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alum Court d Caihr‘nll F
Raymond L. Sandelman SBN 078020 I
600m?“ BUM
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Attorney at Law L L
196 Cohasset Road, Suite 225
3/30/2021
Chico, CA 95926—2284
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(530) 343—5090 / (530) 343—5091 (FAX)
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Email:Raymond@sandelmanlaw.com BF Dani-Ii!
FILED
Attorney for Wayne A. Cook, individually
and as Trustee of The Wayne A. Cook 1998
Family Trust Dated 12/29/98
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 IN AND FOR THE COUNTY OF BUTTE
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WAYNE A. COOK, TRUSTEE OF THE NO" .
ZOCVOOQOS
12 WAYNE A. COOK 1998 FAMILY
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TRUST DATED 12/29/98, NOTICE OF HEARING OF DEMURRER TO
SECOND AMENDED CROSS COMPLAINT
Plaintiff ’
14 OF JOHN DENTON, CONSERVATOR OF
v. THE ESTATE OF EDWARD F. NIDEROST
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AND AS SUCCESSOR TRUSTEE OF THE
16 EDWARD F. NIDEROST REVOCABLE
EDWARD F. NIDEROST, LIVING TRUST
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et. at,
Defendants. Attached Documents: Demurrer to Second
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Amended Cross Complaint of John Denton, etc.,
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19 Declaration of Raymond L. Sandelman
AND RELATED CROSS COMPLAINTS
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/ Hearing Date: 4/5/2021
Hearing Time: 8:30 am.
22 Department: 1
Judge: Tamara Mosbarger
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Date of Complaint: 4/22/2020
24 Trial Date: 4/5/2021
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26 TO JOHN DENTON, CONSERVATOR OF THE ESTATE OF EDWARD F. NIDEROST
27 AND AS SUCCESSOR TRUSTEE OF THE EDWARD F. NIDEROST REVOCABLE LIVING
28 TRUST, AND THEIR ATTORNEY LELAND, MORRISSEY & KNOWLES LLP, AND ALL
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NOTICE OF HEARING ON DEMURRER TO SECOND AMENDED CROSS COMPLAINT
OTHER PARTIES:
NOTICE IS HEREBY GIVEN that Wayne A. Cook, Trustee of The Wayne A. Cook 1998
Family Trust Dated 12/29/98’3 demurrer to the First, Eighth and Ninth Causes of Action to the
Second Amended Cross Complaint by John Denton, Conservator Of The Estate Of Edward F.
Niderost and as Successor Trustee Of The Edward F. Niderost Revocable Living Trust has been set
for hearing on April 5, 2021 at 8:30 a.m. or as soon thereafter as the matter can be heard in
Department 1 of the above—entitled court located at 1775 Concord Avenue, Chico, California.
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Dated: $110M. 30; 1.6213 'VWL‘S‘QVQM
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Raymond L. Sandelman
196 COHASSET ROAD, SUITE 225, CHICO, CA 95926-2284
12 Attorney for Wayne A. Cook,
individually and as Trustee of The
(530) 343—5090 / (530) 343-5091 (FAX)
13 Wayne A. Cook 1998 Family Trust
RAYMOND L. SANDELMAN
ATTORNEY AT LAW
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NOTICE OF HEARING ON DEMURRER TO SECOND AMENDED CROSS COMPLAINT
Raymond L. Sandelman SBN 078020
Attorney at Law
196 Cohasset Road, Suite 225
Chico, CA 95926—2284
(530) 343—5090 / (530) 343—5091 (FAX)
Email:Raymond@sandelmanlaw.com
Attorney for Wayne A. Cook, individually
And as Trustee of The Wayne A. Cook 1998
Family Trust Dated 12/29/98
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 IN AND FOR THE COUNTY OF BUTTE
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WAYNE A. COOK, TRUSTEE OF THE
12 NO" ZOCVOOQOS
WAYNE A. COOK 1998 FAMILY
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TRUST DATED 12/29/98, DEMURRER TO SECOND AMENDED
CROSS COMPLAINT OF JOHN DENTON,
Plaintiff ’
14 CONSERVATOR OF THE ESTATE OF
v. EDWARD F. NIDEROST AND AS
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SUCCESSOR TRUSTEE OF THE EDWARD
16 F. NIDEROST REVOCABLE LIVING TRUST
EDWARD F. NIDEROST, et. al.,
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Hearing Date: 4/5/2021
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Defendants. Hearing Time: 8:30 a.m.
