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SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE
ATrORNEY 0R PARTY wsTHOUT ATTORNEY (Name, stare bar number, and address); FOR coum use ONLY
Raymond L. Sandelman SBN 078020 '
Suwml. Gum H “mm”
Attorney at Law
196 Cohasset Road, Suite 225 CW”? “f Bum
Chico, CA 95926-2284 8/10/2020
TELEPHONE N00; (530) 343—5090 FAX No, (0ptiona/):(530) 343—5091
E-MAIL ADDRESS (Optional);
Raymond@sandelmanlaw.com
Wayne A. Cook, Trustee
AWORNEY FOR (Name);
SUPERIOR COURT OF CALlFORNIA, COUNTY OF BUTTE
D Butte County Courthouse m North Butte County Courthouse
One Court Street, Oroville, CA 95965 1775 Concord Avenue, Chico, CA 95928
(530) 532-7002 (530) 532-7002
PETITIONER/PLAINTIFF: Wayne A. Cook, Trustee of the Wayne A.
Cook 1998 Family Trust dated 12/29/98
RESPONDENT/DEFENDANT: Edward F. Niderost, et al.
CASE NUMBER:
OPPOSITION TO REQUEST FOR A PRETRIAL
20CVOO905
DISCOVERY CONFERENCE
m PIaintiff(s) D Defendant(s) a Cross-complainant(s) m Cross—defendant(s) D Other(s)
Opposition to Request for a Pretrial Discovery Conference.
a Privilege is the basis for the refusal to produce documents and a privilege log is attached which complies with Local Rule 2.14(c).
The parties have engaged in the following meaningful meet and confer efforts prior to ling this opposition: (Describein detail all meet
and confer efforts including any narrowing of the issues or resolutions reached via these efforts.)
On July 30, 2020 Raymond Sandelman advised Andrew Morrissey "If you [Andrew Morrissey] le a motion [for an
extension of time to respond to discovery] please make sure you [Andrew Morrissey] advise the Court that I [Raymond L.
Sandelman] am willing to provide the extension so long as your rm [counsel for Cross Complainants] advises me
[Raymond L. Sandelman] in writing that itwill grant me [Raymond L.Sandelman] reasonable extensions in the future
and follows through on its promise, and that your firm [counsel for Cross Complainants] . . . will take my [Raymond L.
Sandelman's] telephone callsand return my [Raymond L. Sartdelman's] telephone calls, and your rm [counsel for Cross
Complainants] follows through on itspromise. Also advise the court that l[Raymond L. Sandelman] have granted
extensions in the past and that your rm [counsel for Cross Complainants] has refused to grant the one and only request
for an extension that l [Raymond L. Sandelman] made."
This communication was not disclosed in Cross Complainants‘ Request for a Pretrial Conference.
(Lmoao) OPPOSITION TO REQUEST FOR A PRETRIAL 7-1-13
(EPD.
D$COVERYc0NFERENCE
MitféaMd Cook
gb'EoBmlgiw'
A brief summary of why the requested discovery should be denied, including the facts and Iegai arguments in support is as follows:
(Excepting a privilege log if checked above, no pleadings, exhibits, declarations, or attachments shall be attached.)
All of the discovery was due on August 6, 2020. Responses were served on August 3, 2020. They are inadequate, but that
issue is not the subjectof the request for a pretrial conference to obtain an extension.
The discovery issue [Cross Complainant obtaining an extension of time to respond to discovery] can be resolved without a
conference ifcounsel for Cross Complainant willagree to two modest requests that should not require the involvement of the
Court: Counsel for Cross Complainants should state inwriting that that itwillgrant Raymond L.Sandelman reasonable
extensions inthe future and follows through on itspromise, and counsel forCross Complainants will take Raymond L.
Sandelman's telephone calls and return Raymond L. Sandelman's telephone calls, and counsel for Cross Complainants will
follow through on its promise.
It is understood that the lingof the Request for a Pretrial Discovery Conference tolls the time for ling
a motion to compel discovery on
the disputed issues for the number of days between the ling of the request and issuance by the Court of a subsequent order pertaining
to the discovery dispute.
Party received the REQUEST FOR A PRETRIAL DISCOVERY CONFERENCE on: August 8, 2020
Date
Pursuant to Local Rule 2.14(b)1, this opposition is being led within ve (5) court days of service on the Request For Pretrial Discovery
Conference, extended ve (5) days for service by mail, and has been served on the opposing party.
