Preview
Raymond L. Sandelman SBN 078020
Attorney at Law F Superior Court of California F
196 Cohasset Road, Suite 225 County of Butte
Chico, CA 95926-2284 |
(530) 343-5090 / (530) 343-5091 (Fax) 12/9/2020 L
Email:Raymond@sandelmanlaw.com
D
Attorney for Wayne A. Cook, individually By Deputy
Electronically FILED
And as Trustee of The Wayne A. Cook 1998
Family Trust Dated 12/29/98
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 IN AND FOR THE COUNTY OF BUTTE
11 WAYNE A. COOK, TRUSTEE OF THE NO.: 20CV00905
WAYNE A. COOK 1998 FAMILY
REPLY BRIEF IN SUPPORT OF MOTION
12 TRUST DATED 12/29/98,
FOR ORDERS DIRECTED TO JOHN
13 Plaintiff, DENTON, CONSERVATOR AND _ HIS
COUNSEL (A) DEEMING MATTERS
14 ADMITTED, (B) COMPELLING ANSWERS
15 TO INTERROGATORIES, (C) COMPELLING
RESPONSES TO DOCUMENT DEMANDS,
16 EDWARD F. NIDEROST, et. al., AND (D) FOR SANCTIONS
17 Defendants.
Attached Document: Further Declaration of
18 / Raymond L. Sandelman
19 AND RELATED CROSS COMPLAINTS Hearing Date: 12/16/2020
/ Hearing Time: 9:00 a.m.
20)
Department: 1
21 Judge: Tamara Mosbarger
Date of Complaint: 4/22/2020
22 Trial Date: None Set
23
24 1. No Discovery Responses Have Been Received
25 This reply brief is nearly identical to the reply brief supporting the motion filed by Wayne
26) Cook, Trustee of The Wayne A. Cook 1998 Family Trust Dated 12/29/98 (hereafter referred to as
27 “Wayne Cook, Trustee”) against John Denton, successor trustee of The Edward F. Niderost
28 Revocable Living Trust Dated November 8, 1998.
1
REPLY BRIEF IN SUPPORT OF MOTION FOR ORDERS DIRECTED TO JOHN DENTON, CONSERVATOR AND
HIS COUNSEL (A) DEEMING MATTERS ADMITTED, (B) COMPELLING ANSWERS TO INTERROGATORIES,
(C) COMPELLING RESPONSES TO DOCUMENT DEMANDS, AND (D) FOR SANCTIONS
As of 1:00 p.m. on December 9, 2020, John Denton, Conservator of the Estate of Edward
F. Niderost (hereafter referred to as “John Denton, Conservator”) has still not responded to requests
for admissions, two sets of form interrogatories, or two sets of document demands that were
propounded by Wayne Cook, Trustee on September 2, 2020 (Exs. 1-5 to the Declaration of Raymond
L. Sandelman filed with the Moving Brief). Ms. Knowles has made promises before that she has not
complied with (see the unfulfilled promises to file amended pleadings that were discussed in the two
motions for judgment on the pleadings heard by the Court on December 9, 2020 and her unfulfilled
promises to provide further responses to eight sets of discovery (Ex. 6 to the Moving Papers).
The Declaration Of Sara Knowles does not discuss the mandatory “deemed admission”
Bo 10 provisions of Code of Civil Procedure section 2033.280 subdivision (d). The matters must be deemed
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2. Ms. Knowles’ Declaration Makes A Mockery Of The Requirements
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£4204 14 That Declarations Be Supported By Statements Made Under Penalty Of Perjury
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BR 15 Ms. Knowles’ declaration states that it is a response, not an opposition. She then argues the
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16 law in an analysis that is identical to a brief. This makes a mockery of the requirements that
17 declarations be supported by statements made under penalty of perjury.
18 5) [9:49.5] Declarations limited to facts, not legal arguments: It is improper
to include legal arguments in a declaration. (E.g., “the interests of justice require ...”