Department: 1
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19 Judge: Tamara Mosbarger
AND RELATED CROSS COMPLAINTS Date 0f Complaint: 4/22/2020
20 Trial Date: 4/5/2021
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23 Wayne A. Cook, individually, and Wayne A. Cook, Trustee of The Wayne A. Cook 1998
24 Family Trust Dated 12/29/98 (hereafter referred to as “Wayne A. Cook, Trustee”) demur to the
25 First, Eighth and Ninth Causes of Action to the Second Amended Cross Complaint by John Denton,
26 Conservator Of The Estate Of Edward F. Niderost and as Successor Trustee Of The Edward F.
27 Niderost Revocable Living Trust, on the following grounds:
28 (a) The First Cause of Action in the Second Amended Cross Complaint fails to state facts
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DEMURRER TO SECOND AMENDED CROSS COMPLAINT
sufficient to constitute a cause 0f action against Wayne A. Cook, individually .
(b) The Eighth Cause of Action in the Second Amended Cross Complaint fails to state facts
sufficient to constitute a cause of action against Wayne A. Cook, individually.
(c) The Ninth Cause of Action in the Second Amended Cross Complaint fails to state facts
sufficient to constitute a cause of action against Wayne A. Cook, individually.
(d) The First Cause of Action in the Amended Cross Complaint is uncertain as to Wayne A.
Cook, individually, because it cannot be ascertained if the claims are being made by John Denton,
Conservator Of The Estate Of Edward F . Niderost or John Denton as Successor Trustee Of The
Edward F. Niderost Revocable Living Trust.
lO (e) The Eighth Cause of Action in the Amended Cross Complaint is uncertain Wayne A.
11 Cook, individually because it cannot be ascertained if the claims are being made by John Denton,
196 COHASSET ROAD, SUITE 225, CHICO, CA 95926-2284
12 Conservator Of The Estate Of Edward F. Niderost or John Denton as Successor Trustee Of The
(530) 343-5090 / (530) 343—5091 (FAX)
13 Edward F. Niderost Revocable Living Trust.
RAYMOND L. SANDELMAN
ATTORNEY AT LAW
14 (f) The First Cause of Action in the Second Amended Cross Complaint fails to state facts
15 sufficient to constitute a cause of action against Wayne A. Cook, Trustee.
16 (g) The Eighth Cause of Action in the Second Amended Cross Complaint fails to state facts
l7 sufficient to constitute a cause of action against Wayne A. Cook, Trustee.
l8 (h) The Ninth Cause of Action in the Second Amended Cross Complaint fails to state facts
19 sufficient to constitute a cause of action against Wayne A. Cook, Trustee.
20 (i) The First Cause of Action in the Amended Cross Complaint is uncertain as to Wayne A.
21 Cook, Trustee because it cannot be ascertained if the claims are being made by John Denton,
22 Conservator Of The Estate Of Edward F. Niderost or John Denton as Successor Trustee Of The
23 Edward F. Niderost Revocable Living Trust.
24 (j) The Eighth Cause of Action in the Amended Cross Complaint is uncertain as to Wayne