Opposing Party was served with a copy 0fthe OPPOSITION TO REQUEST FOR A PRETRIAL DISCOVERY CONFERENCE on:
August 10, 2020
Date
|declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: August 10, 2020
Raymund | Sandelman SELM55/wlwm
(TYPE OR PRINT NAME) (SIGNA TURE OF PARTY/A TTORNEY FOR PARTY)
(LM.030) OPPOSITION T0 REQUEST FOR A PRETRIAL rye;
°
(alsoage
DISCOVERY CONFERENCE
”alida‘f’WE
CLB f I
Cook
ceb.com ‘
.‘a
PROOF OF SERVICE
95926-2284
I, Wendy Hoy, declare as follows:
I am a resident of the County of Butte, State of California; I am over the age of 18 years and
(530) 343-5090 / (530) 343—5091 (FAX)
196 COHASSET ROAD, SUITE 225. Cmco, CA
not a party to this action; my business address is 196 Cohasset Road, Suite 225, Chico California
RAYMOND L. SANDELMAN
95926—2284, in said County and State. On today's date, I served the Opposition to Request for a
ATTORNEY AT LAW
Pretrial Discovery Conference on the following person(s) at the following address(s), in the manner
indicated below:
David R. Griffith, Esq. Andrew Morrissey
Jameson E.P. Sheehan, Esq. Sara M. Knowles, Esq.
Griffith Horn & Sheehan, LLP Leland, Morrissey & Knowles LLP
1530 Humboldt Road, Suite 3 1660 Humboldt Road, Suite 6
Chico, CA 95928 Chico, CA 95928
BY UNITED STATES MAIL enclosed the documents in a sealed envelope or package
X addressed to the persons at the addresses shown above and placed the envelope for collection
and mailing, following our ordinary business practices. I am readily familiar with this
business's practice for collecting and processing correspondence for mailing, it is deposited in the
ordinary course of business with the United States Postal Service, in a sealed envelope with postage
fully prepaid. I am employed in the county where the mailing occurred. The envelope or package
was placed in the mail at Chico, CA.
BY TRANSMITTING THE DOCUMENT(S) ELECTRONICALLY Via the following
X email addresses: david@davidgriffithlaw.com; jameson@griffithandhorn.com.com;
sknowles@chicolawyer.com; amorrissey@chicolawyer.com.
I certify under penalty of perjury that the foregoing is true and correct, and this declaration
of service was executed on August Q, 2020 at Chico, California.
W/endy Hoy
wayne 1 814lpos opposition 810.docx
m:l0rig_datalworklcliem directorieslcook,
PROOF OF SERVICE
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SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE ATrORNEY 0R PARTY wsTHOUT ATTORNEY (Name, stare bar number, and address); FOR coum use ONLY Raymond L. Sandelman SBN 078020 ' Suwml. Gum H “mm” Attorney at Law 196 Cohasset Road, Suite 225 CW”? “f Bum Chico, CA 95926-2284 8/10/2020 TELEPHONE N00; (530) 343—5090 FAX No, (0ptiona/):(530) 343—5091 E-MAIL ADDRESS (Optional); Raymond@sandelmanlaw.com Wayne A. Cook, Trustee AWORNEY FOR (Name); SUPERIOR COURT OF CALlFORNIA, COUNTY OF BUTTE D Butte County Courthouse m North Butte County Courthouse One Court Street, Oroville, CA 95965 1775 Concord Avenue, Chico, CA 95928 (530) 532-7002 (530) 532-7002 PETITIONER/PLAINTIFF: Wayne A. Cook, Trustee of the Wayne A. Cook 1998 Family Trust dated 12/29/98 RESPONDENT/DEFENDANT: Edward F. Niderost, et al. CASE NUMBER: OPPOSITION TO REQUEST FOR A PRETRIAL 20CVOO905 DISCOVERY CONFERENCE m PIaintiff(s) D Defendant(s) a Cross-complainant(s) m Cross—defendant(s) D Other(s) Opposition to Request for a Pretrial Discovery Conference. a Privilege is the basis for the refusal to produce documents and a privilege log is attached which complies with Local Rule 2.14(c). The parties have engaged in the following meaningful meet and confer efforts prior to ling this opposition: (Describein detail all meet and confer efforts including any narrowing of the issues or resolutions reached via these efforts.) On July 30, 2020 Raymond Sandelman advised Andrew Morrissey "If you [Andrew Morrissey] le a motion [for an extension of time to respond to discovery] please make sure you [Andrew Morrissey] advise the Court that I [Raymond L. Sandelman] am willing to provide the extension so long as your rm [counsel for Cross Complainants] advises me [Raymond L. Sandelman] in writing that itwill grant me [Raymond L.Sandelman] reasonable extensions in the future and follows through on its promise, and that your firm [counsel for Cross Complainants] . . . will take my [Raymond L. Sandelman's] telephone callsand return my [Raymond L. Sartdelman's] telephone