19
or “the following matters constitute ‘good cause’ ...”) As noted by one court, this is
20 “a sloppy practice which should stop ... (I)t makes a mockery of the requirements that
declarations be supported by statements made under penalty of perjury.” [Marriage of
21 Heggie (2002) 99 CA4th 28, 30, 120 CR2d 707, 709, fn. 3]
22
Weil & Brown, California Practice Guide: Civil Procedure Before Trial (The Rutter
23 Group 2020)
24 The reason for the declaration rather than an opposition brief is clear from Paragraph 11 of
25 Ms. Knowles’ declaration. She understands that California Rules of Court Rule 3.1348 discusses
26 circumstances where sanctions are sometimes not awarded when there is no opposition. She called
27 her opposition a “response” thinking it would help. But substantively it is an opposition. Also, she
28 ignored the provisions of Code of Civil Procedure section 2033.280 subdivision (d) which makes an
2
REPLY BRIEF IN SUPPORT OF MOTION FOR ORDERS DIRECTED TO JOHN DENTON, CONSERVATOR AND,
HIS COUNSEL (A) DEEMING MATTERS ADMITTED, (B) COMPELLING ANSWERS TO INTERROGATORIES,
(C) COMPELLING RESPONSES TO DOCUMENT DEMANDS, AND (D) FOR SANCTIONS
award of sanctions mandatory (See the next section of this Brief).
3. An Award Of Sanctions Is Mandatory
Ms. Knowles’s declaration does not dispute the law that sanctions are mandatory, but she
seeks to have sanctions “adjusted” because she claims that there was substantial justification for her
conduct. She does not dispute that the amount sought is a reasonable sum for the motion before the
court. The purported “substantial justification” is her failure to calendar the due date for the
discovery. This is frivolous. Lawyers have been known to make calendar errors and to then state
that they made a mistake, or that their conduct was excusable neglect (Comunidad en Accion v. Los
Angeles City Council (2013) 219 Cal.App.4th 1116, 1134-1135),' but no case supports Ms.
Bo 10 Knowles’ claim that there is substantial justification when an attorney fails to calendar the response
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15 Sandelman filed with the Moving Brief) by first class mail and email. The document demands that
16 were propounded (Exs. 4-5 to the Declaration of Raymond L. Sandelman filed with the Moving
17 Brief) expressly specify the date of production is October 8, 2020. Ms. Knowles claims that the
18 discovery she received on September 2, 2020 specifying a response date of October 8, 2020, with
19 the written notice that the stay for judicial foreclosure had been lifted, was believed to be part of
20 discovery withdrawn on July 2, 2020. This is not credible.
21 On July 2, 2020 very specific discovery was withdrawn (See Ex. 7 to the Further Declaration
22 of Raymond L. Sandelman), The Exhibit 7 July 2, 2020 email states “If there is any discovery
23
* Nicholson v. Rose (1980) 106 Cal.App.3d 457, 460-461 holds that counsel’s course of dilatory tactics and
24 spurious objections throughout the litigation can be grounds for not granting relief for a calendaring error. Ms. Knowles’
Declaration does not dispute that her clients have not provided further responses to eight sets of discovery promised on
25 September 15, 2020, that her clients were sanctioned $1,000 by the court for misuse of the discovery process on
November 9, 2020, that there is a second discovery motion filed by Randal Culley set for hearing on December 16,
26 2020, and there is a pattern of misuse of the discovery process. Ms. Knowles also promised to amend her pleadings
and then failed to do so, which required plaintiff to file motions for judgment on the pleadings as to the Answer and
27 Cross Complaint. More could be said, but when sanctions are mandatory it is inappropriate to get involved in Ms.
Knowles evasive, legally, irrelevant arguments.
28
3
REPLY BRIEF IN SUPPORT OF MOTION FOR ORDERS DIRECTED TO JOHN DENTON, CONSERVATOR AND
HIS COUNSEL (A) DEEMING MATTERS ADMITTED, (B) COMPELLING ANSWERS TO INTERROGATORIES,
(C) COMPELLING RESPONSES TO DOCUMENT DEMANDS, AND (D) FOR SANCTIONS
propounded after the June 12, 2020 Cross Complaint that you contend is only applicable to issues
raised in the Complaint, let me know. If your concerns have merit I will withdraw the inquiries.”