25 A. Cook, Trustee because it cannot be ascertained if the claims are being made by John Denton,
26 Conservator Of The Estate Of Edward F. Niderost or John Denton as Successor Trustee Of The
27 Edward F. Niderost Revocable Living Trust.
28 WHEREFORE, Wayne A. Cook, individually, and as Trustee of The Wayne A. Cook 1998
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DEMURRER TO SECOND AMENDED CROSS COMPLAINT
Family Trust Dated 12/29/98 pray that the demurrer be sustained without leave to amend, that John
Denton, Conservator Of The Estate Of Edward F. Niderost and as Successor Trustee Of The Edward
F. Niderost Revocable Living Trust’s First, Eighth, and Ninth Causes of Action of their Second
Amended Cross Complaint be stricken, and judgment on the Second Amended Cross Complaint be
entered in favor of Wayne A. Cook, individually, and as Trustee of The Wayne A. Cook 1998
Family Trust Dated 12/29/98, and for all other proper relief.
9II'
Dated: Fix/{0.1, 3.0
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Raymond L. Sandelman
10 Attorney for Wayne A. Cook,
individually and as Trustee of The
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Wayne A. Cook 1998 Family Trust
196 COHASSET ROAD, SUITE 225, Cmco, CA 95926-2284
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(530) 343—5090 / (530) 343—5091 (FAX)
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RAYMOND L. SANDELMAN
ATTORNEY AT LAW
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DEMURRER TO SECOND AMENDED CROSS COMPLAINT
Raymond L. Sandelman SBN 078020
Attorney at Law
196 Cohasset Road, Suite 225
Chico, CA 95926—2284
(530) 343-5090 / (530) 343—5091 (FAX)
Email: Raymond@sandelmanlaw. com
Attorney for Wayne A. Cook, individually
And as Trustee of The Wayne A. Cook 1998
Family Trust Dated 12/29/98
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 IN AND FOR THE COUNTY OF BUTTE
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WAYNE A. COOK, TRUSTEE 0F THE
12 NO" 200100905
,
WAYNE A. COOK 1998 FAMILY
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TRUST DATED 12/29/98, DECLARATION 1N SUPPORT OF
Plaintiff’
DEMURRER TO SECOND AMENDED
14 CROSS COMPLAINT OE JOHN DENTON,
v. CONSERVATOR OE THE ESTATE OP
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EDWARD E. NIDEROST AND AS
16 SUCCESSOR TRUSTEE OF THE EDWARD
EDWARD F. NIDEROST, F. NIDEROST REVOCABLE LIVING TRUST
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et- al"
Defendants. Hearing Date: 4/5/2021
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Hearing Time: 8:30 a.m.
/
19 Department: 1
AND RELATED CROSS COMPLAINTS Judge: Tamara Mosbarger
2O Date of Complaint: 4/22/2020
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/ Trial Date: 4/5/2021
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23 I, Raymond L. Sandelman, declare that:
24 1. I am an attorney licensed to practice in all California state courts, and the attorney for
25 Wayne A. Cook, Trustee of The Wayne A. Cook 1998 Family Trust Dated 12/29/98.
26 2. I sent defense counsel a meet and confer communication and a draft of this demurrer
27 discussing the pleading deficiencies in the Second Amended Cross Complaint on March 29, 2021 at
28 4:42 p.m. and advised her that I would telephone her on March 30, 2021 at 9:30 am. Ms. Knowles
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DECLARATION IN SUPPORT OF DEMURRER TO SECOND AMENDED CROSS COMPLAINT
did not take my telephone call when I tried to discuss the pleading deficiencies. She did not respond
in writing to my meet and confer communication.
I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct.
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Raymond L. Sandelman
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196 COHASSET ROAD, SUITE 225, CHICO, CA 95926-2284
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(530) 343—5090 / (530) 343—5091 (FAX)
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RAYMOND L. SANDELMAN
ATTORNEY AT LAW
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DECLARATION IN SUPPORT OF DEMURRER TO SECOND AMENDED CROSS COMPLAINT
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
95926—2284, in said County and State. On today's date, I served copies of the Notice Of Hearing On
Demurrer To Second Amended Cross Complaint Of John Denton, Conservator Of The Estate Of
Edward F. Niderost And As Successor Trustee Of The Edward F. Niderost Revocable Living Trust,
Demurrer To Second Amended Cross Complaint Of John Denton, Conservator Of The Estate Of
Edward F. Niderost And As Successor Trustee Of The Edward F. Niderost Revocable Living Trust,
Declaration In Support Of Demurrer To Second Amended Cross Complaint Of John Denton,
Conservator Of The Estate Of Edward F. Niderost And As Successor Trustee Of The Edward F.
