Lund v. Lund, 795 N.W.2d 318

Orvell and Betty Lund married in 1956; Betty filed for divorce in November 2009.
Orvell responded stating he would not hire counsel and would rely on a fair and equitable settlement.
Notice of trial issued January 11, 2010, scheduling trial for April 26, 2010.
Orvell sought a continuance March 19, 2010 due to a conflicting attorney schedule; district court denied March 22, 2010.
Orvell renewed continuance and moved to disqualify the judge on April 7, 2010; motions denied April 14, 2010; attorney Cole withdrew April 19, 2010.
Trial occurred April 26, 2010; district court granted divorce and distributed marital property; challenged on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the continuance denial was an abuse of discretion	Orvell	Lund	No abuse of discretion
Whether the denial of disqualification was error	Orvell	Lund	No error; no bias shown
Whether the property distribution was clearly erroneous	Orvell	Lund	Not clearly erroneous
Whether the stay-denial issue is reviewable on appeal	Orvell	Lund	Appropriate procedural path to seek stay; appeal deemed from final judgment

Woodward v. Woodward, 2010 ND 143 (N.D. 2010) (interlocutory orders generally not appealable; final judgment reviewed)
Martinson v. Martinson, 2010 ND 110 (N.D. 2010) (interlocutory review and final judgment considerations)
Isaacson v. Isaacson, 2010 ND 18 (N.D. 2010) (consistent judgment standard for appeals from related rulings)
In re D.C.S.H.C., 2007 ND 102 (N.D. 2007) (continuance and trial management principles)
Frohlich v. Frohlich, 2007 ND 45 (N.D. 2007) (diligence in securing counsel; ten-day rule context)
State v. Waters, 542 N.W.2d 742 (N.D. 1996) (considerations for continuance and counsel availability)
Kjolsrud v. MKB Mgmt. Corp., 2003 ND 144 (N.D. 2003) (avoid advisory opinions; procedural stay guidance)
Gustafson v. Gustafson, 2008 ND 233 (N.D. 2008) (restitution when judgment reversed on appeal)