Preview
amen im,
4 CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Shannon B. Jones (#149222) / Lindsey A. Morgan (#274214)
Shannon B. Jones Law Group, Inc.
208 W. El Pintado Road
Danville, CA 94526
TELEPHONE NO.: (925) 837-2317 FAX NO. (Optional): (925) 837-483 1
EMAIL ADDRESS (Optional): shj@sbj-law.com; lam@sbj-law.com F I L E D
ATTORNEY FOR (Name): Plaintiff Pacific Union International, Inc. superior Court of California
SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER San et Piecer
sTREET ADDRESS: 10820 Justice Center Drive
MAILING ADDRESS:
CITY AND ZIP CODE: Roseville, CA 95678
BRANCH NAME: Bill Santucci Justice Center
PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC.
DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE [__] LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less) SCV0042080
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: March 12, 2019 Time: 10:00 a.m. Dept.: 40 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Lindsey A. Morgan, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. This statement is submitted by party (name): Plaintiff Pacific Union International, Inc.
b. [__] This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): November 7, 2018
b. [__] The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [__] The following parties named in the complaint or cross-complaint
(1) [__] have not been served (specify names and explain why not):
(2) [__] have been served but have not appeared and have not been dismissed (specify names):
(3) [-_] have had a default entered against them (specify names):
c. L_] The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of case in complaint LC cross-complaint (Describe, including causes of action):
The Complaint alleges claims against a trust, its trustee, and the beneficiary of the trust for breach of contract, breach of implied covenant of goo
aith and fair dealing, common count, intentional interference with contractual relations, intentional interference with prospective economic
idvantage, intentional misrepresentation, specific performance, and declaratory relief, based upon their interference with the payment of a
rontractually agreed upon commission from the sale of a home. Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720-3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
LexisNexis® Automated California Judicial Council Forms
een —_
CM-110
PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. CASS NUMBER
DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. SCV0042080
4. b. 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 of $978,000, plus interest, after selling a
piece of real estate. The commission has sat in an escrow account since November 2017 because the
Trustee, at the direction of the beneficiary, instructed escrow to hold that amount because of a commission
dispute. The contractual documents are clear about the amount owed to Plaintiff.
[__] (lfmore space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request ajurytrial [la nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a. [__] The trial has been set for (date):
b. 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 (specify dates and explain reasons for unavailability):
See Attachment 1
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 5-7
b. [_] hours (short causes) (specify):
. Trial representation (fo be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption [__] by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
[__] Additional representation is described in Attachment 8.
Preference
[_] 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 L_] 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 L] has [-_] has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) [__] This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under 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 Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
Amount requested exceeds limits.
CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page
2 of 5
LexisNexis® Automated California Judicial Council Forms
li, as.
CM-110
| b PAINTIFFIPETITIONER: PACIFIC UNION INTERNATIONAL, INC. [= o*8=R
E
FENDANTIRESPONDENT: ERIK LUDWICK, an individual, et al. SCV0042080
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 app ly 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
U
Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
HOUUU;OUUU;UUUU;OUUUU;OUUU;OU
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
arbitration
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
LexisNexis® Automated California Judicial Council Forms
-_ a
PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. CASE NUMBER:
DEFENDANTIRESPONDENT: ERIK LUDWICK, an individual, et al. SE VOES2080
11. Insurance
a. [_] Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: [_] Yes [-_] No
ce L_] 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.
[__] Bankruptcy L_] Other (specify):
Status:
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. [__]Amotionto [__] consolidate [_] coordinate will be filed by (name party):
14. Bifurcation
L_] 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):
Plaintiff anticipates filling a dispositive motion after conducting appropriate discovery..
16. Discovery
a. [__] The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Pacific Union International Written discovery Per Code
Pacific Union International Deposition discovery Per Code
Pacific Union International Expert discovery Per Code
c. [__] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
efRea i, 260 CASE MANAGEMENT STATEMENT ragetens
LexisNexis® Automated California Judicial Council Forms
lana a,
CM-110
PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. See NUMBER:
DEFENDANTIRESPONDENT: ERIK LUDWICK, an individual, et al. PC-VOO42080
17. Economic litigation
a. |__] This isis a limited civil case
1 (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. L__] 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):
19. Meet and confer
a. 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): 1
| 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 stipulatians on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: February 20, 2019
LINDSEY A. MORGAN » fy,
(TYPE OR PRINT NAME) (SI@NAWGRE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATUREOF PABTY OR ATTORNEY)
[___] Additional signatures are attached.
CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page
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LexisNexis® Automated California Judicial Council Forms
Attachments
Attachment 1
2/21/19-2/22/19 Vacation; 2/26/19 MSC; 2/28/19-3/1/19 Vacation; 3/6/19 Mediation;
3/7/19 Mediation; 3/13/19 Seminar; 3/13/19 Mediation; 3/14/19 Mediation;
3/18/19-3/29/19 Trial; 3/20/19 Seminar; 3/26/19 Mediation; 3/27/19 Mediation; 4/2/19
Seminar; 4/4/19-4/5/19 Vacation; 4/8/19-4/19/19 Trial; 4/10/19 Hearing; 4/11/19
Mediation; 4/16/19 Mediation; 4/18/19 Mediation; 4/24/19-4/26/19 Vacation; 5/1/19 to
5/4/19 Meetings; 5/6/19-5/17/19 Trial; 5/8/13 Settlement Conference; 5/13/19 Settlement
Conference; 5/22/19 Seminar; 5/28/19-6/7/19 Trial; 5/31/19 Settlement Conference;
6/10/19 Vacation; 6/10/19 to 6/24/19 Trial; 6/12/19 Seminar; 6/17/19 — 6/28/19 Trial;
6/19/19 Seminar; 6/20/19 Settlement Conference; 6/24/19 -7/9/19 Trial; 7/8/19-7/19/19
Trial; 7/10/19 Settlement Conference; 7/22/19 Settlement Conference; 7/22-8/2/19 Trial;
8/2/19 Trial Conference; 8/5/19-8/16/19 Trial; 8/13-16/19 Arbitration; 8/21/19 Issue
Conference: 8/21/19 Settlement Conference; 9/3/19-9/17/19 Trial; 9/11/19 Seminar;
9/18/19 Seminar; 9/19/19 Settlement Conference; 9/20/19 -10/4/19 Trial; 9/25/19 to
9/28/19 Meetings; 9/27/19 Trial Conference; 9/30/19-10/11/19 Trial; 10/7/19-10/18/19;
10/8/19 Settlement Conference; 10/16/19 Seminar; 10/16/19 Settlement Conference:
10/21/19 Seminar; 10/17/19-11/1/19 Trial; 11/4/19-11/15/19 Trial; 11/8/19 Conference;
11/15/19 to 11/27/19 Trial; 12/11/19 Seminar; 12/16/19 MSC; 12/20/19 -1/13/20 Vacation;
1/14/20 Pre-Trial Conference; 1/20/20 -1/31/20 Trial; 1/23/20 Trial Conference; 1/27/20
Trial; 2/11/20-2/21/20 Trial; 3/2/20-3/13/20 Trial; 3/16/20 Conference; 3/27/20
Conference; 4/1/20-4/24/20 Trial.
PROOF OF SERVICE
I, the undersigned, declare:
I am a resident of the State of California and over the age of eighteen years, and
not a party to the within action; my business address is 208 W. El Pintado Road, Danville, CA
94526. On February 20, 2019, I served the within document(s):
CASE MANAGEMENT STATEMENT
ND
X___ by placing the document(s) listed above in a sealed envelope with postage thereon fully
prepaid, in the United States mail at Danville, California addressed as set forth below.
Oo
oS
Attorneys for Defendants Erik Ludwick, The
Anything Trust and Paul Booth as Trustee of
10
the Anything Trust
11 Michael A.J. Nangano, Esq.
Michael A.J. Nangano, A Law Corporation
12 133 North Altadena Drive, Suite 403
Pasadena, CA 91107
13 Tel: (626) 796-9998
Fax: (213) 232-3252
14 mnangano(@lacounsel.com
15
I declare under penalty of perjury under the laws of the State of California that the
16 above is true and correct.