Ms. Knowles does not claim that she ever advised Raymond L. Sandelman that any other discovery
was applicable to the stayed judicial foreclosure action.
Attorneys make mistakes, but to claim that she believed that the amended discovery was
withdrawn is not “substantial justification”; it is negligent conduct.
Ms. Knowles’ Declaration cites Code of Civil Procedure section 2023.010 to argue that
sanctions are discretionary, but she has overlooked the analysis in Weil & Brown California Practice
Guide: Civil Procedure Before Trial (The Rutter Group 2020) cited in the Moving Brief that there
Be 10 are no excuses that will be accepted to avoid the mandatory provisions that sanctions be awarded.
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(5) [8:1376] Monetary sanction also mandatory: Although delayed responses
Ze 12 may defeat a motion to compel, they will not avoid monetary sanctions. Regardless of
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14 necessitated the filing of the deemed-admitted motion. [CCP § 2033.280(c)]
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BS 15 sanctions for delay are mandatory. The purpose is to provide incentive to timely
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respond to RFAs: i.e., no excuses accepted.
16
17 Ms. Knowles’ Declaration notes that there was other discovery in this case, but ignores the
18 fact that her client has not properly responded to the other discovery (See the itemization at footnote
19 1, supra). The existence of other discovery is an indication that calendaring in this case is critical;
20 it is not the situation where there is a single set of discovery that can be remembered in one’s head.
21
22 4. Conclusion
23 The Court should (a) deem that the truth of matters, specified in Wayne Cook, Trustee's
24 Request for Admissions, be admitted, (b) compel answers to the two sets of form interrogatories,
25 (c) compel responses to the two sets of document demands, and (d) order John Denton, Conservator
26 of the Estate of Edward F. Niderost and his attorney Leland, Morrissey & Knowles LLP to jointly
27 and severally pay the sum of $720.00 in attorney’s fees and costs to Wayne Cook, Trustee.
28 Because there is no opposition to the motion for preference set for hearing on December 16,
4
REPLY BRIEF IN SUPPORT OF MOTION FOR ORDERS DIRECTED TO JOHN DENTON, CONSERVATOR AND)
HIS COUNSEL (A) DEEMING MATTERS ADMITTED, (B) COMPELLING ANSWERS TO INTERROGATORIES,
(C) COMPELLING RESPONSES TO DOCUMENT DEMANDS, AND (D) FOR SANCTIONS
1}| 2020, the discovery should be responded to as soon as possible. Given that the discovery was
2|| propounded on September 2, 2020, it is appropriate that the Court order that verified responses to
3}| the interrogatories and document demands be served on or before December 21, 2020.
4
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Dated: Comber 20L0 QL Sob
Raymond L. Sandelman
Attorney for Wayne Cook, Trustee,
Individually and as Successor Trustee
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REPLY BRIEF IN SUPPORT OF MOTION FOR ORDERS DIRECTED TO JOHN DENTON, CONSERVATOR AND)
HIS COUNSEL (A) DEEMING MATTERS ADMITTED, (B) COMPELLING ANSWERS TO INTERROGATORIES,
(C) COMPELLING RESPONSES TO DOCUMENT DEMANDS, AND (D) FOR SANCTIONS
Table of Exhibits
Exhibit 7: July 2, 2020 email to Sara Knowles.
Exhibit 8: September 2, 2020 email to Sara Knowles.
