Preview
F Superior Court of California F
Sara M. Knowles (SBN 216139)
LELAND, MORRISSEY & KNOWLES LLP County of Butte
1660 Humboldt Road, Suite 6 | I
Chico, CA 95928 L 12/22/2020 L
Telephone: (530) 342-4500
Facsimile: (530) 345-6836 D D
By Deputy
Attorney for Conservator John Denton for Successor Trustee
of the Edward F. Niderost Revocable Living Trust Dated
November 8, 1998
SUPERIOR COURT OF CALIFORNIA,
COUNTY OF BUTTE
10
11
WAYNE A. COOK, TRUSTEE OF THE CASE NO. 20CV00905
12 WAYNE A. COOK 1998 FAMILY TRUST
DATED 12/29/98, AMENDED DECLARATION OF SARA
13 M. KNOWLES RE: PLAINTIFF’S
Plaintiff, MOTIONS (2) FOR ORDERS DIRECTED
14 AT JOHN DENTON DEEMING
¥.
MATTERS ADMITTED
15
EDWARD F, NIDEROST, INDIVIDUALLY
16 AND AS TRUSTEE OF THE EDWARD F. Hearing Date: December 23, 2020
NIDEROST REVOCABLE LIVING TRUST Time: 9:00 A.M.
17 DATED NOVEMBER 8, 1998, DOES 1 Dept.: 1
THROUGH 10, Judge: Hon. Tamara Mosbarger
18
Defendants.
19 )
AND RELATED CROSS-ACTION
2 |
|
21 |
22 I, Sara Knowles, declare that I am an attorney licensed in the State of California and
23 ; 4m a partner in the law firm known as Leland, Morrissey & Knowles, LLP, which represents
24 John Denton, the Conservator of Edward F. Niderost and the Successor Trustee of the Edward F,
25 Niderost Revocable Living Trust. If called as a witness to testify, I could and would faithfully
26 and truthfully testify as follows:
27 1 On December 21, 2020, I submitted responses, on behalf of my client, to the Form
28
'
AMENDED DECLARATION OF SARA M. KNOWLES RE: PLAINTIFF’S MOTIONS (2) FOR ORDERS
DIRECTED AT JOHN DENTON DEEMING MATTERS ADMITTED
Interrogatories, Set No. One, Set No. Two- Amended; Amended Demand for Production of
Documents, Set No. One-Amended; Amended Demand for Production of Documents, Set No.
Two- Amended; Demand for Production of Documents, Set No. Three; Special Interrogatories,
Set No. One; Requests for Admission, Set No. Four; and Request for Admissions, No One-
Amended. All propounded by Wayne Cook, by and through his attorney Raymond Sandelman.
These responses were ordered to be supplied by December 21, 2020. True and correct copies are
attached hereto and incorporated herein by reference as Exhibit “A”.
2. The above described Responses to the Requests for Admission are made in
substantial compliance with CCP Section 2033.220. Each request contains an admission, a denial
10 or a statement that the responding party lacks information or knowledge as a basis for the failure
11 to admit all or part of a request for admission and that the responding party has made a
12 reasonable inquiry concerning the matter of the particular request and the information known or
13 readily obtainable is insufficient to enable that party to admit the matter.
14 3 The responses described herein have been transmitted, via regular mail (and by
15 email to Mr. Sandelman), to the propounding party and all other parties.
16 I declare under penalty of perjury under the laws of the State of California that the
17 foregoing is true and correct. Executed this 22" day of December, 2020 at Chico, California.
18
19
20 br Yrowlee
ara Knowles
21
22
23
24
25
26
27
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2
AMENDED DECLARATION OF SARA M. KNOWLES RE: PLAINTIFF'S MOTIONS (2) FOR ORDERS
DIRECTED AT JOHN DENTON DEEMING MATTERS ADMITTED
EXHIBIT “A”
4 | Sara M. Knowles (SBN 216139)
'| LELAND, MORRISSEY & KNOWLES tr
1660 Humboldt Road, Suite 6
Chico, CA 95928
3
Telephone: ($30) 342-4500
‘| Facsimile: (530) 345-6836
5 | Attorneyfor John Denton, Conservator of the Estate of
Edward F. Niderost
8
7
|
8 SUPERIOR COURT OF CALIFORNIA,
9 COUNTY GF BUTTE
10
| WAYNE A. COOK; TRUSTEE OF THE CASE NO. 20CV00905
11 | WAYNE A. COOK 1998 FAMILY TRUST
DATED 12/29/98 RESPONSE TO FORM
INTERROGATORIES, SET NO. ONE
Plaintiff,
13
Y.
