On May 02, 2019 a
Party Statement
was filed
involving a dispute between
Nijjar, Satnam,
Nijjar, Satnam Singh,
and
Christine Rinaldo And Roger Lundblad, Co-Trustees Of The Edwin L. Lundblad Revocable Trust Udt Dated 4 26 88,
Cook, Paul R,
Cullen, Cheryl,
Cullen, Chris,
Edward Landry, Trustee Of The Laurel D. Schumann Revocable Trust,
Landry, Edward,
Lundblad, Roger,
Richard Strecker, Trustee Of The Henry C. Strecker Revocable Trust Dated August 18, 1993,
Richard Strecker, Trustee Of The Lenore Stuart Strecker Trust Uta Dated 9 1 93 Fbo Lenore Stuart Strecker,
Rinaldo, Christine,
Rockwood, Katherine W,
Strecker, Richard,
for civil
in the District Court of Butte County.
Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Nicholas R. Deal 274775
DEAL LAW FIRM
321 D Street, Suite C
Marysville, CA 95901
TELEPHONE NO.:(530) 329-5076 FAX NO.(Optional): (530) 331-0068
nick@nickdeallaw.com
E-MAIL ADDRESS (Optional):
Satnam
ATTORNEY FOR (Name): Singh Nijjar 2/25/2021
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sutter
STREET ADDRESS: 1775 Concord Avenue
MAILING ADDRESS: 1775 Concord Avenue
CITY AND ZIP CODE:Chico 95928
BRANCH NAME: Civil
PLAINTIFF/PETITIONER: Satnam Singh Nijjar
DEFENDANT/RESPONDENT: Cook, Paul R., et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): ‰X UNLIMITED CASE ‰ LIMITED CASE 19CV01342
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 3/3/2021 Time: 10:30 a.m. Dept.: 1 Div.: Room:
Address of court (if different from the address above):
‰X Notice of Intent to Appear by Telephone, by (name): Nicholas Deal
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. ‰X This statement is submitted by party (name): Satnam Singh Nijjar
b. ‰ This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): 5/2/2019
b. ‰ The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. ‰ All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. ‰X The following parties named in the complaint or cross-complaint
(1) ‰X have not been served (specify names and explain why not):
Christine Rinaldo (Massachusetts), Edward Landry (deceased)
(2) ‰X have been served but have not appeared and have not been dismissed (specify names):
Roger Lundblad, Chris Cullen, Cheryl Cullen, Katherine Rockwood
(3) ‰ have had a default entered against them (specify names):
c. ‰X The following additional parties may be added (specify names, nature of involvement in case, and the date by which
they may be served):
Successor trustee for Edward Landry
4. Description of case
a. Type of case in ‰X complaint ‰ cross-complaint (Describe, including causes of action):
Quiet Title
Page 1 of 5
Form Adopted for Mandatory Use
Judicial Council of California
CASE MANAGEMENT STATEMENT Cal. Rules of Court,
rules 3.720-3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
Satnam Nijjar
CM-110
PLAINTIFF/PETITIONER:Satnam Singh Nijjar CASE NUMBER:
19CV01342
DEFENDANT/RESPONDENT: Cook, Paul R., et al.
4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Quiet title action to tax defaulted property in Gridley, CA.
Requesting 90 days to complete service on successor trustee for Edward Landry (still
unknown), Christine Rinaldo (out of state), and re-apply for service by publication
as to unknown persons.
‰ (If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request ‰ a jury trial ‰X a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. ‰ The trial has been set for (date):
b. ‰X No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. ‰ days (specify number):
b. ‰X hours (short causes) (specify): 1
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial ‰X by the attorney or party listed in the caption ‰ by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
‰ Additional representation is described in Attachment 8.
9. Preference
‰ This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel ‰X has ‰ has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party ‰ has ‰ has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) ‰ This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) ‰ Plaintiff
elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) ‰X This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 of 5
Satnam Nijjar
CM-110
PLAINTIFF/PETITIONER:Satnam Singh Nijjar CASE NUMBER:
19CV01342
DEFENDANT/RESPONDENT: Cook, Paul R., et al.