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Preview
Raymond L. Sandelman SBN 078020 Attorney at Law F Superior Court of California F 196 Cohasset Road, Suite 225 County of Butte Chico, CA 95926-2284 | (530) 343-5090 / (530) 343-5091 (Fax) 12/9/2020 L Email:Raymond@sandelmanlaw.com D Attorney for Wayne A. Cook, individually By Deputy Electronically FILED And as Trustee of The Wayne A. Cook 1998 Family Trust Dated 12/29/98 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 IN AND FOR THE COUNTY OF BUTTE 11 WAYNE A. COOK, TRUSTEE OF THE NO.: 20CV00905 WAYNE A. COOK 1998 FAMILY REPLY BRIEF IN SUPPORT OF MOTION 12 TRUST DATED 12/29/98, FOR ORDERS DIRECTED TO JOHN 13 Plaintiff, DENTON, CONSERVATOR AND _ HIS COUNSEL (A) DEEMING MATTERS 14 ADMITTED, (B) COMPELLING ANSWERS 15 TO INTERROGATORIES, (C) COMPELLING RESPONSES TO DOCUMENT DEMANDS, 16 EDWARD F. NIDEROST, et. al., AND (D) FOR SANCTIONS 17 Defendants. Attached Document: Further Declaration of 18 / Raymond L. Sandelman 19 AND RELATED CROSS COMPLAINTS Hearing Date: 12/16/2020 / Hearing Time: 9:00 a.m. 20) Department: 1 21 Judge: Tamara Mosbarger Date of Complaint: 4/22/2020 22 Trial Date: None Set 23 24 1. No Discovery Responses Have Been Received 25 This reply brief is nearly identical to the reply brief supporting the motion filed by Wayne 26) Cook, Trustee of The Wayne A. Cook 1998 Family Trust Dated 12/29/98 (hereafter referred to as 27 “Wayne Cook, Trustee”) against John Denton, successor trustee of The Edward F. Niderost 28 Revocable Living Trust Dated November 8, 1998. 1 REPLY BRIEF IN SUPPORT OF MOTION FOR ORDERS DIRECTED TO JOHN DENTON, CONSERVATOR AND HIS COUNSEL (A) DEEMING MATTERS ADMITTED, (B) COMPELLING ANSWERS TO INTERROGATORIES, (C) COMPELLING RESPONSES TO DOCUMENT DEMANDS, AND (D) FOR SANCTIONS As of 1:00 p.m. on December 9, 2020, John Denton, Conservator of the Estate of Edward F. Niderost (hereafter referred to as “John Denton, Conservator”) has still not responded to requests for admissions, two sets of form interrogatories, or two sets of document demands that were propounded by Wayne Cook, Trustee on September 2, 2020 (Exs. 1-5 to the Declaration of Raymond L. Sandelman filed with the Moving Brief). Ms. Knowles has made promises before that she has not complied with (see the unfulfilled promises to file amended pleadings that were discussed in the two motions for judgment on the pleadings heard by the Court on December 9, 2020 and her unfulfilled promises to provide further responses to eight sets of discovery (Ex. 6 to the Moving Papers). The Declaration Of Sara Knowles does not discuss the mandatory “deemed admission” Bo 10 provisions of Code of Civil Procedure section 2033.280 subdivision (d). The matters must be deemed aR <é 6s 11 admitted unless a proposed response to the requests for admission that is in substantial compliance ae QR g<= B09 12 with Code of Civil Procedure section 2033.100 is served prior to the hearing. Saun 4,88 48a8 Ze Ze~ 13 2. Ms. Knowles’ Declaration Makes A Mockery Of The Requirements ge a3 £4204 14 That Declarations Be Supported By Statements Made Under Penalty Of Perjury Sa aa ge BR 15 Ms. Knowles’ declaration states that it is a response, not an opposition. She then argues the ao 16 law in an analysis that is identical to a brief. This makes a mockery of the requirements that 17 declarations be supported by statements made under penalty of perjury. 18 5) [9:49.5] Declarations limited to facts, not legal arguments: It is improper to include legal arguments in a declaration. (E.g., “the interests of justice require ...” 