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  • Wayne A Cook, Trustee of the Wayne A Cook 1998 Family Trust Dated 12/29/98 vs Edward f Niderost, Individually and as Trustee of the Edward F Niderost Revocable Living Trust Dated November 8, 1998(26) Unlimited Other Real Property document preview
  • Wayne A Cook, Trustee of the Wayne A Cook 1998 Family Trust Dated 12/29/98 vs Edward f Niderost, Individually and as Trustee of the Edward F Niderost Revocable Living Trust Dated November 8, 1998(26) Unlimited Other Real Property document preview
  • Wayne A Cook, Trustee of the Wayne A Cook 1998 Family Trust Dated 12/29/98 vs Edward f Niderost, Individually and as Trustee of the Edward F Niderost Revocable Living Trust Dated November 8, 1998(26) Unlimited Other Real Property document preview
  • Wayne A Cook, Trustee of the Wayne A Cook 1998 Family Trust Dated 12/29/98 vs Edward f Niderost, Individually and as Trustee of the Edward F Niderost Revocable Living Trust Dated November 8, 1998(26) Unlimited Other Real Property document preview
  • Wayne A Cook, Trustee of the Wayne A Cook 1998 Family Trust Dated 12/29/98 vs Edward f Niderost, Individually and as Trustee of the Edward F Niderost Revocable Living Trust Dated November 8, 1998(26) Unlimited Other Real Property document preview
  • Wayne A Cook, Trustee of the Wayne A Cook 1998 Family Trust Dated 12/29/98 vs Edward f Niderost, Individually and as Trustee of the Edward F Niderost Revocable Living Trust Dated November 8, 1998(26) Unlimited Other Real Property document preview
  • Wayne A Cook, Trustee of the Wayne A Cook 1998 Family Trust Dated 12/29/98 vs Edward f Niderost, Individually and as Trustee of the Edward F Niderost Revocable Living Trust Dated November 8, 1998(26) Unlimited Other Real Property document preview
  • Wayne A Cook, Trustee of the Wayne A Cook 1998 Family Trust Dated 12/29/98 vs Edward f Niderost, Individually and as Trustee of the Edward F Niderost Revocable Living Trust Dated November 8, 1998(26) Unlimited Other Real Property document preview
						
                                

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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 28 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