Preview
Raymond
Attorney
L. Sandelman
at Law
SBN 078020
F mm M —F
196 Cohasset Road, Suite 225 |
“mum“ |
Chico, CA 95926—2284 L 2/22/2021 L
(530) 343—5090 / (530) 343—5091 (FAX) E E
Email: Raymond@sandelmanlaw.com D _
D
for A.
By new
Attorney Wayne Cook, individually
And as Trustee of The Wayne A. Cook 1998
Family Trust Dated 12/29/98
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF BUTTE
10 WAYNE A. COOK, TRUSTEE OF THE No.: 20CV00905
WAYNE A. COOK 1998 FAMILY
11
TRUST DATED 12/29/98, NOTICE OF RESOLUTION OF
12 DISCOVERY DISPUTE RE: SUBPOENA
Plaintiff, ISSUED BY ERWIN WILLIAMS,
13 GUARDIAN AD LIT EM
vs.
14
15 EDWARD F. NIDEROST, et al., Hearing Date: 2/23/2021
Hearing Time: 1:30 p.m.
16 Defendants. Department: 1
l7 / Judge: Tamara
Mosbarger
18 AND RELATED CROSS COMPLAINTS. Date of Complaint: 4/22/2020
Trial Date: 3/29/2021
19
/
20
21
22 TO THE PARTIES HEREIN AND TO THEIR ATTORNEYS:
23 PLEASE TAKE NOTICE that the discovery dispute concerning the issuance of a subpoena
24 by Erwin Williams, guardian ad litem for Edward Niderost has been resolved. Counsel for Plaintiff
25 requests that the discovery conference on this issue set for hearing on February 26, 2021 be dropped.
26 The discovery dispute concerning the expert witness disclosures by John Denton,
27 Conservator and Successor Trustee has not been resolved. A conference on this issue has
discovery
28 been set for the same time on February 26, 2021.
1
NOTICE OF RESOLUTION OF DISCOVERY DISPUTE RE: SUBPOENA ISSUED BY ERWIN WILLIAMS,
GUARDIAN AD LITEM
(D: R. {I
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Dated: <
Raymond L. Sandelman
Attorney for Wayne A. Cook, individually
And as Trustee of The Wayne A. Cook 1998
Family Trust Dated 12/29/98
196 COHASSET ROAD, SUITE 225, CHICO, CA 95926—2284
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(530) 343-5090 / (530) 343—5091 (FAX)
11
DAIVDLLKVIAIV
12
ATTORNEY AT LAW
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“HUN”
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NOTICE OF RESOLUTION OF DISCOVERY DISPUTE RE: SUBPOENA ISSUED BY ERWIN WILLIAMS,
GUARDIAN AD LITEM
PROOF OF SERVICE
I, Shyla Anderson, declare as follows:
I am employed in the County of Butte, State of California; I am over the age of 18 years and
not a party to this action; my business address is 196 Cohasset Road, Suite 225, Chico California
in said and State. On I served of the Notice Of
95926—2284,
Resolution Of Discovery
County
Re:
February
Issued
2;: , 2021,
Erwin
copies
Guardian Ad Litem on
Dispute Subpoena By Williams,
the following person(s) at the following address(s), in the manner indicated below:
David R. Griffith, Esq. Sara M. Knowles, Esq.
Jameson E.P. Sheehan, Esq. Leland, Morrissey & Knowles LLP
Griffith Horn & Sheehan, LLP 1600 Humboldt Road, Suite 6
1530 Humboldt Road, Suite 3 Chico, CA 95928
Chico, CA 95928
10
Larry Gene Lushanko Erwin Williams
ll Law Office of Larry G. Lushanko McKernan, Lanam, Bakke & Williams
12
1241 E. Mission Rd. LLP
95926—2284
Fallbrook, CA 92028 55 Independence Circle, Suite 106
13 Chico, CA 95973
(530) 343—5090 / (530) 343—5091 (FAX)
196 COHASSET ROAD, SUITE 225, CHICO, CA
14
RAYMOND L. SANDELMAN
BY UNITED STATES MAIL
ATTORNEY AT LAW
15 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
16 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
17
ordinary course of business with the United States Postal Service, in a sealed envelope with postage
18 fully prepaid. I am employed in the county where the mailing occurred. The envelope or package
was placed in the mail at Chico, CA.
19
20
BY TRANSMITTING THE DOCUMENT(S) ELECTRONICALLY via the following
X email addresses: david@davidgriffithlaw.com; jameson@griffithandhorn.com,
21 sknowles@chicolawyer.com; office@lushankolaw.com; ; lawoffice@mlbwlaw.org
22
23 I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct, and this declaration of service was executed on Februa yZZ ,2021 at Chico,
24 California.
{W .