14
| EDWARD F, NIDEROST, INDIVIDUALLY
45 | AND AS TRUSTEE OF THE EDWARD F.
NIDEROST REVOCABLE LIVING TRUST
16 | DATED NOVEMBER 8, 1998, DOES 1
| THROUGH 10,
17 |
Defendants.
18 |
19
20 ‘| PROPOUNDING PARTY: Wayne A. Cook
21 | RESPONDING PARTY: John Denton, Conservator of the Estate
of Edward F
22 Niderost
23 || SET NUMBER: ONE
— Amended
241, Responding Party, pursuant to she provisions of Section 2030.210 of the California Code
25 | of Civil Procedure, hereby responds to Wayne A. Cook’s Form Interrogatories - General, Set
26 | one, as follows:
27 || Responding Party is pursuing its investigation and analysis of the facts and law relating to
28
i
RESPONSE TO FORM INTERROGATORIES, SET NO, ONE
1 | this case and has not completed its discovery or preparation for trial. Therefore,
the responses
2 set forth herein are given without prejadice to Responding Party's right to produce any
3 i subsequently discovered facts or to add, modify, or otherwise change or amend the responses
4 | herein, The information hereinafter set forth is true and correct to the best knowledge of
5 ‘ Responding Party as of this date, and is subject to correction for inadvertent errors, mistakes or |
6 omissions. These responses are based on information presently available to Responding Party.
7 Responding
Party reserves the right to use at trial or deposition
or in support of or in
8 | opposition to any motion any and all evidence heretofore or hereafter produced by parties in this
9 action or by third persons. To the extent that Responding Party identifies certain writings or
10 delineates any facts, it does so without prejudice to establish at a later date any additional facts
1 that may be contained within or discovered as a result of any subsequently-discovered facts or
12 any additional investigation and discovery.
13 Inadvertent production of privileged information by Responding Party is not a waiver of
14 any applicable privilege. Production of any evidence or information does not waive any trial |
15 objection, including but not limited to, relevancy and/or to the admission of such information in
16 evidence.
17 RESPONSE TO INTERROGATORY NO. 1.1:
18 Sara M. Knowles, 1660 Humboldt Road, Suite 6, Chico, California 95928, (530)342-
19 4500, attomey.
20 RESPONSE TO INTERROGATORY NO. 2.8:
21 No
22 RESPONSE TO INTERROGATORY NO. 2.9:
23 Yes
24 RESPONSE TO INTERROGATORY NO. 2.10:
25 i
Yes
26 RESPONSE TO INTERROGATORY NO, 4.1:
27 No
28
2
RESPONSE
TO FIRM INTERROGATORIES, SET NO. ONE
|
i
i
RESPONSE
| TO INTERROGATORY NO. 6.1:
‘INo
RESPONSE TO INTERROGATORY NO. 12.1:
None known to Responding Party. Investigation and discovery are ongoing.
RESPONSE TO INTFERROGATORY NO. 12.2:
RESPONSE TO INTERROGATORY NO. 14.1:
Wayne Cook, and/or Wayne Cook, Trustee: acted as an unlicensed mortgage broker as defined
10 by CA Bus & Prof Code § 10131 as to the solicitation, negotiation, an arrangement of the Fine
1 $500k Note
12 RESPONSE TO INTERROGATORY NO. 14.2:
13 No.
14 {RESPONSE TO INTERROGATORY NO. 17.1:
15 | '
16 @A
(b) Probate
Code section 811 provides that “A determination that a person is of unsound
17 mind or lacks the capacity to make a decision to do a certain action, including, but not
limited to , the incapacity to contract. .. shall be supported by evidence of a deficit in at
18
least one of the following mental functions. . . and evidence of a correlation between the
19 deficit or deficits and the decision or acts in question. ...” This section further provides
that “This part applies only to the evidence that is present to, and the findings that are
made by, a court determining the capacity of a person to do a certain act or make a
21 decision. . . “ To the best of my knowledge, and based on all information known by
me and accessibl
to me,
e | admit that there has been no determination
by any court.
