Conference: Wayne A Cook, Trustee of the Wayne A Cook 1998 Family Trust Dated 12/29/98 vs Edward f Niderost, Individually and as Trustee of the Edward F Niderost Revocable Living Trust Dated November 8, 1998

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                                F   Supetion Courtof Califomia       F
                                                                                          County of Butte
         Raymond L. Sandelman           SBN 078020                                                                     I
         Attorney at Law
                                                                                          1/11/2022                   L
         196 Cohasset Road, Suite 225
         Chico, CA 95926-2284
         (530) 343-5090 / (530) 343-5091 (FAX)                                        Sparit,    allah,              D
                                                                                                                  Deputy
         Email:Raymond@sandelmanlaw.com
                                                                                          Glectronutally 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
                                           IN AND FOR THE COUNTY        OF BUTTE
10
         WAYNE     A. COOK, TRUSTEE OF THE                      NO.: 20CV00905
11       WAYNE       A. COOK   1998 FAMILY
12       TRUST DATED           12/29/98,                        DECLARATION          OF
                                                                                    RAYMOND    L
                                                                SANDELMAN RE: EFFORTS TO OBTAIN
13                         Plaintiff,                           APPROVAL AS TO FORM FOR PROPOSED
                                                                JUDGMENT
14

1S

16       EDWARD      F. NIDEROST, et. al.,
17                         Defendants.

18                                                      /
19       AND RELATED CROSS COMPLAINTS
20                                                      /
21

22             I, Raymond       L. Sandelman,   declare that:

23             1. I am an attorney licensed to practice in all California State courts, and the attorney for

24   Wayne      A. Cook,      individually and as Trustee of The Wayne    A. Cook     1998 Family Trust Dated

25   12/29/98.
26             2. On January 4, 2022 I sent Sara Knowles via email a proposed judgment to approve as to
27   form. A      true and correct copy of the email and proposed order is attached hereto marked Exhibit

28   1


                                                                1
     DECLARATION OF RAYMOND                 L. SANDELMAN    RE: EFFORTS TO OBTAIN APPROVAL AS TO FORM FOR
     PROPOSED JUDGMENT
3. Ms. Knowles did not return the proposed order.      She did not advise me of any terms in

                the proposed order that she thought were inappropriate.        In this case, she previously decline to
                approve two proposed orders as to form.
                        4. Iam requesting that the Court sign the proposed judgment at this time.

                        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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                                                                   2
                DECLARATION OF RAYMOND         L. SANDELMAN    RE: EFFORTS TO OBTAIN APPROVAL AS TO FORM FOR
                PROPOSED JUDGMENT
EXHIBIT   1
Raymond L. Sandelman

From:                                   Raymond L. Sandelman
Sent:                                   Tuesday, January 4, 2022 1:31 PM
To:                                     Sara Knowles 
Ce:                                     ‘Raoul LeClerc Esq. (rleclerc@leclerclawoffice.com)'
Subject:                                Cook v. Niderost
Attachments:                            Proposed Judgment       104.pdf


Sara:

Attached is a proposed judgement.         Please approve the document as to form by sending me Page 7 with your signature.

| have broken down the award of attorney's fees and costs for Wayne Cook, Trustee based upon the first and second
deeds of trust. The fees for prosecuting and defending claims on the $500,000 note and first deed of trust are
straightforward. Wayne Cook, Trustee is also entitled to attorney’s fees for defending claims to cancel the second deed
of trust and the $674,062.39 note it secures.         See Passanisi v. Merit-McBride Realtors, Inc. (1987) 190 Cal.App.3d             1496
(“Such an award . . . is the result of the debtor-trustor's voluntary act in bringing an unmeritorious suit which the creditor-
beneficiary was required to make expenditures to defend.”). | will file a motion for attorney's fees and you can assert any
Opposition that you feel is appropriate. | am now just advising you why the judgment has the different sections. If you
want any modifications to the proposed judgment, please advise me within five calendar days of your concerns.

RAYMOND L. SANDELMAN
Attorney at Law
196 Cohasset Road, Suite 225
Chico, CA 95926-2284
(530) 343-5090
(530) 343-5091 (Fax)

Raymond      sandelmanlaw.com

NOTE:   This email is confidential and is intended for the recipient(s) listed. If you are not a listed recipient or someone authorized to
receive email on behalf of a listed recipient, please reply to the sender that the email was misdirected and delete the email. Thank you.




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