Preview
CM-110
ATTORNEY 0R PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Erwin Williams (Bar # 206908)
McKernan, Lanam, Bakke & Williams LLP
55 Inde endence Circle, Suite 106
Chico, A 95973 Cdu'td CII‘I'IlIII'I'IlI
TELEPHONE NO:
(530) 877-4961 FAX NO. (Optional):
(530) 877_8163
Superior
—F
E-MAIL ADDRESS (Optional):
GWWHBUIIB
lawoffice@mlbwlaw.com I |
ATTORNEY FOR (Name):
L 5/28/2021 L
SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE
STREET ADDRESS:1775 Concord Avenue E E
1775
MAILING ADDRESS: Concord Avenue D D
Chico 95928
CITY AND ZIP CODE:
new
BRANCH NAME:Civil Department WFlLED
PLAlNTlFF/PETITIONERI Wayne A. Cook, Trustee of the Wayne A, Cook 1998 Family Trust dated 12/29/98
DEFENDANT/RESPONDENT: Edward F. Niderost, individually and as Trustee of the Edward F.
NidernsLReLhwnglmsLdated l ”DR/QR
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): [2] UNLIMITED CASE [:1 LlMlTED CASE
(Amount demanded (Amount demanded is $25,000 20CV00905
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows: .
Date: June 23, 2021 Time: 10:30 am. Dept: 1 Div.: TBD Room: TBD
Address of court (if difierent from the address above):
Notice of intent to Appear by Telephone, by (name): Erwin Williams, Esq.
lNSTRUCTlONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. DC] This statement is submitted by party (name): Erwin Williams, Guardian Ad Litem for Edward Niderost
b. C: 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 (data):
b. E] The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. C] All parties named in the complaint and cross—complaint have been served, have appeared, or have been dismissed.
b. [:1 The following parties named in the complaint or cross-complaint
(1) [2 have not been served (specify names and explain why not):
(2) [:3 have been served but have not appeared and have not been dismissed (specify names):
(3) [:1 have had a default entered against them (specify names):
0. [:3 The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
3- Type Of case 'n I: complaint [:1 cross—complaint (Describe, including causes of action):
Complaint to foreclose on deed of trust and for specific performance; cross-complaint for elder abuse, common
count, civil concpiracy for fraud, involuntary trust, declaratiory and injunctive relief, breach of fiduicary duty,
unconscionability, predatory lending and breach of good faith and fair dealing.
Page 1 of 5
Form Adopted for Mandatory Use
Judicial Council of California
CASE MANAGEMENT STATEMENT Cal, Rules of Court,
rules 3120—3130
_
0M4 10 (Rev. JUIY 1. 2011} www.courtscagov
LexisNexis® Automated California Judicial Council Farms
CM-110
PLAINTIFF/PETITIONER; Wayne A. Cook, Trustee of the Wayne A. Cook 1998 Family Trust daied’isfiW/Mgm:
DEFENDANT/RESPONDENT: Edward F. Niderost, individually of the Edward F. Niderost
and as Trustee 20CV00905
4. b. Provide a brief statemenihif’litigatéaese‘flll‘c‘baih‘ésgflftfigdéé%‘¥9fir 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.)
Plaintiff filed his complaint against defendant to foreclose on a deed of trust and for specific
performance. Defendant subsequently filed his cross—complaint alleging elder abuse and other causes of
action.
E! (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 [:1 a jury trialE] a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. E: The trial has been set for (date):
b. [:1 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. [:3 days (specify number):
b. [:3 hours (short causes) (specify):
8. Trial representation (to be answered for each party)
C]
The party or parties will be represented at trial by the attorney or party listed in the caption[:3 by the following:
a. Attorney:
b Firm:
0 Address:
d. Telephone number: f. Fax number:
e E—mail address:
9. Party represented:
[:3 Additional representation is described in Attachment 8.
9. Preference
I: 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 :3 has [:1 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[:3 has [:3 has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) [:3 This matter is sub'ect to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) [:1 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) [:1 This case of the California Rules of Court or from civil action
is exempt from judicial arbitration under rule 3.811
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
’
CMv110{Rev.July1,2011] .
.
CASE MANAGEMENT STATEMENT .
PageZofS
LexisNexis® A utomated Californ ia Judicial Council Forms
CM-110
PLAINTIFF/PETWIONER: CASE NUMBER:
Wayne A. Cook, Trustee of the Wayne A.
Cook 1998 Family Tmst date d 12/29/98
DEFENDANT/RESPONDENT: 20CV00905
Edward F. Niderost, individually and as Trustee of the Edward F.
Niderost Revocable Living Trust dated 11/08/98 . .