22
(c) None
23 (d) None
24
@ B
(b) I was not present during the discussions between the parties and do not have first-hand
knowledge any representations that were made to Edward F. Niderost.
26
(c) None
{d) None
28
3
RESPONSE TO FORM INTERROGATORIES, SET NO. ONE
lak ©
ih) I was not present during the discussions between the parties and do not have first-hand
2: knowledge any representations that were made to Edward F Niderost,
{c) None.
(d) None.
5 || (aD
(b) I was not present during the discussions between the parties
and do not have first-hand
knowledge any representations that were made to Edward F, Niderost.
{c) None.
(d) None.
8 |!
@E
is; Twas not present during the discussions between the parties and do not have first-hand
10 knowledge any representations that were made to Edward F. Niderost.
44 (c) None.
|
(d) None.
412
13 (a) F
(b) I was not present during the discussions between the parties and do not have first-hand
4 | knowledge any representations that were made to Edward F. Niderost.
{c) None,
15 i il} None.
16|
17 @G
(b) I was not present during the discussions between the parties and do not have first-hand
18 knowledge any representations that were made to Edward F. Niderost.
(c) None.
19
(d) None.
20 |
21 @H
(b) I was not present during the discussions between the parties and do not have first-hand
22 knowledge any representations that were made to Edward F. Niderost.
(c) None.
(a) None.
@!
(hi | was not present during the discus between sions
the parties and do not have first-hand
knowledge any representations that were made to Edward F. Niderost.
(c) None.
27
(d) None.
28
4
RESPONSE TO FORM INTERROGATORIES, SET NO. ONE
4
@i
(b) I was not present during the discussions between the parties and do not have first-hand
knowledge any representations that were made to Edward F. Niderost.
(c) None.
(d) None.
@k
(b) I was not present during the discussions between the parties and do not have first-hand
knowledge any representations that were made to Edward F. Niderost.
(c) None.
(@ None.
@L
{b) I was not present during the discussions between the parties and do not have first-hand
9
knowledge any representations that were made to Edward F. Niderost.
10 (c) None.
(d) None,
11
12 @M
(b) I was not present during the discussions
between the parties
and do not have first-hand
13
knowledge any representations that were made to Edward F_ Niderost.
14 (c) None.
15
(d) None.
16 | RE iE. OGATORY NO, 50.1;
17 @ Real Estate Purchase Agreement, Agreement to Extend Financing, Deeds of Trust
18 1
{ (2), Promissory Notes (2). These materials in the possession of the Propounding Party,
1
19 (b) There is no portion of the agreement that is not in writing, however discovery and
20 : investigation are ongoing.
21 (c) None, discovery and investigation are ongoing.
22 (d)There are no modifications to the agreement, however discovery and investigation are
23 ongoing
24 (e} None, discovery and investigation are ongoing
25 (f) None, discovery and investigation are ongoing
26
27
28
5
RESPONSE TO FORM INTERROGATORIES, SET NO, ONE
RESPONSE TO INTERROGATORY NO. 50,2:
The Propounding Party asserts that there has been breaches of the provisions of the
promissory note, known as the Fine Note as well as other breaches.
RESPONSETO INTERROGA’ ry. 50.3:
Yes, performance of the agreements should be excused because the agreement to
purchase was the result of elder abuse and created an unconscionable contract. The real estate
purchase agreement, the promissory notes and deeds
of trusts should
be nullified and all parties
should be retumed to their positions prior to the creation of the real estate purchase agreement,
deeds of trusts and promissory notes.
10 RESPONSE TO INTERROGATORY NO, 50.4:
11 No.
12 | RESPONSE TO INTERROGATORY NO. 50.5:
13 Yes.
14 The real estate agreement and subsequent promissory notes and deeds of trust are
15 i unenforceable because result of elder abuse and created an unconscionable contract. The real
16 estate purchase agreement, the promissory notes and deeds of trusts should be nullified and al!
