om ; From: Steve Burlingham Sent: Tuesday, February 20, 2018 2:52 PM To: ‘mhgradstein@gmail.com’; 'dkfamilylaw@yahoo.com' Subject: DeVore-Grijalva-Montanez-Rivera Agreement to Consolidate and Assign to Family Law Dept Good afternoon, David and Marc! This isto confirm our agreement this morning that: 1. Twillobtain an Order Shortening Time’on February 21, hopefully to obtain orders: A. consolidating for hearing and trial the Complaint inthe referenced case (S-CV-0040742) with the Adoption Request (SAD-0003574). David would like the Petition for Writ of Mandate also consolidated which I oppose. B. Requesting that the court assign all matters to the Family Law Department; C. Staying the adoption process except for supervisory visits, our motion for visitation and Indian Child Welfare Act matters. I will endeavor to have this matter set on Thursday, March 15. Please confirm at your earliest convenience. Steve Burlingham Steven R. Burlingham GARY, TILL & BURLINGHAM Phone: (916) 332-8122 | Fax: (916) 332-8153 | SteveB@GTBilaw.com 5330 Madison Avenue, Suite F, Sacramento, CA 95841 , CONFIDENTIALITY NOTICE: This is'a confidential transinittal or may communication be otherwise are If you privileged. legally nottheintended you.are recipient, you that notified hereby havereceived in transmittal this and error thatany dissemination, review, of any or copying distribution in contained. information of the orattached to transmission this have If you prohibited. is strictly this communication received please in error, and officé, this notify delete immediately message this and its all attachments. TAX ADVICE DISCLOSURE: To compliance ensure with by imposed requirements theIRS 20,we in. Circular informyou we unless that, state expressly in otherwise this any (including communication any attachments), tax in contained advice is net communication this to or written intended be and used, for be used, cannot purpose the of (i) under penalties avoiding the Revenue Intemal Code or marketing, (ii) promoting, party to another or recommending any or transaction matter other herein. addressed EXHIBIT A