ADR process or processes that the party or parties are Willing
_ _
10. 0. indicate the to participate in, have agreed to pariiCipate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing It 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):
DUDE
Mediation session not yet scheduled
(1) Mediation
1:] Mediation session scheduled for (date):
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
DUDE
(2) Settlement
conference
[:3 Settlement conference scheduled for (date):
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
DUDE
Neutral evaluation not yet scheduled
(3) N eutra l eva l uation [:3 Neutral evaluation scheduled for (date):
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
DUDE]
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date):
(4) Nonbinding judicial
arbitration
[:3
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
DUDE
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
(5) Binding private
arbitration
[:3
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
UDDD
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other (specify):
E]
Agreed to complete ADR session by (date):
ADR completed on (date):
i,
(SM-110 [Rev Juiy
2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
LexiSNexis® A uiomaied California Judicial Cozmcil Forms
CM
PLAlNTlFF/PETlTlONER: Wayne A. Cook, Trustee of the Wayne A. Cook 1998 Family Trust dated DWIWMBER:
DEFENDANT/RESPONDENT
2OCV00905
Edward F. Niderost, individually and as Trustee of the Edward F.
11_ Insurance Niderost Revocable Living Trust dated 11/08/98
a. [:1 insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: [:3 Yes [:3 No
c. [:3 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.
[:3 Bankruptcy [:3 Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. I: There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
[:1 Additional cases are described in Attachment 13a.
b. [:3 A motion to [:1 consolidate 1:] coordinate will be filed by (name party):
14. Bifurcation
[:3 The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes
of
action (specifi/ moving party, type of motion, and reasons):
15. Other motions
[:3 The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. [:3 The party or parties have completed all discovery.
b. [:1 The following discovery will be completed by the date specified (describe all anticipated discovery):
m Description Date
c. [:3 The foilowing discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM»110[Rev. July
2011]
1,
CASE MANAGEMENT STATEMENT Page 4 of 5
LexisNexis® Automated California Judicial Council Farms
CM-110
PLAINTIFF/PETiTIONERI Wayne A. COOK, Trustee ofthe Wayne A. Cook 1998 Family Trust dated 12 297% NUMBER?
DEFENDANT/RESPONDENT: Edward F. Niderost, individually and as Trustee of the Edward F. 20CV00905
Niderost Revocable Living Trust dated 1 1/08/98
17. Economic litigation
a. C] 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. [:3 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):
The authorities of Erwin Williams, as guardian ad litem for Edward Niderost, were and are limited in scope to the issue of defending
Defendant Niderost's deposition and/or the filing of a protective order as set forth in the Application and Order for Appointment of
Guardian Ad Litem granted December 1, 2020 in this matter and expanded to represent Mr. Niderost’s interest at trial on April 6,
2021 as set forth in the Amended Application and Order for Appointment of Guardian Ad Litem granted March 29, 2021 in this
matter.
19. Meet and confer
a.[:I 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): 0
Iam 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: May 28, 2021
Erwin Williams P “At. ,
(TYPE OR PRINT NAME) OF PARTY
(SIGQTURE
ORjORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
E: Additional signatures are attached.
CM‘llolReV‘ My20“]
1-
CASE MANAGEMENT STATEMENT Page
LexisNexis® Automated California Judicial Council Forms
PROOF OF SERVICE
I am a citizen of the United States and employed in Butte County, California. I am over the age
of eighteen (18) years and not a party to the Within action. My business address is 55 Independence
Circle, Suite 106, Chico, California 95973. On May 28, 2021, I served the following:
CASE MANAGEMENT STATEMENT
2L. by placing a true copy thereof enclosed in a sealed envelope with postage fully prepaid and:
(a) depositing the sealed envelope with the United States Postal Service;
2L (b) placing the envelope for collection and mailing on the date and at the place shown below
following our ordinary business practices. 1 am readily familiar with this business' practice for
collecting and processing correspondence for mailing. On the same day that correspondence is
placed for collection of business with the United States Postal Service in a sealed envelope with
postage fully prepaid.
Via personal service.
Via electronic transmittal.
Via facsimile transmission.
Name and address of person served:
Raymond L. Sandelman, Esq. Larry Gene Lushanko, Esq.
Attorney at Law Law Office of Larry G. Lushanko
196 Cohasset Road, Suite 225 1241 E Mission Road
Chico, CA 95926 Fallbrook, CA 92028
Raoul LeClerc, Esq. Sara M. Knowles, Esq.
P.O. Drawer 111 Leland, Morrissey & Knowles LLP
Oroville, CA 95965 1660 Humboldt Road, Suite 6
Chico, CA 95928
l declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct.