7 | parties should be returned to their positions prior to the creation of the real estate purchase
18 agreement, deeds of trusts and promissory notes.
1g RESPONSE TO INTERROGATORY NO. 50.6:
20 No.
21 LELAND, MORRISSEY & KNOWLES up
22
ioD
23
Dated: December. 2A 2020 4 das. fo
M. Knowles
24 “‘Attomey for John Denton, Conservator
of the Estate
of Edward F, Niderost
25
26
27
28
6
RESPONSE TO FORM INTERROGATORIES, SET NO. ONE.
4 |
VERIFICATION
v of Edward F. Nidsrost in this
i Joha Denton, em te Conservator of the Estei
verify
rrogatories, Set No.Guo -Amended and
proceeding. Thave read te Response to Form Inte
as to thoss
ledge of the frets therein wlleged, e.cspt
the conteats thersof Thave parcona! know
at to such foots, I beliove them to be true.
fasts alleged on informution and belinf and,
eq
laws of the State of Caléfornia that he
16
4 Veécclare under the poxalty of pegury ucdar the
44 foregoing is tras end comers
.
0 of Decwuber, 2020 ni Chico, California
pxeoted thie 21° day
4%
13
4
a Denton
45
8
a7
48
1s
20
2%
22
23
a
26
26
2
23
EE TO ORM INTERROGATORIES SETNOONE
|
+ |) Sara M. Knowles (SBN 216139)
LELAND, MORRISSEY & KNOWLES tie
2 | 1660 Humboldt Road, Suite6
‘| Chico, CA 95928
Telephone: (530) 342-4500
4 ||Facsimile: (530) 345-6836
& :| Atto
for rney
John Denton, Conserva
of the Estate
torof
Edward F. Niderost
T I
8 SUPERIOR COURT OF CALIFORNIA,
4
8 COUNTY OF BUTTE
10
WAYNE A, COOK; TRUSTEE OF THE CASE NO. 20CV00905
11 WAYNE A. COOK 1998 FAMILY TRUST
DATED 12/29/98 RESPONSE TO FORM
INTERROGATORIES, SET NO. TWO -
13| v.
Plaintiff,
14
EDWARD F, NIDEROST, INDIVIDUALLY
16 AND AS TRUSTEE OF THE EDWARD F,
NIDEROST REVOCABLE LIVING TRUST
16 DATED NOVEMBER 8, 1998, DOES 1
THROUGH 10,
17
Defendants.
18
AND RELATED CROSS-ACTION
19
20
21
22 PROPOUNDING PARTY: Wayne A. Cook, Trustee
23 RESPONDING PARTY: John Denton, Consoferva
the Estate tor
of Edward F
24 Niderost
25 SET NUMBER: TWO
- Amended
26 Responding Party, pursuant to the provisions of Section 2030.210 of the California Code
27 of Civil Procedure, hereby responds to Wayne A. Cook’s Form Interrogatories, Set Two,
28 follows:
|
|
i 4
RESPONSE TO FORM INTERROGATORIES, SET NO. TWO- AMENDED
1) Responding Party is pursuing its investigation and analysis of the facts and law relating to
2) this case and has not completed its discovery or preparation for trial. Therefor
the responses
e,
3 | set forth herein are given without prejudice to Responding Party's right to produce any
as subsequently disc
facts
overor to add,ed
modify, or otherwise change or amend the responses
5 | herein. The information hereinafter set forth is true and correct to the best knowledge of
6 } Responding Party as of this date, and is subject to correction for inadvertent errors, mistakes or
a | omissions, These responses are based on information presently available to Responding Party.
3 Respo
Party nding
reserves the right to use at trial or deposition or in support of or in
S. opposition
to any motion any and all evidence heretofore or hereafter produced by parties in this
|
10 i action or by third persons. To the extent that Responding Party identifies certain writings or
4 delineates any facts, it does so without prejudice to establish at a later date any additional facts
12 that may be contained within or discovered as a result of any subsequently-discovered facts or
13 | any additional investigation and discovery.