19 or “the following matters constitute ‘good cause’ ...”) As noted by one court, this is 20 “a sloppy practice which should stop ... (I)t makes a mockery of the requirements that declarations be supported by statements made under penalty of perjury.” [Marriage of 21 Heggie (2002) 99 CA4th 28, 30, 120 CR2d 707, 709, fn. 3] 22 Weil & Brown, California Practice Guide: Civil Procedure Before Trial (The Rutter 23 Group 2020) 24 The reason for the declaration rather than an opposition brief is clear from Paragraph 11 of 25 Ms. Knowles’ declaration. She understands that California Rules of Court Rule 3.1348 discusses 26 circumstances where sanctions are sometimes not awarded when there is no opposition. She called 27 her opposition a “response” thinking it would help. But substantively it is an opposition. Also, she 28 ignored the provisions of Code of Civil Procedure section 2033.280 subdivision (d) which makes an 2 REPLY BRIEF IN SUPPORT OF MOTION FOR ORDERS DIRECTED TO JOHN DENTON, CONSERVATOR AND, HIS COUNSEL (A) DEEMING MATTERS ADMITTED, (B) COMPELLING ANSWERS TO INTERROGATORIES, (C) COMPELLING RESPONSES TO DOCUMENT DEMANDS, AND (D) FOR SANCTIONS award of sanctions mandatory (See the next section of this Brief). 3. An Award Of Sanctions Is Mandatory Ms. Knowles’s declaration does not dispute the law that sanctions are mandatory, but she seeks to have sanctions “adjusted” because she claims that there was substantial justification for her conduct. She does not dispute that the amount sought is a reasonable sum for the motion before the court. The purported “substantial justification” is her failure to calendar the due date for the discovery. This is frivolous. Lawyers have been known to make calendar errors and to then state that they made a mistake, or that their conduct was excusable neglect (Comunidad en Accion v. Los Angeles City Council (2013) 219 Cal.App.4th 1116, 1134-1135),' but no case supports Ms. Bo 10 Knowles’ claim that there is substantial justification when an attorney fails to calendar the response ag <é SE = os 11 due date to five sets of discovery. 258 BS Ag 12 On September 2, 2020, Ms. Knowles was advised in writing that the stay for judicial oun aes wee Ze Zs 13 foreclosures had been lifted (Ex. 8 to the Further Declaration of Raymond L. Sandelman). The ge a3 14 B< a8 Sa amended discovery was propounded on the same date (Exs. 1-5 to the Declaration of Raymond L. ga BS Ba go 15 Sandelman filed with the Moving Brief) by first class mail and email. The document demands that 16 were propounded (Exs. 4-5 to the Declaration of Raymond L. Sandelman filed with the Moving 17 Brief) expressly specify the date of production is October 8, 2020. Ms. Knowles claims that the 18 discovery she received on September 2, 2020 specifying a response date of October 8, 2020, with 19 the written notice that the stay for judicial foreclosure had been lifted, was believed to be part of 20 discovery withdrawn on July 2, 2020. This is not credible. 21 On July 2, 2020 very specific discovery was withdrawn (See Ex. 7 to the Further Declaration 22 of Raymond L. Sandelman), The Exhibit 7 July 2, 2020 email states “If there is any discovery 23 * Nicholson v. Rose (1980) 106 Cal.App.3d 457, 460-461 holds that counsel’s course of dilatory tactics and 24 spurious objections throughout the litigation can be grounds for not granting relief for a calendaring error. Ms. Knowles’ Declaration does not dispute that her clients have not provided further responses to eight sets of discovery promised on 25 September 15, 2020, that her clients were sanctioned $1,000 by the court for misuse of the discovery process on November 9, 2020, that there is a second discovery motion filed by Randal Culley set for hearing on December 16, 26 2020, and there is a pattern of misuse of the discovery process. Ms. Knowles also promised to amend her pleadings and then failed to do so, which required plaintiff to file motions for judgment on the pleadings as to the Answer and 27 Cross Complaint. More could be said, but when sanctions are mandatory it is inappropriate to get involved in Ms. Knowles evasive, legally, irrelevant arguments. 