M)
Executed on May 28, 2021, at Chico, California. iffy/fat, if“
i
Rebecca Yuhasz
H
Preview
CM-110 ATTORNEY 0R PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Erwin Williams (Bar # 206908) McKernan, Lanam, Bakke & Williams LLP 55 Inde endence Circle, Suite 106 Chico, A 95973 Cdu'td CII‘I'IlIII'I'IlI TELEPHONE NO: (530) 877-4961 FAX NO. (Optional): (530) 877_8163 Superior —F E-MAIL ADDRESS (Optional): GWWHBUIIB lawoffice@mlbwlaw.com I | ATTORNEY FOR (Name): L 5/28/2021 L SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE STREET ADDRESS:1775 Concord Avenue E E 1775 MAILING ADDRESS: Concord Avenue D D Chico 95928 CITY AND ZIP CODE: new BRANCH NAME:Civil Department WFlLED PLAlNTlFF/PETITIONERI Wayne A. Cook, Trustee of the Wayne A, Cook 1998 Family Trust dated 12/29/98 DEFENDANT/RESPONDENT: Edward F. Niderost, individually and as Trustee of the Edward F. NidernsLReLhwnglmsLdated l ”DR/QR CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): [2] UNLIMITED CASE [:1 LlMlTED CASE (Amount demanded (Amount demanded is $25,000 20CV00905 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: . Date: June 23, 2021 Time: 10:30 am. Dept: 1 Div.: TBD Room: TBD Address of court (if difierent from the address above): Notice of intent to Appear by Telephone, by (name): Erwin Williams, Esq. lNSTRUCTlONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. DC] This statement is submitted by party (name): Erwin Williams, Guardian Ad Litem for Edward Niderost b. C: 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 (data): b. E] The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. C] All parties named in the complaint and cross—complaint have been served, have appeared, or have been dismissed. b. [:1 The following parties named in the complaint or cross-complaint (1) [2 have not been served (specify names and explain why not): (2) [:3 have been served but have not appeared and have not been dismissed (specify names): (3) [:1 have had a default entered against them (specify names): 0. [:3 The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case 3- Type Of case 'n I: complaint [:1 cross—complaint (Describe, including causes of action): Complaint to foreclose on deed of trust and for specific performance; cross-complaint for elder abuse, common count, civil concpiracy for fraud, involuntary trust, declaratiory and injunctive relief, breach of fiduicary duty, unconscionability, predatory lending and breach of good faith and fair dealing. Page 1 of 5 Form Adopted for Mandatory Use Judicial Council of California CASE MANAGEMENT STATEMENT Cal, Rules of Court, rules 3120—3130 _ 0M4 10 (Rev. JUIY 1. 2011} www.courtscagov LexisNexis® Automated California Judicial Council Farms CM-110 PLAINTIFF/PETITIONER; Wayne A. Cook, Trustee of the Wayne A. Cook 1998 Family Trust daied’isfiW/Mgm: DEFENDANT/RESPONDENT: Edward F. Niderost, individually of the Edward F. Niderost and as Trustee 20CV00905 4. b. Provide a brief statemenihif’litigatéaese‘flll‘c‘baih‘ésgflftfigdéé%‘¥9fir 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.) Plaintiff filed his complaint against defendant to foreclose on a deed of trust and for specific performance. Defendant subsequently filed his cross—complaint alleging elder abuse and other causes of action. E! (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 [:1 a jury trialE] a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. E: The trial has been set for (date): b. [:1 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. [:3 days (specify number): b. [:3 hours (short causes) (specify): 8. Trial representation (to be answered for each party) C] The party or parties will be represented at trial by the attorney or party listed in the caption[:3 by the following: a. Attorney: b Firm: 0 Address: d. Telephone number: f. Fax number: e E—mail address: 9. Party represented: [:3 Additional representation is described in Attachment 8. 9. Preference I: 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 :3 has [:1 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[:3 has [:3 has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) [:3 This matter is sub'ect to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) [:1 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) [:1 This case of the California Rules of Court or from civil action is exempt from judicial arbitration under rule 3.811 mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): ’ CMv110{Rev.July1,2011] . . CASE MANAGEMENT STATEMENT . PageZofS LexisNexis® A utomated Californ ia Judicial Council Forms CM-110 PLAINTIFF/PETWIONER: CASE NUMBER: Wayne A. Cook, Trustee of the Wayne A. Cook 1998 Family Tmst date d 12/29/98 DEFENDANT/RESPONDENT: 20CV00905 Edward F. Niderost, individually and as Trustee of the Edward F. Niderost Revocable Living Trust dated 11/08/98 . . ADR process or processes that the party or parties are Willing _ _ 10. 