Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
MICHAEL A.J. NANGANO, ESQ. SBN 133999
MICHAEL A.J. NANGANO, A LAW CORPORATION
133 North Altadena Drive, Suite 403
Pasadena, CA 91107
TELEPHONE NO: (626) 796-9998 FAX NO.(Optiona): (213) 232-3252
E-MAIL ADDRESS (Optional): Mnangano@lacounsel.com
ATTORNEY FOR (Name): Erik Ludwick, et al.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Placer
streetappress: 10820 Justice Center Drive
MAILING ADDRESS:
ak Chatters
Officer & Clerk
cityanozipcooe: Roseville, CA 95678 Executive bard, Deputy
srancHname: Bill Santucci Justice Center
PLAINTIFF/PETITIONER: Pacific Union International, Inc.
DEFENDANT/RESPONDENT: Erik Ludwick, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): [Z] UNLIMITED CASE (-) LiMiTED CASE SCV0042080
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Time: 10:00 a.m. Dept.: 40 Div.: Room:
Date: March 12, 2019
Address of court (if different from the address above):
(] Notice of Intent to Appear by Telephone, by (name): Michael AJ Nangano, Esq.
information must be provided.
INSTRUCTIONS: All applicable boxes must be checked, and the specified
1. Party or parties (answer one):
a. QW] This statement is submitted by party (name): Defendants Erik Ludwick, Anything Trust aand Paul D. Booth, Trustee
b. (C] This statement is submitted jointly by parties (names):
plainants only)
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-com
a. The complaint was filed on (date):
b. [C] The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
appeared, or have been dismissed.
a. [YJ] All parties named in the complaint and cross-complaint have been served, have
b. (C] The following parties named in the complaint or cross-complaint
(1) (C] have not been served (specify names and explain why not):
(specify names):
(2) (CJ have been served but have not appeared and have not been dismissed
(3) (CQ have had a default entered against them (specify names):
and the date by which
c. () The following additional parties may be added (specify names, nature of involvement in case,
they may be served):
4. Description of case
Type of case in (] complaint (C] cross-complaint (Describe, including causes of action):
a.
trust for breach of contract, breach of
The complaint alleges claims against a trust, its trustee and the benificiary of the
count, intentional interference with contractual relations, intentional
implied covenant of good faith and fair dealing, common
intentional misrepresentation, specific performance and, declaratory relief,
interference with prospective economic advantage,
commission from the sale of a home.
based upon their interference with the payment of a contractually agreed upon Page 1 of 5
Forndopeste Mase Ue Cry essential CASE MANAGEMENT STATEMENT ca amet oo
www.courts.ca.gov
CM-110 (Rev. July 1, 2011] cabeom | f2\Forms
LUDWICK, ERIK
PLAINTIFF/PETITIONER:Pacific Union International, Inc.
CM-110
CASE NUMBER:
SCV0042080
DEFENDANT/RESPONDENT: Erik Ludwick, et al.
Provide a brief statement of the case, including any damages. (If 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
eamings to date, and estimated future lost eamings. If equitable relief is sought, describe the nature
of the relief.)
Plaintiff seeks to recover a contractually agreed upon commission after selling a piece of real estate.
The
coe has been held in an escrow accoun tsince November 2017 due to a dispute regarding the amount owed
to Plaintiff.
(J (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 [YJ a jury trial ~[] a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. (L) The trial has been set for (date):
b. [QZ] 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 yaad dates and explain reasons for unavailability):
3/18 Hrng; 4/19 Hrng; 4/26 Hrng; 5/6 Trial; 5/14 Hrng; 4/30 Hrng; 6/6 - 6/7 Trial; 6/28 Pro-Tem; 9/20 Hrng; 9/17 Hrng; 10/7
- 10/11 Trial; 10/11 Pro-tem; 10/28 Hrng;11/18 Hrng; 12/2 - 12/17 Trial; 1/3/20 Hrng; 1/10/20 Hrng; 1/20/19 Trial
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [Q] days (specify number): 10-15
b. (] hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial LY] by the attorney or party listed in the caption WY] by the following:
a. Attorney: Co-Counsel Lawrence E. Skidmore, Esq.
b. Firm: Aronowitz Skidmore Lyon
c. Address: 200 Auburn Folsom Road, Ste. 305, Auburn, CA 95603
d. Telephone number: 530-823-9736 f. Fax number: 530-823-5241
e. E-mail address: g. Party represented: Defendants, Erik Ludwick, et al.