28 3 REPLY BRIEF IN SUPPORT OF MOTION FOR ORDERS DIRECTED TO JOHN DENTON, CONSERVATOR AND HIS COUNSEL (A) DEEMING MATTERS ADMITTED, (B) COMPELLING ANSWERS TO INTERROGATORIES, (C) COMPELLING RESPONSES TO DOCUMENT DEMANDS, AND (D) FOR SANCTIONS propounded after the June 12, 2020 Cross Complaint that you contend is only applicable to issues raised in the Complaint, let me know. If your concerns have merit I will withdraw the inquiries.” Ms. Knowles does not claim that she ever advised Raymond L. Sandelman that any other discovery was applicable to the stayed judicial foreclosure action. Attorneys make mistakes, but to claim that she believed that the amended discovery was withdrawn is not “substantial justification”; it is negligent conduct. Ms. Knowles’ Declaration cites Code of Civil Procedure section 2023.010 to argue that sanctions are discretionary, but she has overlooked the analysis in Weil & Brown California Practice Guide: Civil Procedure Before Trial (The Rutter Group 2020) cited in the Moving Brief that there Be 10 are no excuses that will be accepted to avoid the mandatory provisions that sanctions be awarded. ae <é be = 11 Be gs oR 62 (5) [8:1376] Monetary sanction also mandatory: Although delayed responses Ze 12 may defeat a motion to compel, they will not avoid monetary sanctions. Regardless of oun as ras the reason for the delay in responding, it is mandatory that a monetary sanction be abas Ze gs 13 imposed on the party or attorney, or both, whose failure to serve a timely response ZOAS gets 14 necessitated the filing of the deemed-admitted motion. [CCP § 2033.280(c)] g< a? Sa Za (a) [8:1377] Comment: This is the only place in the Discovery Act where BS 15 sanctions for delay are mandatory. The purpose is to provide incentive to timely ge respond to RFAs: i.e., no excuses accepted. 16 17 Ms. Knowles’ Declaration notes that there was other discovery in this case, but ignores the 18 fact that her client has not properly responded to the other discovery (See the itemization at footnote 19 1, supra). The existence of other discovery is an indication that calendaring in this case is critical; 20 it is not the situation where there is a single set of discovery that can be remembered in one’s head. 21 22 4. Conclusion 23 The Court should (a) deem that the truth of matters, specified in Wayne Cook, Trustee's 24 Request for Admissions, be admitted, (b) compel answers to the two sets of form interrogatories, 25 (c) compel responses to the two sets of document demands, and (d) order John Denton, Conservator 26 of the Estate of Edward F. Niderost and his attorney Leland, Morrissey & Knowles LLP to jointly 27 and severally pay the sum of $720.00 in attorney’s fees and costs to Wayne Cook, Trustee. 28 Because there is no opposition to the motion for preference set for hearing on December 16, 4 REPLY BRIEF IN SUPPORT OF MOTION FOR ORDERS DIRECTED TO JOHN DENTON, CONSERVATOR AND) HIS COUNSEL (A) DEEMING MATTERS ADMITTED, (B) COMPELLING ANSWERS TO INTERROGATORIES, (C) COMPELLING RESPONSES TO DOCUMENT DEMANDS, AND (D) FOR SANCTIONS 1}| 2020, the discovery should be responded to as soon as possible. Given that the discovery was 2|| propounded on September 2, 2020, it is appropriate that the Court order that verified responses to 3}| the interrogatories and document demands be served on or before December 21, 2020. 4 5 6 Dated: Comber 20L0 QL Sob Raymond L. Sandelman Attorney for Wayne Cook, Trustee, Individually and as Successor Trustee Bs 10 ag sé Se — os 11 Baa 13 a8 2a 14 Zh ga 5S gs 15 go 16 17 18 19 20 21 22 23 24 25 26 27 28 5 REPLY BRIEF IN SUPPORT OF MOTION FOR ORDERS DIRECTED TO JOHN DENTON, CONSERVATOR AND) HIS COUNSEL (A) DEEMING MATTERS ADMITTED, (B) COMPELLING ANSWERS TO INTERROGATORIES, (C) COMPELLING RESPONSES TO DOCUMENT DEMANDS, AND (D) FOR SANCTIONS Table of Exhibits Exhibit 7: July 2, 2020 email to Sara Knowles. Exhibit 8: September 2, 2020 email to Sara Knowles. 10) 11 12) ao 13 ag <é oe 14 gs a2 oR BA0 Fo 15 aunas AS 16) 4eas eS Bs gE a3 17 E