Niderost Revocable Living Trust, on the following person(s) at the following address(s), in the
manner indicated below:
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11 Gene Culley Larry Gene Lushanko
2185 Esplanade Law Office of Larry G. Lushanko
12 Chico, CA 95926 1241 E Mission Rd.
Fallbrook, CA 92028
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14 Sara M. Knowles, Esq. Amy E. Starrett, Esq.
Leland, Morrissey & Knowles LLP First American Title Insurance Company
15 1660 Humboldt Road, Suite 6 5 First American Way
16 Chico, CA 95928 Santa Ana, CA 92707
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BY TRANSMITTING THE DOCUMENT(S) ELECTRONICALLY via the following
18 X email addresses: office@lushankolaw.com; gculley@sbcglobal.net;
19 sknowles@chicolawyer.com; astarrett@firstam.com
20 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
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and mailing, following our ordinary business practices. I am readily familiar with this
22 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
23 fully prepaid. I am employed in the county where the mailing occurred. The envelope or package
was placed in the mail at Chico, CA.
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25 I certify under penalty of perjury that the foregoing is true and correct, and this declaration
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of service was executed on March g
{A} , 2021 at Chico, California.
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QMLL /-im(mam\)
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S’hylafiAn‘derson
m:lorig_data\worklclient directorieslcook, wayne I814lnoticedemurrer 330.d0cx
PROOF OF SERVICE
Preview
alum Court d Caihr‘nll F Raymond L. Sandelman SBN 078020 I 600m?“ BUM I Attorney at Law L L 196 Cohasset Road, Suite 225 3/30/2021 Chico, CA 95926—2284 E E (530) 343—5090 / (530) 343—5091 (FAX) D D Email:Raymond@sandelmanlaw.com BF Dani-Ii! FILED Attorney for Wayne A. Cook, individually and as Trustee of The Wayne A. Cook 1998 Family Trust Dated 12/29/98 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 IN AND FOR THE COUNTY OF BUTTE 11 WAYNE A. COOK, TRUSTEE OF THE NO" . ZOCVOOQOS 12 WAYNE A. COOK 1998 FAMILY 13 TRUST DATED 12/29/98, NOTICE OF HEARING OF DEMURRER TO SECOND AMENDED CROSS COMPLAINT Plaintiff ’ 14 OF JOHN DENTON, CONSERVATOR OF v. THE ESTATE OF EDWARD F. NIDEROST 15 AND AS SUCCESSOR TRUSTEE OF THE 16 EDWARD F. NIDEROST REVOCABLE EDWARD F. NIDEROST, LIVING TRUST 17 et. at, Defendants. Attached Documents: Demurrer to Second 18 Amended Cross Complaint of John Denton, etc., / 19 Declaration of Raymond L. Sandelman AND RELATED CROSS COMPLAINTS 20 21 / Hearing Date: 4/5/2021 Hearing Time: 8:30 am. 22 Department: 1 Judge: Tamara Mosbarger 23 Date of Complaint: 4/22/2020 24 Trial Date: 4/5/2021 25 26 TO JOHN DENTON, CONSERVATOR OF THE ESTATE OF EDWARD F. NIDEROST 27 AND AS SUCCESSOR TRUSTEE OF THE EDWARD F. NIDEROST REVOCABLE LIVING 28 TRUST, AND THEIR ATTORNEY LELAND, MORRISSEY & KNOWLES LLP, AND ALL 1 NOTICE OF HEARING ON DEMURRER TO SECOND AMENDED CROSS COMPLAINT OTHER PARTIES: NOTICE IS HEREBY GIVEN that Wayne A. Cook, Trustee of The Wayne A. Cook 1998 Family Trust Dated 12/29/98’3 demurrer to the First, Eighth and Ninth Causes of Action to the Second Amended Cross Complaint by John Denton, Conservator Of The Estate Of Edward F. Niderost and as Successor Trustee Of The Edward F. Niderost Revocable Living Trust has been set for hearing on April 5, 2021 at 8:30 a.m. or as soon thereafter as the matter can be heard in Department 1 of the above—entitled court located at 1775 Concord Avenue, Chico, California. 