(_} Additional representation is described in Attachment 8.
9. Preference
(C} 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 [has [CJ] 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 [Jhas [_] has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) (C] This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) (] 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) [This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
Amount requested exceeds limits.
CM-110 [Rev. July1, 2011] CASE MANAGEMENT STATEMENT 2 of §
Page
CEB | Eiforme:
[2° | Essential
LUDWICK, ERIK
CM-110
PLAINTIFF/PETITIONER:Pacific Union International, Inc.
CASE NUMBER:
SCV0042080
DEFENDANT/RESPONDENT: Erik Ludwick, et al.
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have
agreed to participate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing If 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):
(] Mediation session not yet scheduled
(1) Mediation Ww (J Mediation session scheduled for (date):
Cj Agreed to complete mediation by (date):
() Mediation completed on (date):
(_] Settlement conference not yet scheduled
(2) Settlement oO (] Settlement conference scheduled for (date):
eomteinnes CJ Agreed to complete settlement conference by (date):
(_] Settlement conference completed on (date):
(-} Neutral evaluation not yet scheduled
(3) Neutral evaluation oO (-} Neutral evaluation scheduled for (date):
(_] Agreed to complete neutral evaluation by (date):
| Neutral evaluation completed on (date):
(} Judicial arbitration not yet scheduled
(4) Nonbinding judicial Cj (.} Judicial arbitration scheduled for (date):
alain (_] Agreed to complete judicial arbitration by (date):
(_)} Judicial arbitration completed on (date):
(-) Private arbitration not yet scheduled
(5) Binding private CJ (_] Private arbitration scheduled for (date):
arhitration (_] Agreed to complete private arbitration by (date):
() Private arbitration completed on (date):
(_} ADR session not yet scheduled
(6) Other (specify): | (J ADR session scheduled for (date):
(-] Agreed to complete ADR session by (date):
[_] ADR completed on (date):
CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5
CEB’ Essential
ceb.com fe]Forms-
LUDWICK, ERIK
PLAINTIFF/PETITION CM-110
Pacific
ER: Union International, Inc. CASE NUMBER:
SCV0042080
DEFENDANT/RESPONDENT: Erik Ludwick, et al.
11. Insurance
a. (.] Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Cy Yes (CC) No
c CJ 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.
(YJ Bankruptcy Other (specify): Defendants’ motion to transfer venue to the Los Angeles Superior Court
(LASC)
Status: is currently pending before the Court. If the matter is not transferred, a related civil action will be filed
in
LASC by Defendants against Plaintiffs and others.
13. Related cases, consolidation, and coordination
a. () There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
(_] Additional cases are described in Attachment 13a.
b. YY Amotionto (WZ) consolidate [2] coordinate will be filed by (name party):
Defendants in LASC against Plaintiffs.
14. Bifurcation
(} The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
(] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Defendants may file 1) Motion to Transfer basedon Forum Non Conveniens (if necessary);
2) MSJ/MSAI
16. Discovery
a. [W] The party or parties have completed all discovery.
b. (C) The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendants Written discovery Per Code
Defendants Deposition discovery Per Code
Defendants Expert discovery Per Code
c. [L] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-410 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page
4 of §
‘TR ntial
CEB | ESfonme LUDWICK, ERIK
CM-110
PLAINTIFF/PETITIONER: Pacific Union International, Inc. CASE NUMBER:
SCV0042080
DEFENDANT/RESPONDENT: Erik Ludwick, et al.
17. Economic litigation
a. (.) 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. (]) 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): See, 12, 13 and 15
19. Meet and confer
a. [Q] 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)? SSE
| am 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 require
Date: 3/1/2019 fi,
Lawrence E. Skidmore Lh oo CM Cee
(TYPE OR PRINT NAME) Lo (SIGNATURE OF PARTY OR ATTORNEY)
>
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(-] Additional signatures are attached.