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):
‰X Mediation session not yet scheduled
(1) Mediation ‰X ‰ Mediation session scheduled for (date):
‰ Agreed to complete mediation by (date):
‰ Mediation completed on (date):
‰ Settlement conference not yet scheduled
(2) Settlement
‰ ‰ Settlement conference scheduled for (date):
conference
‰ Agreed to complete settlement conference by (date):
‰ Settlement conference completed on (date):
‰ Neutral evaluation not yet scheduled
(3) Neutral evaluation ‰ ‰ Neutral evaluation scheduled for (date):
‰ Agreed to complete neutral evaluation by (date):
‰ Neutral evaluation completed on (date):
‰ Judicial arbitration not yet scheduled
(4) Nonbinding judicial ‰ ‰ Judicial arbitration scheduled for (date):
arbitration
‰ Agreed to complete judicial arbitration by (date):
‰ Judicial arbitration completed on (date):
‰ Private arbitration not yet scheduled
(5) Binding private ‰ ‰ Private arbitration scheduled for (date):
arbitration
‰ Agreed to complete private arbitration by (date):
‰ Private arbitration completed on (date):
‰ ADR session not yet scheduled
(6) Other (specify): ‰ ‰ ADR session scheduled for (date):
‰ Agreed to complete ADR session by (date):
‰ ADR completed on (date):
CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5
Satnam Nijjar
CM-110
PLAINTIFF/PETITIONER: Satnam Singh Nijjar CASE NUMBER:
19CV01342
DEFENDANT/RESPONDENT: Cook, Paul R., et al.
11. Insurance
a. ‰ Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: ‰ Yes ‰ No
c. ‰ Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case, and describe the status.
‰ Bankruptcy ‰ Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. ‰ There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
‰ Additional cases are described in Attachment 13a.
b. ‰ A motion to ‰ consolidate ‰ coordinate will be filed by (name party):
14. Bifurcation
‰ The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
‰ The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. ‰ The party or parties have completed all discovery.
b. ‰ The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
c. ‰ The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5
Satnam Nijjar
CM-110
PLAINTIFF/PETITIONER: Satnam Singh Nijjar CASE NUMBER:
19CV01342
DEFENDANT/RESPONDENT: Cook, Paul R., et al.
17. Economic litigation
a. ‰ This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. ‰ This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
‰ The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a. ‰X The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of
Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any):
I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: 2/24/2021
Nicholas Deal
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
‰ Additional signatures are attached.
CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5
Satnam Nijjar
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Nicholas R. Deal 274775 DEAL LAW FIRM 321 D Street, Suite C Marysville, CA 95901 TELEPHONE NO.:(530) 329-5076 FAX NO.(Optional): (530) 331-0068 nick@nickdeallaw.com E-MAIL ADDRESS (Optional): Satnam ATTORNEY FOR (Name): Singh Nijjar 2/25/2021 SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sutter STREET ADDRESS: 1775 Concord Avenue MAILING ADDRESS: 1775 Concord Avenue CITY AND ZIP CODE:Chico 95928 BRANCH NAME: Civil PLAINTIFF/PETITIONER: Satnam Singh Nijjar DEFENDANT/RESPONDENT: Cook, Paul R., et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): ‰X UNLIMITED CASE ‰ LIMITED CASE 19CV01342 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 3/3/2021 Time: 10:30 a.m. Dept.: 1 Div.: Room: Address of court (if different from the address above): ‰X Notice of Intent to Appear by Telephone, by (name): Nicholas Deal INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. ‰X This statement is submitted by party (name): Satnam Singh Nijjar b. ‰ This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): 5/2/2019 b. ‰ The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. ‰ All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. ‰X The following parties named in the complaint or cross-complaint (1) ‰X have not been served (specify names and explain why not): Christine Rinaldo (Massachusetts), Edward Landry (deceased) (2) ‰X have been served but have not appeared and have not been dismissed (specify names): Roger Lundblad, Chris Cullen, Cheryl Cullen, Katherine Rockwood (3) ‰ have had a default entered against them (specify names): c. ‰X The following additional parties may be added (specify names, nature of involvement in case, and the date by which they may be served): Successor trustee for