17 Executed on February 20, 2019, at Danville, California.
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P Aye
P. BULL
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amen im, 4 CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Shannon B. Jones (#149222) / Lindsey A. Morgan (#274214) Shannon B. Jones Law Group, Inc. 208 W. El Pintado Road Danville, CA 94526 TELEPHONE NO.: (925) 837-2317 FAX NO. (Optional): (925) 837-483 1 EMAIL ADDRESS (Optional): shj@sbj-law.com; lam@sbj-law.com F I L E D ATTORNEY FOR (Name): Plaintiff Pacific Union International, Inc. superior Court of California SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER San et Piecer sTREET ADDRESS: 10820 Justice Center Drive MAILING ADDRESS: CITY AND ZIP CODE: Roseville, CA 95678 BRANCH NAME: Bill Santucci Justice Center PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE [__] LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) SCV0042080 A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: March 12, 2019 Time: 10:00 a.m. Dept.: 40 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Lindsey A. Morgan, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): Plaintiff Pacific Union International, Inc. b. [__] This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): November 7, 2018 b. [__] The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [__] The following parties named in the complaint or cross-complaint (1) [__] have not been served (specify names and explain why not): (2) [__] have been served but have not appeared and have not been dismissed (specify names): (3) [-_] have had a default entered against them (specify names): c. L_] The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type of case in complaint LC cross-complaint (Describe, including causes of action): The Complaint alleges claims against a trust, its trustee, and the beneficiary of the trust for breach of contract, breach of implied covenant of goo aith and fair dealing, common count, intentional interference with contractual relations, intentional interference with prospective economic idvantage, intentional misrepresentation, specific performance, and declaratory relief, based upon their interference with the payment of a rontractually agreed upon commission from the sale of a home. Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720-3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov LexisNexis® Automated California Judicial Council Forms een —_ CM-110 PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. CASS NUMBER DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. SCV0042080 4. b. 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 of $978,000, plus interest, after selling a piece of real estate. The commission has sat in an escrow account since November 2017 because the Trustee, at the direction of the beneficiary, instructed escrow to hold that amount because of a commission dispute. The contractual documents are clear about the amount owed to Plaintiff. [__] (lfmore space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request ajurytrial [la nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a. [__] The trial has been set for (date): b. 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 (specify dates and explain reasons for unavailability): See Attachment 1 Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 5-7 b. [_] hours (short causes) (specify): . Trial representation (fo be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption [__] by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: [__] Additional representation is described in Attachment 8. Preference [_] 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 L_] 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 L] has [-_] has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) [__] This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under 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 Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): Amount requested exceeds limits. CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 of 5 LexisNexis® Automated California Judicial Council Forms li, as. CM-110 | b PAINTIFFIPETITIONER: PACIFIC UNION INTERNATIONAL, INC. [= o*8=R E FENDANTIRESPONDENT: ERIK LUDWICK, an individual, et al. SCV0042080 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 app ly 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 U Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): HOUUU;OUUU;UUUU;OUUUU;OUUU;OU Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT LexisNexis® Automated California Judicial Council Forms -_ a PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. CASE NUMBER: DEFENDANTIRESPONDENT: ERIK LUDWICK, an individual, et al. SE VOES2080 11. Insurance a. [_] Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: [_] Yes [-_] No ce L_] 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. [__] Bankruptcy L_] Other (specify): Status: 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. [__]Amotionto [__] consolidate [_] coordinate will be filed by (name party): 14. Bifurcation L_] 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): Plaintiff anticipates filling a dispositive motion after conducting appropriate discovery.. 