1, 2011]
CM-110 [Rev. July CASE MANAGEMENT STATEMENT 5 of 5
Page
‘CR’ | Essential
CEB | fsieorms: LUDWICK, ERIK
— PROOF OF SERVICE
| am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action. My business address is 133 N. Altadena Drive, Suite 403,
Pasadena, CA 91107.
On March 1, 2019, I served the following document(s) described as:
CASE MANAGEMENT STATEMENT
on all interested parties in this action by placing [X]atrue copy [ | the original thereof enclosed
in sealed envelopes addressed as follows:
SEE ATTACHED MAILING LIST
[| (BY FACSIMILE) The facsimile machine I used complied with Rule 2003(3) and no error
10 was reported by the machine. Pursuant to Rule 2008(e)(4), I caused the machine to print a
record of the transmission.
11
(BY MAIL, 1013a, 2015.5 C.C.P.) Lam readily familiar with the firm’s practice for
12 collection and processing correspondence for mailing. Under that practice, this document
will be deposited with the U.S. Postal Service on this date with postage thereon fully prepaid
13 at Los Angeles, California in the ordinary course of business. | am aware that on motion of
the party served, service is presumed invalid if postal cancellation date or postage meter date
14 is more than one day after date of deposit for mailing in affidavit.
15 (BY OVERNIGHT DELIVER Y/COURIER) I served the above referenced document(s)
enclosed in a sealed package, for collection and for delivery marked for next day delivery in
16 the ordinary course of business, addressed to the office of the addressee(s) listed above or on
attached sheet.
17
(BY HAND DELIVERY) I caused to be delivered by hand the foregoing envelope to the
18 offices of the addressee.
19 (BY E-MAIL) I transmitted a copy of the foregoing document(s) via e-mail to the
addressee(s). Courtesy copy
(STATE) I declare under penalty of perjury under the laws of the State of California that the
21 above is true and correct.
22 (FEDERAL) | declare that | am employed in the office of a member of the bar of this Court
at whose direction the service was made.
23
Executed on March 1, 2019, at Pasadena, California.
24
25
ricia M. Poole
]
PROOF OF SERVICE
MAILING LIST
Pacific Union International, Inc. v. Ludwick, et al.
Case No. SCV0042080
Shannon B. Jones, Esq.
Shannon B. Jones Law Group, Inc.
208 W. El Pintado Road
Danville, CA 94526
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PROOF OF SERVICE
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CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY MICHAEL A.J. NANGANO, ESQ. SBN 133999 MICHAEL A.J. NANGANO, A LAW CORPORATION 133 North Altadena Drive, Suite 403 Pasadena, CA 91107 TELEPHONE NO: (626) 796-9998 FAX NO.(Optiona): (213) 232-3252 E-MAIL ADDRESS (Optional): Mnangano@lacounsel.com ATTORNEY FOR (Name): Erik Ludwick, et al. SUPERIOR COURT OF CALIFORNIA, COUNTY OF Placer streetappress: 10820 Justice Center Drive MAILING ADDRESS: ak Chatters Officer & Clerk cityanozipcooe: Roseville, CA 95678 Executive bard, Deputy srancHname: Bill Santucci Justice Center PLAINTIFF/PETITIONER: Pacific Union International, Inc. DEFENDANT/RESPONDENT: Erik Ludwick, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): [Z] UNLIMITED CASE (-) LiMiTED CASE SCV0042080 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Time: 10:00 a.m. Dept.: 40 Div.: Room: Date: March 12, 2019 Address of court (if different from the address above): (] Notice of Intent to Appear by Telephone, by (name): Michael AJ Nangano, Esq. information must be provided. INSTRUCTIONS: All applicable boxes must be checked, and the specified 1. Party or parties (answer one): a. QW] This statement is submitted by party (name): Defendants Erik Ludwick, Anything Trust aand Paul D. Booth, Trustee b. (C] This statement is submitted jointly by parties (names): plainants only) 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-com a. The complaint was filed on (date): b. [C] The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) appeared, or have been dismissed. a. [YJ] All parties named in the complaint and cross-complaint have been served, have b. (C] The following parties named in the complaint or cross-complaint (1) (C] have not been served (specify names and explain why not): (specify names): (2) (CJ have been served but have not appeared and have not been dismissed (3) (CQ have had a default entered against them (specify names): and the date by which c. () The following additional parties may be added (specify names, nature of involvement in case, they may be served): 