Edward Landry 4. Description of case a. Type of case in ‰X complaint ‰ cross-complaint (Describe, including causes of action): Quiet Title Page 1 of 5 Form Adopted for Mandatory Use Judicial Council of California CASE MANAGEMENT STATEMENT Cal. Rules of Court, rules 3.720-3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov Satnam Nijjar CM-110 PLAINTIFF/PETITIONER:Satnam Singh Nijjar CASE NUMBER: 19CV01342 DEFENDANT/RESPONDENT: Cook, Paul R., et al. 4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Quiet title action to tax defaulted property in Gridley, CA. Requesting 90 days to complete service on successor trustee for Edward Landry (still unknown), Christine Rinaldo (out of state), and re-apply for service by publication as to unknown persons. ‰ (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request ‰ a jury trial ‰X a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. ‰ The trial has been set for (date): b. ‰X No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. ‰ days (specify number): b. ‰X hours (short causes) (specify): 1 8. Trial representation (to be answered for each party) The party or parties will be represented at trial ‰X by the attorney or party listed in the caption ‰ by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: ‰ Additional representation is described in Attachment 8. 9. Preference ‰ This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel ‰X has ‰ has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party ‰ has ‰ has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) ‰ This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) ‰ Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) ‰X This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 of 5 Satnam Nijjar CM-110 PLAINTIFF/PETITIONER:Satnam Singh Nijjar CASE NUMBER: 19CV01342 DEFENDANT/RESPONDENT: Cook, Paul R., et al. 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): ‰X Mediation session not yet scheduled (1) Mediation ‰X ‰ Mediation session scheduled for (date): ‰ Agreed to complete mediation by (date): ‰ Mediation completed on (date): ‰ Settlement conference not yet scheduled (2) Settlement ‰ ‰ Settlement conference scheduled for (date): conference ‰ Agreed to complete settlement conference by (date): ‰ Settlement conference completed on (date): ‰ Neutral evaluation not yet scheduled (3) Neutral evaluation ‰ ‰ Neutral evaluation scheduled for (date): ‰ Agreed to complete neutral evaluation by (date): ‰ Neutral evaluation completed on (date): ‰ Judicial arbitration not yet scheduled (4) Nonbinding judicial ‰ ‰ Judicial arbitration scheduled for (date): arbitration ‰ Agreed to complete judicial arbitration by (date): ‰ Judicial arbitration completed on (date): ‰ Private arbitration not yet scheduled (5) Binding private ‰ ‰ Private arbitration scheduled for (date): arbitration ‰ Agreed to complete private arbitration by (date): ‰ Private arbitration completed on (date): ‰ ADR session not yet scheduled (6) Other (specify): ‰ ‰ ADR session scheduled for (date): ‰ Agreed to complete ADR session by (date): ‰ ADR completed on (date): CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5 Satnam Nijjar CM-110 PLAINTIFF/PETITIONER: Satnam Singh Nijjar CASE NUMBER: 19CV01342 DEFENDANT/RESPONDENT: Cook, Paul R., et al. 11. Insurance a. ‰ Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: ‰ Yes ‰ No c. ‰ Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case, and describe the status. ‰ Bankruptcy ‰ Other (specify): Status: 13. Related cases, consolidation, and coordination a. ‰ There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: ‰ Additional cases are described in Attachment 13a. b. ‰ A motion to ‰ consolidate ‰ coordinate will be filed by (name party): 14. Bifurcation ‰ The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions ‰ The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. ‰ The party or parties have completed all discovery. b. ‰ The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date c. ‰ The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5 Satnam Nijjar CM-110 PLAINTIFF/PETITIONER: Satnam Singh Nijjar CASE NUMBER: 19CV01342 DEFENDANT/RESPONDENT: Cook, Paul R., et al. 17. Economic litigation a. ‰ This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. ‰ This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues ‰ The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. ‰X The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: 2/24/2021 Nicholas Deal (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) ‰ Additional signatures are attached. CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5 Satnam Nijjar