:
14 Inadvertent production of privileged information by Responding Party is not a waiver of
I
16 ,| ay applicable privilege. Production of any evidence or information does not waive any trial
16 objection, including but not limited to, relevancy and/or to the admission of such information in
17 evidence.
18 RES SE TO INTERR: ‘ORY NO. 101.1:
19 | Sara M. Knowles, 1660 Humboldt Road, Suite 6, Chico, CA 95928, (530) 342-4500,
20 attorney.
21 RE: iE INTERROGAT' iza.
22
| Tam unaware that Plaintiff has been damaged in any sense at this time. Plaintiff seeks a
|
23 judicial forecl
as osure
the assignee of a note, in a transaction that was created by Plaintiff in an
24 | attempt to have Defendant overextend and overreach his financial ability. Defendant is unaware
26 if Plaintiff even actually paid for the assignment of the note, and whether the payment was for
26 the face value of the note or not. Plaintiff dictated the terms of the financial arrangements
27 between him, Defenda
andnt
Dr. Fine all in an effort to off load the Miller Mansion and obtain
|
28 ‘maximum Tecovery by issuing “loans” to an elderly man who did not have the capacity to
2
RESPONSE TO FORM INTERROGATORIES, SET NO. TWO- AMENDED
|i
|
|
1 ! understand the transaction, or the income to pay the loans. At the time, Plain
wastiff
aware that
|
|
2 Defendant owned another property (referred to herein as the “Pentz Ranch”) and sought to have
3 i Defendant pledge that property so that Plaintiff could keep the down payment for the Miller
4 || Mansion, foreclose on the Miller Mansion and on Pentz Ranch.
5, RESPONSE TO ATORY NO. 115.3:
6! If there are any damages, Wayne Cook, individually and as Trustee (telephone number
7 | and address know to Plaintiff) and Dr. Matthew Fine (530 532-8691); 2767 Olive Highway,
8 | Oroville, CA 95966.
9
10 | LELAND, MORBISSEY & KNOWLES up
P Vwats 12) 2 2020
“Sara M. Knowles
13| Attorney for John Denton, Conservator of the Estate
14)
| of Edward F, Niderost
16
16
17
18
19
20 ||
at
22
23
24
25
26
27
28
3
RESPONSE TO FORM INTERROGATORIES, SET NO. TWO- AMENDED
VERLFICATION
I, John Deaton, am the conservator
of the Estate of Edward F. Niderost in this
proceeding. I have read the Response
to Form Interrogatories,
Set No. Two- Amended and
i
verify the contents thereof. | have personal knowledge
of the facts therein alleged, except
as to }
those facts alleged on information
and belief and, as to such facts, I believe them to ts true.
T declare under the penalty of periury under
the laws of the State of California
that the
Executed thisl > “day offPocabu,2020
at Chico, California.
410
1
ctbeae
—
12 J
4 33
44
16
18
W
18
18
21
23
24
25
26
27
28
4
RESPONSE TO FORM INTERROGATORIES, SET NO, TWO- AMENDED
—— --—-—
Sara M. Knowles (SBN 21613
LELAND, MORRISSEY & jOWLES te
1660 Humboldt Road, Suite 6
Chico, CA 95928
Telephone; (530) 342-4500
Facsimile: (530) 345-6836
Attfor
omeJohn Denton,
y Conserva
of the Estate
torof
}] Edward F. Niderost
SUPERIOR COURT OF CALIFORNIA,
COUNTY OF BUTTE
10
WAYNE A. COOK; TRUSTEE OF THE CASE NO. 20CV00905
1 WAYNE A. COOK 1998 FAMILY TRUST
DATED 12/29/98 RESPONSE TO AMENDED DEMAND
FOR PRODUCTION OF DOCUMENTS,
Plaintiff, SET NO. GNE - AMENDED
13
iv.
14
EDWARD F. NIDEROST, INDIVIDUALLY
15 , AND AS TRUSTEE OF THE EDWARD F.
| NIDEROST REVOCABLE LIVING TRUST
16 | DATED NOVEMBER 8, 1998, DOES 1
THROUGH 10,
7
Defendants.