4. Description of case Type of case in (] complaint (C] cross-complaint (Describe, including causes of action): a. trust for breach of contract, breach of The complaint alleges claims against a trust, its trustee and the benificiary of the count, intentional interference with contractual relations, intentional implied covenant of good faith and fair dealing, common intentional misrepresentation, specific performance and, declaratory relief, interference with prospective economic advantage, commission from the sale of a home. based upon their interference with the payment of a contractually agreed upon Page 1 of 5 Forndopeste Mase Ue Cry essential CASE MANAGEMENT STATEMENT ca amet oo www.courts.ca.gov CM-110 (Rev. July 1, 2011] cabeom | f2\Forms LUDWICK, ERIK PLAINTIFF/PETITIONER:Pacific Union International, Inc. CM-110 CASE NUMBER: SCV0042080 DEFENDANT/RESPONDENT: Erik Ludwick, et al. Provide a brief statement of the case, including any damages. (If 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 eamings to date, and estimated future lost eamings. If equitable relief is sought, describe the nature of the relief.) Plaintiff seeks to recover a contractually agreed upon commission after selling a piece of real estate. The coe has been held in an escrow accoun tsince November 2017 due to a dispute regarding the amount owed to Plaintiff. (J (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 [YJ a jury trial ~[] a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. (L) The trial has been set for (date): b. [QZ] 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 yaad dates and explain reasons for unavailability): 3/18 Hrng; 4/19 Hrng; 4/26 Hrng; 5/6 Trial; 5/14 Hrng; 4/30 Hrng; 6/6 - 6/7 Trial; 6/28 Pro-Tem; 9/20 Hrng; 9/17 Hrng; 10/7 - 10/11 Trial; 10/11 Pro-tem; 10/28 Hrng;11/18 Hrng; 12/2 - 12/17 Trial; 1/3/20 Hrng; 1/10/20 Hrng; 1/20/19 Trial 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [Q] days (specify number): 10-15 b. (] hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial LY] by the attorney or party listed in the caption WY] by the following: a. Attorney: Co-Counsel Lawrence E. Skidmore, Esq. b. Firm: Aronowitz Skidmore Lyon c. Address: 200 Auburn Folsom Road, Ste. 305, Auburn, CA 95603 d. Telephone number: 530-823-9736 f. Fax number: 530-823-5241 e. E-mail address: g. Party represented: Defendants, Erik Ludwick, et al. (_} Additional representation is described in Attachment 8. 9. Preference (C} 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 [has [CJ] 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 [Jhas [_] has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) (C] This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) (] 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) [This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): Amount requested exceeds limits. CM-110 [Rev. July1, 2011] CASE MANAGEMENT STATEMENT 2 of § Page CEB | Eiforme: [2° | Essential LUDWICK, ERIK CM-110 PLAINTIFF/PETITIONER:Pacific Union International, Inc. CASE NUMBER: SCV0042080 DEFENDANT/RESPONDENT: Erik Ludwick, et al. 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing If 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): (] Mediation session not yet scheduled (1) Mediation Ww (J Mediation session scheduled for (date): Cj Agreed to complete mediation by (date): () Mediation completed on (date): (_] Settlement conference not yet scheduled (2) Settlement oO (] Settlement conference scheduled for (date): eomteinnes CJ Agreed to complete settlement conference by (date): (_] Settlement conference completed on (date): (-} Neutral evaluation not yet scheduled (3) Neutral evaluation oO (-} Neutral evaluation scheduled for (date): (_] Agreed to complete neutral evaluation by (date): | Neutral evaluation completed on (date): (} Judicial arbitration not yet scheduled (4) Nonbinding judicial Cj (.} Judicial arbitration scheduled for (date): alain (_] Agreed to complete judicial arbitration by (date): (_)} Judicial arbitration completed on (date): (-) Private arbitration not yet scheduled (5) Binding private CJ (_] Private arbitration scheduled for (date): arhitration (_] Agreed to complete private arbitration by (date): () Private arbitration completed on (date): (_} ADR session not yet scheduled (6) Other (specify): | (J ADR session scheduled for (date): (-] Agreed to complete ADR session by (date): [_] ADR completed on (date): CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5 CEB’ Essential ceb.com fe]Forms- LUDWICK, ERIK PLAINTIFF/PETITION CM-110 Pacific ER: Union International, Inc. CASE NUMBER: SCV0042080 DEFENDANT/RESPONDENT: Erik Ludwick, et al. 11. Insurance a. (.] Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Cy Yes (CC) No c CJ 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. (YJ Bankruptcy Other (specify): Defendants’ motion to transfer venue to the Los Angeles Superior Court (LASC) Status: is currently pending before the Court. If the matter is not transferred, a related civil action will be filed in LASC by Defendants against Plaintiffs and others. 13. Related cases, consolidation, and coordination a. () There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: (_] Additional cases are described in Attachment 13a. b. YY Amotionto (WZ) consolidate [2] coordinate will be filed by (name party): Defendants in LASC against Plaintiffs. 14. Bifurcation (} The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions (] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Defendants may file 1) Motion to Transfer basedon Forum Non Conveniens (if necessary); 2) MSJ/MSAI 16. Discovery a. [W] The party or parties have completed all discovery. b. (C) The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendants Written discovery Per Code Defendants Deposition discovery Per Code Defendants Expert discovery Per Code c. [L] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-410 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of § ‘TR ntial CEB | ESfonme LUDWICK, ERIK CM-110 PLAINTIFF/PETITIONER: Pacific Union International, Inc. CASE NUMBER: SCV0042080 DEFENDANT/RESPONDENT: Erik Ludwick, et al. 17. Economic litigation a. (.) 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. (]) 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): See, 12, 13 and 15 19. Meet and confer a. [Q] 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)? SSE | am 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 require Date: 3/1/2019 fi, Lawrence E. Skidmore Lh oo CM Cee (TYPE OR PRINT NAME) Lo (SIGNATURE OF PARTY OR ATTORNEY) > (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (-] Additional signatures are attached. 1, 2011] CM-110 [Rev. July CASE MANAGEMENT STATEMENT 5 of 5 Page ‘CR’ | Essential CEB | fsieorms: LUDWICK, ERIK — PROOF OF SERVICE | am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action. My business address is 133 N. Altadena Drive, Suite 403, Pasadena, CA 91107. On March 1, 2019, I served the following document(s) described as: CASE MANAGEMENT STATEMENT on all interested parties in this action by placing [X]atrue copy [ | the original thereof enclosed in sealed envelopes addressed as follows: SEE ATTACHED MAILING LIST [| (BY FACSIMILE) The facsimile machine I used complied with Rule 2003(3) and no error 10 was reported by the machine. Pursuant to Rule 2008(e)(4), I caused the machine to print a record of the transmission. 11 (BY MAIL, 1013a, 2015.5 C.C.P.) Lam readily familiar with the firm’s practice for 12 collection and processing correspondence for mailing. Under that practice, this document will be deposited with the U.S. Postal Service on this date with postage thereon fully prepaid 13 at Los Angeles, California in the ordinary course of business. | am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date 14 is more than one day after date of deposit for mailing in affidavit. 15 (BY OVERNIGHT DELIVER Y/COURIER) I served the above referenced document(s) enclosed in a sealed package, for collection and for delivery marked for next day delivery in 16 the ordinary course of business, addressed to the office of the addressee(s) listed above or on attached sheet. 17 (BY HAND DELIVERY) I caused to be delivered by hand the foregoing envelope to the 18 offices of the addressee. 19 (BY E-MAIL) I transmitted a copy of the foregoing document(s) via e-mail to the addressee(s). Courtesy copy (STATE) I declare under penalty of perjury under the laws of the State of California that the 21 above is true and correct. 22 (FEDERAL) | declare that | am employed in the office of a member of the bar of this Court at whose direction the service was made. 23 Executed on March 1, 2019, at Pasadena, California. 24 25 ricia M. Poole ] PROOF OF SERVICE MAILING LIST Pacific Union International, Inc. v. Ludwick, et al. Case No. SCV0042080 Shannon B. Jones, Esq. Shannon B. Jones Law Group, Inc. 208 W. El Pintado Road Danville, CA 94526 10 11 Ie 13 14 15 16 17 18 Lo 20 21 22 z23 24 25 26 27 28 2 PROOF OF SERVICE