On April 22, 2020 a
Conference
was filed
involving a dispute between
Edward F Niderost, Individually And As Trustee Of The Edward F Niderost Revocable Living Trust Dated November 8, 1998,
Patterson, Lawrence,
Wayne A Cook, Trustee Of The Wayne A Cook 1998 Family Trust Dated 12 29 98,
Wayne A Cook, Trustee Of The Wayne A. Cook 1998 Family Trust Dated 12 29 98,
and
Edward F Niderost, Individually And As Trustee Of The Edward F Niderost Revocable Living Trust Dated November 8, 1998,
for (26) Unlimited Other Real Property
in the District Court of Butte County.
Preview
Larry G. Lushanko, Esq. (SB¹69143)
1 office lushankolaw.corn
Brittney L. Lushanko, Esq. (SB¹272959)
2 brittnev lushankolaw.corn 12/23/2020
LAW OFFICES OF LARRY G. LUSHANKO
3 1241 East Mission Road
Fallbrook, California 92028
4 Telephone: (760) 728-9899
Facsimile: (760) 728-9499
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Attorneys for Cross-Defendant LAURENCE PATTERSON
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF BUTTE, NORTH BUTTE COUNTY COURTHOUSE
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WAYNE A. COOK, Trustee of the Wayne A. Case No.: 20CV00905
Cook 1998 Family Trust Dated 12/29/98, NOTICE OF CASK MANAGEMENT
CONFERENCE
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Plaintiff, Date: April 7, 2021
14 Time: 10:30 a.m.
Dept.: 1
V.
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EDWARD F. NIDEROST, individually; and Assigned for All Purposes to:
as Trustee of THE EDWARD F. NIDEROST Judge: Hon. Tamara L. Mosbarger
REVOCABLE LIVING TRUST Dated Dept: 1
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November 8, 1998; DOES I through 10, Complaint Filed: April 22, 2020
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Defendants.
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EDWARD F. NIDEROST, individually; and
20 as Trustee of THE EDWARD F. NIDEROST
REVOCABLE LIVING TRUST Dated
21 November 8, 1998; DOES I through 10,
22 Cross-Complainant,
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WAYNE A. COOK, Trustee of the Wayne A.
24 Cook 1998 Family Trust Dated 12/29/98;
LAWRENCE PATTERSON; GENE
25 CULLEY; MID VALLEY TITLE AND
ESCROW COMPANY; and ROES I through
26 25, inclusive,
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Cross-Defendants.
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ANSWER TO CROSS-COMPLAINT
1 TO ALL PARTIES AND ATTORNEYS OF RECORD:
2 NOTICE IS HEREBY GIVEN that a Case Management Conference in this matter has
3 been scheduled for April 7, 2021, at 10:30 a.m. in Department I of the above entitled court.
4 DATED: December 21, 2020 Law Offices fKa ry G. Lushauko
Larry G. Lushanko, Esq.
Brittney L. Lushanko, Esq.
Attorneys for Cross-Defendant Laurence
Patterson
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ANSWER TO CROSS-COMPLAINT
Cook v, /Viderost, and Related Cross-Actions
Superior Court of California, County of Butte
Case No.: 20CV00905
3 PROOF OF SERVICE
I declare that I am over the age of eighteen years and not a party to the within action. I
am einployed in, or am a resident of, the County of San Diego, Califorma; my business address
is 1241 E. Mission Road, Fallbrook, California 92028.
I further declare that on this date I served a copy of the following document(s):
1. NOTICE OF CASE MANAGEMENT CONFERENCE
on the following in the manner described below:
Raymond L. Sandelman Sara M. Knowles
10 Attorney at Law Leland, Morrissey & Knowles, LLP
196 Cohasset Road, Suite 225 1660 Humboldt Road, Ste. 6
Chico, CA 95926-2284 Chico, CA 95928
12 (530) 343-5090 (530) 342-4500
raymond@sandeimanlaw.corn sknowles chicolawyer.corn
13 Attorney for Plaintiff/Cross-Defendant Attorney for Defendant/Cross-Complainant Niderost
Cook
14 Erwin Williams
David Griffith
Griffith, Hom & Sheehan, LLP 55 Independence Circle, Ste. 106
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1530 Humboldt Road, Ste. 3 ffiCA
Chico, 95973
ce@mlbwla.org
16 Chico, CA 95928 (530) 877-4961
(530) 812-1000 1awo
17 david@davidgri ffithlaw.corn Guardian Ad Litem for Edward Niderost
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[ X ] BY MAIL. I caused such envelope to be placed for collection and mailing following this
19 firm's ordinary business pracfices. I am readily familiar with the firm's practice of collection and
processing correspondence for mailing. Under that practice, on the same day that
20 correspondence is placed for collection and mailing, it is deposited with the U.S. Postal Service
in a sealed envelope with postage fully prepaid. I am aware that on motion of party served,
21 service is presumed invalid if postal cancellation date or postage meter date is more that (I) day
after date of deposit for mailing in affidavit.
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23 [ ] BY CERTIFIED MAIL. I caused such envelope with postage thereon fully prepaid for
Certified Mail Return Receipt Requested to be placed in the United States Mail in Fallbrook,
24 CA.
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[ BY EXPRESS MAIL OR ANOTHER METHOD OF DELIVER PROVIDING FOR
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OVERNIGHT DELIVERY.
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27 [ ] BY ELECTRONIC FILING AND/OR SERVICE. I served a hue copy electronically
with all exhibits via Onelegal
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ANSWER TO CROSS-COMPLAJNT
BY FEDERAL EXPRESS. I deposited the Federal Express envelope containing the
[ ] California.
aforementioned documents in the Federal Express depository located in Fallbrook,
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[ ] BY PERSONAL SERVICE. I delivered such documents personally.
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[ ] BY FACSIMILE SERVICE, I transmitted the foregoing document by facsimile to the
4 party(s) identified above using the facsimile number(s) indicated and the activity report
generated by said facsimile machine indicated all pages were transmitted without error.
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I declare that I am employed in the office of a member of the bar of this court at whose
California
direction the service was made and under penalty of perjury under the laws of the State of
that the foregoing is true and correct.
Executed on December~+ 2020
Lpiif
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ANSWER TO CROSS-COMPLAINT