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26 Shy'la nderson‘
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wayne 1814lnoticeresoluti0n 222.docx
m:lorig_datalworklclient directorieslcook,
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PROOF OF SERVICE
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Raymond Attorney L. Sandelman at Law SBN 078020 F mm M —F 196 Cohasset Road, Suite 225 | “mum“ | Chico, CA 95926—2284 L 2/22/2021 L (530) 343—5090 / (530) 343—5091 (FAX) E E Email: Raymond@sandelmanlaw.com D _ D for A. By new Attorney Wayne Cook, individually And as Trustee of The Wayne A. Cook 1998 Family Trust Dated 12/29/98 SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF BUTTE 10 WAYNE A. COOK, TRUSTEE OF THE No.: 20CV00905 WAYNE A. COOK 1998 FAMILY 11 TRUST DATED 12/29/98, NOTICE OF RESOLUTION OF 12 DISCOVERY DISPUTE RE: SUBPOENA Plaintiff, ISSUED BY ERWIN WILLIAMS, 13 GUARDIAN AD LIT EM vs. 14 15 EDWARD F. NIDEROST, et al., Hearing Date: 2/23/2021 Hearing Time: 1:30 p.m. 16 Defendants. Department: 1 l7 / Judge: Tamara Mosbarger 18 AND RELATED CROSS COMPLAINTS. Date of Complaint: 4/22/2020 Trial Date: 3/29/2021 19 / 20 21 22 TO THE PARTIES HEREIN AND TO THEIR ATTORNEYS: 23 PLEASE TAKE NOTICE that the discovery dispute concerning the issuance of a subpoena 24 by Erwin Williams, guardian ad litem for Edward Niderost has been resolved. Counsel for Plaintiff 25 requests that the discovery conference on this issue set for hearing on February 26, 2021 be dropped. 26 The discovery dispute concerning the expert witness disclosures by John Denton, 27 Conservator and Successor Trustee has not been resolved. A conference on this issue has discovery 28 been set for the same time on February 26, 2021. 1 NOTICE OF RESOLUTION OF DISCOVERY DISPUTE RE: SUBPOENA ISSUED BY ERWIN WILLIAMS, GUARDIAN AD LITEM (D: R. {I «N )‘ 3: I ‘3 , E 7"“ Dated: < Raymond L. Sandelman Attorney for Wayne A. Cook, individually And as Trustee of The Wayne A. Cook 1998 Family Trust Dated 12/29/98 196 COHASSET ROAD, SUITE 225, CHICO, CA 95926—2284 10 (530) 343-5090 / (530) 343—5091 (FAX) 11 DAIVDLLKVIAIV 12 ATTORNEY AT LAW 13 L. 14 “HUN” 15 M 16 17 18 19 20 21 22 23 24 25 26 27 28 2 NOTICE OF RESOLUTION OF DISCOVERY DISPUTE RE: SUBPOENA ISSUED BY ERWIN WILLIAMS, GUARDIAN AD LITEM PROOF OF SERVICE I, Shyla Anderson, declare as follows: I am employed in the County of Butte, State of California; I am over the age of 18 years and not a party to this action; my business address is 196 Cohasset Road, Suite 225, Chico California in said and State. On I served of the Notice Of 95926—2284, Resolution Of Discovery County Re: February Issued 2;: , 2021, Erwin copies Guardian Ad Litem on Dispute Subpoena By Williams, the following person(s) at the following address(s), in the manner indicated below: David R. Griffith, Esq. Sara M. Knowles, Esq. Jameson E.P. Sheehan, Esq. Leland, Morrissey & Knowles LLP Griffith Horn & Sheehan, LLP 1600 Humboldt Road, Suite 6 1530 Humboldt Road, Suite 3 Chico, CA 95928 Chico, CA 95928 10 Larry Gene Lushanko Erwin Williams ll Law Office of Larry G. Lushanko McKernan, Lanam, Bakke & Williams 12 1241 E. Mission Rd. LLP 95926—2284 Fallbrook, CA 92028 55 Independence Circle, Suite 106 13 Chico, CA 95973 (530) 343—5090 / (530) 343—5091 (FAX) 196 COHASSET ROAD, SUITE 225, CHICO, CA 14 RAYMOND L. SANDELMAN BY UNITED STATES MAIL ATTORNEY AT LAW 15 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 16 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 17 ordinary course of business with the United States Postal Service, in a sealed envelope with postage 18 fully prepaid. I am employed in the county where the mailing occurred. The envelope or package was placed in the mail at Chico, CA. 19 20 BY TRANSMITTING THE DOCUMENT(S) ELECTRONICALLY via the following X email addresses: david@davidgriffithlaw.com; jameson@griffithandhorn.com, 21 sknowles@chicolawyer.com; office@lushankolaw.com; ; lawoffice@mlbwlaw.org 22 23 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and this declaration of service was executed on Februa yZZ ,2021 at Chico, 24 California. {W . i 25 ,1 26 Shy'la nderson‘ 27 wayne 1814lnoticeresoluti0n 222.docx m:lorig_datalworklclient directorieslcook, 28 PROOF OF SERVICE