18
AND RELATED CROSS-ACTION
19
20
ai lrmoroumne PARTY: Wayne A. Cook, Trustee
| RESPONDING PARTY: John Denton, Conservator of the Estate of Edward F
23 Niderost
24 SET NUMBER: ONE - Amended
25 | Responding Party, pursuant to the provisions of Section 2031.020, et seq,, of the
26 ‘California Code of Civil Procedure, hereby responds to Wayne A. Cook, Trustee’s Amended
|
27 ‘ Demand
|
for Production of Documents, Set No. One - Amended, as follows:
28 Responding Party is pursuing its investigation and analysis of the facts and Jaw telating to
| :
ST 1
RESPONSE TO AMENDED DEMAND FOR PRODUCTION OF DOCUMEN
TS, SET NO. ONE - AMENDED:
|
|
1 this case and has not completed its discovery or preparation for trial. Therefore, the responses
2) set forth herein are given without prejudice to Responding Party's right to produce any
3 | subsequently discovered facts or to add, modify, or otherwise change or amend the responses
4 | herein. The information hereinafter set forth is true and correct to the best knowledge of
& | Responding Party as of this date, and is subject to correction for inadvertent errors, mistakes or
6 omissions. These responses are based on information presently available to Responding Party.
7 Responding Party reserves the right to use at trial or deposition or in support of or in
8 | oppesition to any motion any and all evidence heretofore or hereafter produced by parties in this
9| action or by third persons, To the extent that Responding Party identifies certain writings or
10 delineates any facts, it does so without prejudice to establish at a later date any additional facts
1 ;| that may be contained with
or discovered
inas a result
of any subsequently-discovefacts
red or
12 any additional investigation and discovery.
13 Inadvertent production of privileged information by Responding Party is not waiver of
14 || any applicable privilege. Production of any evidence or information does not waive any trial
18 | objection, including but not limited to, relevancy and/or to the admission of such information in
16 evidence.
17 RESPONSE TO DEMAND FOR PRODUCTION NO. 1:
18 1 The request will be allowed in whole and responsive documents in the possession,
19 | custody or control of the Responding Party will be produced.
20 |, RESPONSE TO DEMAND FOR PRODUCTION NO. 2:
21 The request will be allowed in whole and responsive documents in the possession,
22 | custody or control of the Responding Party will be produced.
23 RE NSE TO DI ODUCTION NO. 3:
i
24 After a diligent search and reasonable inquiry for the documents describ
in ed
this
i
25 |Fequest, Iam unable to comply with the request because the requested document has never
*, 1
26
27 RESPONSE TO DEMAND FOR PRODUCTION NO. 4:
28 Aftera diligent search and reasonable inquiry for the documents described in this request,
2
RESPONSE TO AMENDED DEMAND FOR PRODUCTION OF DOCUMENTS, SET NO. ONE - AMENDED
1 {|Tam unable to comply with the request because the requested document has never existed.
|| RESPONSE TO DEMAND FOR PRODUCTION NO. 5:
Aftera diligent search and reasonable inquiry for the documents described in this tequest,
. Tam unable to comply with the request because the requested document has never existed.
& | RESPONSE TO DEMAND FOR PRODUC’ TION NO. 6:
6!
After a diligent search and reasonable inquiry for the documents described in this request,
7 | Tam unable to comply with the request because the requested document has never existed.
SEZ TO DEMAND FOR PR (ON NO. 7;
9; After a diligent search and reasonable inqu
for theiry
documents described in this request,
!
10 | Tam unable to comply with the request because the requested document has never existed.
11 RESPON: D FOR PRODU! . 8:
12 After a diligent search and reasonable inquiry for the documents described in this request,
13 1am unable to comply with the request because the requested document has never existed.
14 RESPONSE TO DEMAND FOR PRODUCTION NO. 9:
15 Aftera diligent search and reasonable inquiry for the documents described in this request,
16 Iam unable to comply with the request because the requested document has never existed,
17 RESPONSE TO DEMAND FOR PRODUCTION NO. 10:
18 After a diligent search and reasonable inquiry for the documents described in this request,
198 Tam unable to comply with the request because the requested document has never existed.
20 NSE TO D! FOR U ION NO. 11:
21 After a diligent search and reasonable inquiry for the documents described in this request,
22 1am unable to comply with the request because the requested document has never existed.