1O Dated: $110M. 30; 1.6213 'VWL‘S‘QVQM 11 Raymond L. Sandelman 196 COHASSET ROAD, SUITE 225, CHICO, CA 95926-2284 12 Attorney for Wayne A. Cook, individually and as Trustee of The (530) 343—5090 / (530) 343-5091 (FAX) 13 Wayne A. Cook 1998 Family Trust RAYMOND L. SANDELMAN ATTORNEY AT LAW 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 NOTICE OF HEARING ON DEMURRER TO SECOND AMENDED CROSS COMPLAINT Raymond L. Sandelman SBN 078020 Attorney at Law 196 Cohasset Road, Suite 225 Chico, CA 95926—2284 (530) 343—5090 / (530) 343—5091 (FAX) Email:Raymond@sandelmanlaw.com Attorney for Wayne A. Cook, individually And as Trustee of The Wayne A. Cook 1998 Family Trust Dated 12/29/98 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 IN AND FOR THE COUNTY OF BUTTE 11 WAYNE A. COOK, TRUSTEE OF THE 12 NO" ZOCVOOQOS WAYNE A. COOK 1998 FAMILY 13 TRUST DATED 12/29/98, DEMURRER TO SECOND AMENDED CROSS COMPLAINT OF JOHN DENTON, Plaintiff ’ 14 CONSERVATOR OF THE ESTATE OF v. EDWARD F. NIDEROST AND AS 15 SUCCESSOR TRUSTEE OF THE EDWARD 16 F. NIDEROST REVOCABLE LIVING TRUST EDWARD F. NIDEROST, et. al., 17 Hearing Date: 4/5/2021 18 Defendants. Hearing Time: 8:30 a.m. Department: 1 / 19 Judge: Tamara Mosbarger AND RELATED CROSS COMPLAINTS Date 0f Complaint: 4/22/2020 20 Trial Date: 4/5/2021 / 21 22 23 Wayne A. Cook, individually, and Wayne A. Cook, Trustee of The Wayne A. Cook 1998 24 Family Trust Dated 12/29/98 (hereafter referred to as “Wayne A. Cook, Trustee”) demur to the 25 First, Eighth and Ninth Causes of Action to the Second Amended Cross Complaint by John Denton, 26 Conservator Of The Estate Of Edward F. Niderost and as Successor Trustee Of The Edward F. 27 Niderost Revocable Living Trust, on the following grounds: 28 (a) The First Cause of Action in the Second Amended Cross Complaint fails to state facts 3 DEMURRER TO SECOND AMENDED CROSS COMPLAINT sufficient to constitute a cause 0f action against Wayne A. Cook, individually . (b) The Eighth Cause of Action in the Second Amended Cross Complaint fails to state facts sufficient to constitute a cause of action against Wayne A. Cook, individually. (c) The Ninth Cause of Action in the Second Amended Cross Complaint fails to state facts sufficient to constitute a cause of action against Wayne A. Cook, individually. (d) The First Cause of Action in the Amended Cross Complaint is uncertain as to Wayne A. Cook, individually, because it cannot be ascertained if the claims are being made by John Denton, Conservator Of The Estate Of Edward F . Niderost or John Denton as Successor Trustee Of The Edward F. Niderost Revocable Living Trust. lO (e) The Eighth Cause of Action in the Amended Cross Complaint is uncertain Wayne A. 11 Cook, individually because it cannot be ascertained if the claims are being made by John Denton, 196 COHASSET ROAD, SUITE 225, CHICO, CA 95926-2284 12 Conservator Of The Estate Of Edward F. Niderost or John Denton as Successor Trustee Of The (530) 343-5090 / (530) 343—5091 (FAX) 13 Edward F. Niderost Revocable Living Trust. RAYMOND L. SANDELMAN ATTORNEY AT LAW 14 (f) The First Cause of Action in the Second Amended Cross Complaint fails to state facts 15 sufficient to constitute a cause of action against Wayne A. Cook, Trustee. 