16. Discovery a. [__] The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Pacific Union International Written discovery Per Code Pacific Union International Deposition discovery Per Code Pacific Union International Expert discovery Per Code c. [__] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): efRea i, 260 CASE MANAGEMENT STATEMENT ragetens LexisNexis® Automated California Judicial Council Forms lana a, CM-110 PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. See NUMBER: DEFENDANTIRESPONDENT: ERIK LUDWICK, an individual, et al. PC-VOO42080 17. Economic litigation a. |__] This isis a limited civil case 1 (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. L__] 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): 19. Meet and confer a. 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): 1 | 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 stipulatians on these issues at the time of the case management conference, including the written authority of the party where required. Date: February 20, 2019 LINDSEY A. MORGAN » fy, (TYPE OR PRINT NAME) (SI@NAWGRE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATUREOF PABTY OR ATTORNEY) [___] Additional signatures are attached. CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5 LexisNexis® Automated California Judicial Council Forms Attachments Attachment 1 2/21/19-2/22/19 Vacation; 2/26/19 MSC; 2/28/19-3/1/19 Vacation; 3/6/19 Mediation; 3/7/19 Mediation; 3/13/19 Seminar; 3/13/19 Mediation; 3/14/19 Mediation; 3/18/19-3/29/19 Trial; 3/20/19 Seminar; 3/26/19 Mediation; 3/27/19 Mediation; 4/2/19 Seminar; 4/4/19-4/5/19 Vacation; 4/8/19-4/19/19 Trial; 4/10/19 Hearing; 4/11/19 Mediation; 4/16/19 Mediation; 4/18/19 Mediation; 4/24/19-4/26/19 Vacation; 5/1/19 to 5/4/19 Meetings; 5/6/19-5/17/19 Trial; 5/8/13 Settlement Conference; 5/13/19 Settlement Conference; 5/22/19 Seminar; 5/28/19-6/7/19 Trial; 5/31/19 Settlement Conference; 6/10/19 Vacation; 6/10/19 to 6/24/19 Trial; 6/12/19 Seminar; 6/17/19 — 6/28/19 Trial; 6/19/19 Seminar; 6/20/19 Settlement Conference; 6/24/19 -7/9/19 Trial; 7/8/19-7/19/19 Trial; 7/10/19 Settlement Conference; 7/22/19 Settlement Conference; 7/22-8/2/19 Trial; 8/2/19 Trial Conference; 8/5/19-8/16/19 Trial; 8/13-16/19 Arbitration; 8/21/19 Issue Conference: 8/21/19 Settlement Conference; 9/3/19-9/17/19 Trial; 9/11/19 Seminar; 9/18/19 Seminar; 9/19/19 Settlement Conference; 9/20/19 -10/4/19 Trial; 9/25/19 to 9/28/19 Meetings; 9/27/19 Trial Conference; 9/30/19-10/11/19 Trial; 10/7/19-10/18/19; 10/8/19 Settlement Conference; 10/16/19 Seminar; 10/16/19 Settlement Conference: 10/21/19 Seminar; 10/17/19-11/1/19 Trial; 11/4/19-11/15/19 Trial; 11/8/19 Conference; 11/15/19 to 11/27/19 Trial; 12/11/19 Seminar; 12/16/19 MSC; 12/20/19 -1/13/20 Vacation; 1/14/20 Pre-Trial Conference; 1/20/20 -1/31/20 Trial; 1/23/20 Trial Conference; 1/27/20 Trial; 2/11/20-2/21/20 Trial; 3/2/20-3/13/20 Trial; 3/16/20 Conference; 3/27/20 Conference; 4/1/20-4/24/20 Trial. PROOF OF SERVICE I, the undersigned, declare: I am a resident of the State of California and over the age of eighteen years, and not a party to the within action; my business address is 208 W. El Pintado Road, Danville, CA 94526. On February 20, 2019, I served the within document(s): CASE MANAGEMENT STATEMENT ND X___ by placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid, in the United States mail at Danville, California addressed as set forth below. Oo oS Attorneys for Defendants Erik Ludwick, The Anything Trust and Paul Booth as Trustee of 10 the Anything Trust 11 Michael A.J. Nangano, Esq. Michael A.J. Nangano, A Law Corporation 12 133 North Altadena Drive, Suite 403 Pasadena, CA 91107 13 Tel: (626) 796-9998 Fax: (213) 232-3252 14 mnangano(@lacounsel.com 15 I declare under penalty of perjury under the laws of the State of California that the 16 above is true and correct. 17 Executed on February 20, 2019, at Danville, California. 18 19 P Aye P. BULL 20 21 22 23 24 25 26 27 28