23 RESPONSE TO DEMAND FOR PRODUCTION NO, 12:
24 After a diligent search and reasonable inquiry for the documents described in thistequest,
26 Tam unable to comp
with the
ly request because the requested docu
has ment
never existed.
26 RESPONSE TQ DEMAND FOR PRODUCTION NO. 13:
27 After a diligent search and reasonable inquiry for the documents described in thisrequest,
28 Tam unable to comply with the request because the requested document has never existed
i
3
RESPONSE TO AMENDED DEMAND FOR PRODUCTION OF DOCUMENTS, SET NO. ONE-AMENDED
'| RESPONSE TO DEMAND FOR PRODUCTION NO. 14:
After a diligent search and reasonable inquiry for the documents described in this request,
I
i Tam unable to comply with the request because the requested document has never existed.
| RESPONSE TO DEMAND FOR PRODUCTION NO. 15:
After a diligent search and reasonable inquiry for the documents described in this request,
i Tam unable to comply with the request because the requested docu
has ment
never existed.
| RESPONSE TO DEMAND FOR PRODUCTION NO. 16:
After a diligent search and reasonable inquiry for the documents described in this request,
{
| Tam unable to comply with the request because the requested document has never existed.
10 RESPONSE TO DEMAND FOR PRODUCTION NO. 17:
1 After a diligent search and reasonable inquiry for the documents described in this request,
12 Tam unable to comply with the request because the requested document has never existed.
13 RESPONSE TO DEMAND FOR PRODUCTION NO. 18:
14 After a diligent search and reasonable inquiry for the documents described in this request,
15 am unable to comply with the request because the requested document has never existed,
16 RESPONSE TO DEMAND FOR PRODUCTION NO, 19:
17 After a diligent search and reasonable inquiry for the documents described in this request,
18 Jam unable to comply with the request because the requested document has never existed.
19 PONSE TO D! JR PRODUCTION 20:
After a diligent search and reasonable inquiry for the documents described in this request,
21 am unable to comply with the request because the requested document has never existed.
22 E TO DE! ‘OR PRODUCTI QO. 21:
23 After a diligent search and reasonable inquiry for the documents described in this request,
Tam unable to comply with the request because the Tequested document has never existed.
25 RESPONSE TO DEMAND FOR PRODUCTION NO, 22:
26 After a diligent search and reasonable inquiry for the documents described in this request,
27 Tam unable to comply with the request because the requested document has never existed.
28 SPONSE T: FOR PRODU INNO. 23:
4
RESPONSE TO AMENDED DEMAND FOR PRODUCTION OF DOCUMENTS, SET NO. ONE - AMENDED
After a diligent search and reasonable inquiry for the documents described in this request,
Tam unable to comply with the request because the requested document has never existed.
RESPONSE TO DEMAND FOR PRODUCTION NO. 24:
After a diligent search and reasonable inquiry for the documents described in this request,
Tam unable to comply with the request because the requested document has never existed.
RESPONSE TO DEMAND FOR PRODUCTION NO. 25:
After a diligent search and reasonable inquiry for the documents described in this request,
Tam unable to comply with the request because the requested document has never existed.
RES = TO Di FOR NO. 26:
16 After a diligent search and reasonable inquiry for the documents described in this request,
11 Tam unable to comply with the request because the requested document has never existed.
12 DEMAND 0D! NO. 27:
13 After a diligent search and reasonable inquiry for the documents descri
in thisbed
request,
14 Tam unable to comply with the request because the requested document has never existed.
15 RESPONSE TO DEMAND FOR PRODUCTION NO, 28:
16 After a diligent search and reaso
inquirynable
for the documents described in this request,
7 Tam unable to comply with the request because the requested document has never existed.
18 RESPONSE EMAND FOR P) NO. 29:
18 After a diligent search and reasonable inquiry for the documents described in this fequest,
20 Tam unable to comply with the request because the requested document has never existed.
21 SE TO D F ODUCTION NO, 30:
22 After a diligent search and reasonable inquiry for the documents described in this request,
23 Tam unable to comply with the request because the requested document has never existed.
24 RESP' TO DEMAND PRODUCTION NO. 31:
25 After a diligent search and reasonable inquiry for the documents described in this request,
26 Tam unable to comply with the request because the requested document has never existed.
27 || RESPONSE TO DEMAND FOR PRODUCTION NO. 32:
i
28 After a diligent search and reasonable inquiry for the documents described in this request,
5
i
i RESPONSE TO AMENDED DEMAND FOR PRODUCTION OF DOCUMENTS, SET NO, ONE- AMENDED
Tam unable to comply with the request because the requested document has never existed.
RESPONSE TO DEMAND FOR PRODUCTION NO. 33:
i After a diligent search and reasonable inquiry for the documents describe
in this request,
d
Tam unable to comply with the request becaus
the requested
e document has never existed.
RESPONSE TC DEMAND FOR PRODUCTION NG. 34:
i After a diligent search and reasonable inquiry for the documents described in this request,
Tam unable to comply with the request because the requested document has never existed.
I
t RES? ‘SE TO DEMAND FOR PRODUCTIO 2
|t
After a diligent search and reasonable inquiry for the documents described in this request,
\
16 '|T am unable to comply with the request because the requested document has never existed.
11 | RESPONSE TO DEMAND FOR PRODUCTION NG. 36:
|
12 After a diligent search and reasonable inquiry for the documents described in this request,
13 Jam unable to comply with the request because the requested document has never existed,
14
18 LELAND, MORRISSEY & KNCWLES wp
16
0
17 Dated:) 2.) 2 2020 th, Kpeovstle
18 CSara M. Knowles
Attomey for John Denton, Conservator of the Estate
19 of Edward F. Niderost
20
21
22
23
27
28
6
RESPONSE TO AMENDED DEMAND FOR PRODUCTION OF DOCUMENTS, SET NO. ONE
- AMENDED
VERIFICATION
1, John Denton, am the conservator of the Estate of Edward F. Niderost in this
proceeding. I kave read the Response to Amended Demand for Production of Documents, Set,
No. One — Amended and verify the contents thereof. I have personal knowledge of the facts
therein alleged, except as to those facts alleged on information enc belief and, as to such facts, I
believe
them to be true.
I declare under the penalty of perjur
under the y
laws of the State of California
that the
foregoing
is true and correct.
10 Executed this day of December, 2020 at Chico, California.
i
12
13 Join Denton
44
16
16
7
18
19
21
22
23
26
27
28
7
RESPONSE TO AMENDED DEMAND FOR PRODUCTION OF DOCUMENTS, SET NO. ONE - AMENDED
1 VERIFICATION
2
3 I, John Deiton, am the conservator of the Batata of Edward ¥. Niderost
in this
4 || preceeding. I have read the Respanse to Amencted Demon for Pindustion of Documents, Sei,
s iJ One ~ Arsandid and verify the contents thereof. [ have persone! Imowledge of the facts
8 |{ thovein alleged, except as to thous Sante alleged oa information ead Selfuf aad, as to such fiasts, I |
? talieve them to be trae,
8 i declare under the newslty of perjury wader thy laws of the Stets of California thet tho
9 forvacing
is trac and conest.
10 Buocused this U * tay of Deccmbee, 2020 at Chico, Celifomia,
==——
1
47
%
14
46
16
7
1
18
2
21!
22 |
2s |i
7
RESPONSE TG AMENDED DEMAND FOR PRODUCTION OF DOCUMENTS, SET NO, ONE - AMENDED
Sows
1 Sara M. Knowles (SBN 216139)
LELAND, MORRISSEY & KNOWLES ui?
2 1660 Humboldt Road, Suite 6
Chico, CA 95!
3
Telephone: (530) 342-4500
Facsimile: (530) 345-6836
| Attorney
EdwardF
John Denton, Conservator of the Estate of
|
|
SUPERIOR COURT OF CALIFORMIA,
COUNTY OF BUTTE
10
é WAYNE A. COOK; TRUSTEE OF THE CASE NO. 20CV00905
1 4