16 (g) The Eighth Cause of Action in the Second Amended Cross Complaint fails to state facts l7 sufficient to constitute a cause of action against Wayne A. Cook, Trustee. l8 (h) The Ninth Cause of Action in the Second Amended Cross Complaint fails to state facts 19 sufficient to constitute a cause of action against Wayne A. Cook, Trustee. 20 (i) The First Cause of Action in the Amended Cross Complaint is uncertain as to Wayne A. 21 Cook, Trustee because it cannot be ascertained if the claims are being made by John Denton, 22 Conservator Of The Estate Of Edward F. Niderost or John Denton as Successor Trustee Of The 23 Edward F. Niderost Revocable Living Trust. 24 (j) The Eighth Cause of Action in the Amended Cross Complaint is uncertain as to Wayne 25 A. Cook, Trustee because it cannot be ascertained if the claims are being made by John Denton, 26 Conservator Of The Estate Of Edward F. Niderost or John Denton as Successor Trustee Of The 27 Edward F. Niderost Revocable Living Trust. 28 WHEREFORE, Wayne A. Cook, individually, and as Trustee of The Wayne A. Cook 1998 4 DEMURRER TO SECOND AMENDED CROSS COMPLAINT Family Trust Dated 12/29/98 pray that the demurrer be sustained without leave to amend, that John Denton, Conservator Of The Estate Of Edward F. Niderost and as Successor Trustee Of The Edward F. Niderost Revocable Living Trust’s First, Eighth, and Ninth Causes of Action of their Second Amended Cross Complaint be stricken, and judgment on the Second Amended Cross Complaint be entered in favor of Wayne A. Cook, individually, and as Trustee of The Wayne A. Cook 1998 Family Trust Dated 12/29/98, and for all other proper relief. 9II' Dated: Fix/{0.1, 3.0 .. fzp' ‘ Q LES WL‘WWN. Raymond L. Sandelman 10 Attorney for Wayne A. Cook, individually and as Trustee of The 11 Wayne A. Cook 1998 Family Trust 196 COHASSET ROAD, SUITE 225, Cmco, CA 95926-2284 12 (530) 343—5090 / (530) 343—5091 (FAX) 13 RAYMOND L. SANDELMAN ATTORNEY AT LAW 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 DEMURRER TO SECOND AMENDED CROSS COMPLAINT Raymond L. Sandelman SBN 078020 Attorney at Law 196 Cohasset Road, Suite 225 Chico, CA 95926—2284 (530) 343-5090 / (530) 343—5091 (FAX) Email: Raymond@sandelmanlaw. com Attorney for Wayne A. Cook, individually And as Trustee of The Wayne A. Cook 1998 Family Trust Dated 12/29/98 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 IN AND FOR THE COUNTY OF BUTTE 11 WAYNE A. COOK, TRUSTEE 0F THE 12 NO" 200100905 , WAYNE A. COOK 1998 FAMILY 13 TRUST DATED 12/29/98, DECLARATION 1N SUPPORT OF Plaintiff’ DEMURRER TO SECOND AMENDED 14 CROSS COMPLAINT OE JOHN DENTON, v. CONSERVATOR OE THE ESTATE OP 15 EDWARD E. NIDEROST AND AS 16 SUCCESSOR TRUSTEE OF THE EDWARD EDWARD F. NIDEROST, F. NIDEROST REVOCABLE LIVING TRUST 17 et- al" Defendants. Hearing Date: 4/5/2021 18 Hearing Time: 8:30 a.m. / 19 Department: 1 AND RELATED CROSS COMPLAINTS Judge: Tamara Mosbarger 2O Date of Complaint: 4/22/2020 21 / Trial Date: 4/5/2021 22 23 I, Raymond L. Sandelman, declare that: 24 1. I am an attorney licensed to practice in all California state courts, and the attorney for 25 Wayne A. Cook, Trustee of The Wayne A. Cook 1998 Family Trust Dated 12/29/98. 