calls, and your rm [counsel for Cross Complainants] follows through on itspromise. Also advise the court that l[Raymond L. Sandelman] have granted extensions in the past and that your rm [counsel for Cross Complainants] has refused to grant the one and only request for an extension that l [Raymond L. Sandelman] made." This communication was not disclosed in Cross Complainants‘ Request for a Pretrial Conference. (Lmoao) OPPOSITION TO REQUEST FOR A PRETRIAL 7-1-13 (EPD. D$COVERYc0NFERENCE MitféaMd Cook gb'EoBmlgiw' A brief summary of why the requested discovery should be denied, including the facts and Iegai arguments in support is as follows: (Excepting a privilege log if checked above, no pleadings, exhibits, declarations, or attachments shall be attached.) All of the discovery was due on August 6, 2020. Responses were served on August 3, 2020. They are inadequate, but that issue is not the subjectof the request for a pretrial conference to obtain an extension. The discovery issue [Cross Complainant obtaining an extension of time to respond to discovery] can be resolved without a conference ifcounsel for Cross Complainant willagree to two modest requests that should not require the involvement of the Court: Counsel for Cross Complainants should state inwriting that that itwillgrant Raymond L.Sandelman reasonable extensions inthe future and follows through on itspromise, and counsel forCross Complainants will take Raymond L. Sandelman's telephone calls and return Raymond L. Sandelman's telephone calls, and counsel for Cross Complainants will follow through on its promise. It is understood that the lingof the Request for a Pretrial Discovery Conference tolls the time for ling a motion to compel discovery on the disputed issues for the number of days between the ling of the request and issuance by the Court of a subsequent order pertaining to the discovery dispute. Party received the REQUEST FOR A PRETRIAL DISCOVERY CONFERENCE on: August 8, 2020 Date Pursuant to Local Rule 2.14(b)1, this opposition is being led within ve (5) court days of service on the Request For Pretrial Discovery Conference, extended ve (5) days for service by mail, and has been served on the opposing party. Opposing Party was served with a copy 0fthe OPPOSITION TO REQUEST FOR A PRETRIAL DISCOVERY CONFERENCE on: August 10, 2020 Date |declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: August 10, 2020 Raymund | Sandelman SELM55/wlwm (TYPE OR PRINT NAME) (SIGNA TURE OF PARTY/A TTORNEY FOR PARTY) (LM.030) OPPOSITION T0 REQUEST FOR A PRETRIAL rye; ° (alsoage DISCOVERY CONFERENCE ”alida‘f’WE CLB f I Cook ceb.com ‘ .‘a PROOF OF SERVICE 95926-2284 I, Wendy Hoy, declare as follows: I am a resident of the County of Butte, State of California; I am over the age of 18 years and (530) 343-5090 / (530) 343—5091 (FAX) 196 COHASSET ROAD, SUITE 225. Cmco, CA not a party to this action; my business address is 196 Cohasset Road, Suite 225, Chico California RAYMOND L. SANDELMAN 95926—2284, in said County and State. On today's date, I served the Opposition to Request for a ATTORNEY AT LAW Pretrial Discovery Conference on the following person(s) at the following address(s), in the manner indicated below: David R. Griffith, Esq. Andrew Morrissey Jameson E.P. Sheehan, Esq. Sara M. Knowles, Esq. Griffith Horn & Sheehan, LLP Leland, Morrissey & Knowles LLP 1530 Humboldt Road, Suite 3 1660 Humboldt Road, Suite 6 Chico, CA 95928 Chico, CA 95928 BY UNITED STATES MAIL enclosed the documents in a sealed envelope or package X addressed to the persons at the addresses shown above and placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with this business's practice for collecting and processing correspondence for mailing, it is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid. I am employed in the county where the mailing occurred. The envelope or package was placed in the mail at Chico, CA. BY TRANSMITTING THE DOCUMENT(S) ELECTRONICALLY Via the following X email addresses: david@davidgriffithlaw.com; jameson@griffithandhorn.com.com; sknowles@chicolawyer.com; amorrissey@chicolawyer.com. I certify under penalty of perjury that the foregoing is true and correct, and this declaration of service was executed on August Q, 2020 at Chico, California. W/endy Hoy wayne 1 814lpos opposition 810.docx m:l0rig_datalworklcliem directorieslcook, PROOF OF SERVICE