0. indicate the to participate in, have agreed to pariiCipate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing It 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): DUDE Mediation session not yet scheduled (1) Mediation 1:] Mediation session scheduled for (date): Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled DUDE (2) Settlement conference [:3 Settlement conference scheduled for (date): Agreed to complete settlement conference by (date): Settlement conference completed on (date): DUDE Neutral evaluation not yet scheduled (3) N eutra l eva l uation [:3 Neutral evaluation scheduled for (date): Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): DUDE] Judicial arbitration not yet scheduled Judicial arbitration scheduled for (date): (4) Nonbinding judicial arbitration [:3 Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): DUDE Private arbitration not yet scheduled Private arbitration scheduled for (date): (5) Binding private arbitration [:3 Agreed to complete private arbitration by (date): Private arbitration completed on (date): UDDD ADR session not yet scheduled ADR session scheduled for (date): (6) Other (specify): E] Agreed to complete ADR session by (date): ADR completed on (date): i, (SM-110 [Rev Juiy 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT LexiSNexis® A uiomaied California Judicial Cozmcil Forms CM PLAlNTlFF/PETlTlONER: Wayne A. Cook, Trustee of the Wayne A. Cook 1998 Family Trust dated DWIWMBER: DEFENDANT/RESPONDENT 2OCV00905 Edward F. Niderost, individually and as Trustee of the Edward F. 11_ Insurance Niderost Revocable Living Trust dated 11/08/98 a. [:1 insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: [:3 Yes [:3 No c. [:3 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. [:3 Bankruptcy [:3 Other (specify): Status: 13. Related cases, consolidation, and coordination a. I: There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: [:1 Additional cases are described in Attachment 13a. b. [:3 A motion to [:1 consolidate 1:] coordinate will be filed by (name party): 14. Bifurcation [:3 The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specifi/ moving party, type of motion, and reasons): 15. Other motions [:3 The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. [:3 The party or parties have completed all discovery. b. [:1 The following discovery will be completed by the date specified (describe all anticipated discovery): m Description Date c. [:3 The foilowing discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM»110[Rev. July 2011] 1, CASE MANAGEMENT STATEMENT Page 4 of 5 LexisNexis® Automated California Judicial Council Farms CM-110 PLAINTIFF/PETiTIONERI Wayne A. COOK, Trustee ofthe Wayne A. Cook 1998 Family Trust dated 12 297% NUMBER? DEFENDANT/RESPONDENT: Edward F. Niderost, individually and as Trustee of the Edward F. 20CV00905 Niderost Revocable Living Trust dated 1 1/08/98 17. Economic litigation a. C] 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. [:3 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): The authorities of Erwin Williams, as guardian ad litem for Edward Niderost, were and are limited in scope to the issue of defending Defendant Niderost's deposition and/or the filing of a protective order as set forth in the Application and Order for Appointment of Guardian Ad Litem granted December 1, 2020 in this matter and expanded to represent Mr. Niderost’s interest at trial on April 6, 2021 as set forth in the Amended Application and Order for Appointment of Guardian Ad Litem granted March 29, 2021 in this matter. 19. Meet and confer a.[:I 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): 0 Iam 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: May 28, 2021 Erwin Williams P “At. , (TYPE OR PRINT NAME) OF PARTY (SIGQTURE ORjORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) E: Additional signatures are attached. CM‘llolReV‘ My20“] 1- CASE MANAGEMENT STATEMENT Page LexisNexis® Automated California Judicial Council Forms PROOF OF SERVICE I am a citizen of the United States and employed in Butte County, California. I am over the age of eighteen (18) years and not a party to the Within action. My business address is 55 Independence Circle, Suite 106, Chico, California 95973. On May 28, 2021, I served the following: CASE MANAGEMENT STATEMENT 2L. by placing a true copy thereof enclosed in a sealed envelope with postage fully prepaid and: (a) depositing the sealed envelope with the United States Postal Service; 2L (b) placing the envelope for collection and mailing on the date and at the place shown below following our ordinary business practices. 1 am readily familiar with this business' practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection of business with the United States Postal Service in a sealed envelope with postage fully prepaid. Via personal service. Via electronic transmittal. Via facsimile transmission. Name and address of person served: Raymond L. Sandelman, Esq. Larry Gene Lushanko, Esq. Attorney at Law Law Office of Larry G. Lushanko 196 Cohasset Road, Suite 225 1241 E Mission Road Chico, CA 95926 Fallbrook, CA 92028 Raoul LeClerc, Esq. Sara M. Knowles, Esq. P.O. Drawer 111 Leland, Morrissey & Knowles LLP Oroville, CA 95965 1660 Humboldt Road, Suite 6 Chico, CA 95928 l declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. M) Executed on May 28, 2021, at Chico, California. iffy/fat, if“ i Rebecca Yuhasz H