26 2. I sent defense counsel a meet and confer communication and a draft of this demurrer 27 discussing the pleading deficiencies in the Second Amended Cross Complaint on March 29, 2021 at 28 4:42 p.m. and advised her that I would telephone her on March 30, 2021 at 9:30 am. Ms. Knowles 6 DECLARATION IN SUPPORT OF DEMURRER TO SECOND AMENDED CROSS COMPLAINT did not take my telephone call when I tried to discuss the pleading deficiencies. She did not respond in writing to my meet and confer communication. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. . ””3 St: ' 6" 3 _ Dated: 3"}: r iv- V : 2:173} {A Mi ~ \x: "' : Raymond L. Sandelman 10 11 196 COHASSET ROAD, SUITE 225, CHICO, CA 95926-2284 12 (530) 343—5090 / (530) 343—5091 (FAX) 13 RAYMOND L. SANDELMAN ATTORNEY AT LAW 14 15 16 l7 18 19 20 21 22 23 24 25 26 27 28 7 DECLARATION IN SUPPORT OF DEMURRER TO SECOND AMENDED CROSS COMPLAINT 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 95926—2284, in said County and State. On today's date, I served copies of the Notice Of Hearing On Demurrer To Second Amended Cross Complaint Of John Denton, Conservator Of The Estate Of Edward F. Niderost And As Successor Trustee Of The Edward F. Niderost Revocable Living Trust, Demurrer To Second Amended Cross Complaint Of John Denton, Conservator Of The Estate Of Edward F. Niderost And As Successor Trustee Of The Edward F. Niderost Revocable Living Trust, Declaration In Support Of Demurrer To Second Amended Cross Complaint Of John Denton, Conservator Of The Estate Of Edward F. Niderost And As Successor Trustee Of The Edward F. Niderost Revocable Living Trust, on the following person(s) at the following address(s), in the manner indicated below: 10 11 Gene Culley Larry Gene Lushanko 2185 Esplanade Law Office of Larry G. Lushanko 12 Chico, CA 95926 1241 E Mission Rd. Fallbrook, CA 92028 13 14 Sara M. Knowles, Esq. Amy E. Starrett, Esq. Leland, Morrissey & Knowles LLP First American Title Insurance Company 15 1660 Humboldt Road, Suite 6 5 First American Way 16 Chico, CA 95928 Santa Ana, CA 92707 17 BY TRANSMITTING THE DOCUMENT(S) ELECTRONICALLY via the following 18 X email addresses: office@lushankolaw.com; gculley@sbcglobal.net; 19 sknowles@chicolawyer.com; astarrett@firstam.com 20 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 21 and mailing, following our ordinary business practices. I am readily familiar with this 22 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 23 fully prepaid. I am employed in the county where the mailing occurred. The envelope or package was placed in the mail at Chico, CA. 24 25 I certify under penalty of perjury that the foregoing is true and correct, and this declaration 26 of service was executed on March g {A} , 2021 at Chico, California. 27 QMLL /-im(mam\) 28 S’hylafiAn‘derson m:lorig_data\worklclient directorieslcook, wayne I814lnoticedemurrer 330.d0cx PROOF OF SERVICE