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Lawrence E. Skidmore (SBN 137587)
ARONOWITZ SKIDMORE LYON
Arp ek eg a ola CORPORATION
pO
Auburn Folsom Road, Suite 305 i=
Auburn, CA 95603
WD
Superior TL. ED.
ee County of Placer
acsimile: -823-5241
BP
JUN 13 2019
MICHAEL A.J. NANGANO (SBN 133999)
WNW
MICHAEL AJ NANGANO, A LAW CORPORATION
9
DEFENDANTS’ SEPARATE STATEMENT in SUPPORT OF MOTION TO COMPEL
FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE
ground that this interrogatory is unintelligible as phrased. Accordingly, Responding Party is unable
—
to respond to this interrogatory.
NYO
REASON WHY FURTHER RESPONSE IS NEEDED:
WY
California Civil Code §2079.16 requires that while acting in a “dual agent” capacity,
FP
Responding Party and its affiliated agents (including, in particular, PARTNERS TRUST and
On
MADISON HILDEBRAND) had a fiduciary duty of the highest level to LUDWICK.
Dn
Notwithstanding
this fiduciary duty, and in breach thereof, HILDEBRAND proceeded to engage in a series of actions
oN
which were designed to ENRICH HILDEBRAND personally at the expense of LUDWICK - in an
amount totaling hundreds of thousands of dollars. LUDWICK is entitled to know if, when and to
oOo
whom Responding Party fulfilled its dual agency disclosure obligations.
OO
This Interrogatory requests that Responding Party “ identify who was present” at any time
KY
eee
when any employee, real estate agent and/or broker for Responding Party provided LUDWICK with
YB
any document regarding the dual agency of the participating brokers and agents in the sale of the
WwW
REAL PROPERTY. Responding Party has failed to provide any response
FB
identifying who was
present when the documents were delivered.
WH
Further, neither Responding Party’s objections that this interrogatory seeks or assumes facts
DH
not in evidence nor its objection that “this interrogatory ... seeks confidential information of non-
NI
parties to this lawsuit” is accurate and/or applicable.
Oo
Rm
O
DOD
SPECIAL INTERROGATORY NO. 33:
Please FULLY IDENTIFY by the address of the REAL PROPERTY involved, and the name
KH
NR
and address of all participating parties for each and every time that YOU, asa
NY
licensed broker and/or
NR
real estate agent, acted in dual agency in the sale of any real property at any time during the past 2
Ww
RD
years.
ee
NY
//
YN
NYY
H/
DN
KN
RESPONSE TO SPECIAL INTERROGATORY NO. 33:
NY
oN
No
10
DEFENDANTS’ SEPARATE STATEMENT in SUPPORT OF MOTION TO COMPEL
FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE
Responding Party objects to this interrogatory on the grounds that it is overbroad, vague and
ambiguous and seeks information that is not relevant and not likely to lead to the discovery of
NY
admissible evidence. Responding Party further objects to this interrogatory on the grounds that is
WY
assumes facts not in evidence. Responding Party objects to this interrogatory on the grounds that
FSF
it seeks facts not in evidence. Responding Party objects to this interrogatory on the grounds it seeks
WH
confidential information of non-parties to this lawsuit. Responding Party further objects on the
HD
ground that this interrogatory is unintelligible as phrased. Accordingly, Responding Party is unable
NY
to respond to this interrogatory.
eo
Subject to and without waiving those privacy objections, Responding Party responds as
oOo
10 follows: Responding Party frequently acts as a dual agency in the sale of real property, and has
ll conducted four (4) dual agency transactions since 2017. Responding Party declines to provide the
12 information and physical addresses of non-party clients. Responding Party represented Propounding
13 Party in a dual Agency offer for the listing at 6237 Bonsall Canyon in Malibu, but that transaction
14 did not conclude.
15
16 REASON WHY FURTHER RESPONSE IS NEEDED:
17 California Civil Code §2079.16 requires that while acting in a “dual agent” capacity,
18 Responding Party and its affiliated agents (including, in particular, PARTNERS TRUST and
19 MADISON HILDEBRAND) had a fiduciary duty of the highest level to LUDWICK. Notwithstanding
20 this fiduciary duty, and in breach thereof, HILDEBRAND proceeded to engage in a series of actions
21 which were designed to enrich HILDEBRAND personally at the expense of LUDWICK - in an
22 amount totaling hundreds of thousands of dollars. LUDWICK is entitled to know if, when and to
23 whom Responding Party fulfilled its dual agency disclosure obligations.
24 This Interrogatory requests that Responding Party identify other dual agency transactions in
25 which Responding Party has participated in the past two years. Responding Party references four
26 (4) suchtransactions but fails to provide the requested detail with respect to any of them.
27 LUDWICK is informed and believes that Responding Party (including, in particular, PARTNERS
28
1]
DEFENDANTS’ SEPARATE STATEMENT in SUPPORT OF MOTION TO COMPEL
FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE
TRUST and MADISON HILDEBRAND) have a pattern and practice of ignoring their fiduciary duties
when acting ina “dual agent” capacity. LUDWICK is entitled to discovery with respect to any such
WN
“pattern and practice.”
WY
Further, neither Responding Party’s objections that this interrogatory seeks or assumes facts
Fe.
not in evidence nor its objection that “this interrogatory ... seeks confidential information of non-
YH
parties to this lawsuit” is accurate and/or applicable.
Dn
ON
SPECIAL INTERROGATORY NO. 60:
If YOU contend that the reasonable value of services provided by the real estate broker to the
oo
10 SELLER was Nine Hundred Seventy-Eight Thousand Dollars ($978,000.00), please state all
11 FACTS on which YOU base that contention.
12 RESPONSE TO SPECIAL INTERROGATORY NO. 60:
13 Responding Party objects to this interrogatory on the grounds that it is overbroad, vague and
14 ambiguous and seeks information that is not relevant and not likely to lead to the discovery of
15 admissible evidence. Responding Party further objects to this interrogatory on the grounds that it
16 assumes facts not in evidence.
17 Subject to and without waiving the foregoing objections, Responding Party responds as
18 follows: The contractually agreed value of value of services provided by the real estate broker -
19 whether or not that is the “reasonable value,” whatever that undefined phrase means- is Nine
20 Hundred Seventy-Eight Thousand Dollars ($978,000.00).
21 REASON WHY FURTHER RESPONSE IS NEEDED:
22 This Interrogatory simply requests that Responding Party identify the facts upon which it
23 bases the contention in its Complaint that the reasonable value of the services Responding Party
24 provided to SELLER with respect to the sale of the Toyopa Property was Nine Hundred Seventy-
25 Eight Thousand Dollars ($978,000.00). Responding Party has failed to do so, even after Moving
26 Party clarified, in the meet and confer process, the definition of the term “reasonable value” was its
27 common English usage.
28
12
DEFENDANTS’ SEPARATE STATEMENT in SUPPORT OF MOTION TO COMPEL
FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE
SPECIAL INTERROGATORY NO. 61:
If YOU contend that the reasonable value of services provided by the real estate broker to
bo
the SELLER was Nine Hundred Seventy-Eight Thousand Dollars ($978,000.00), please fully
IDENTIFY all WITNESSES to the facts on which YOU base that contention.
RESPONSE TO SPECIAL INTERROGATORY NO. 61:
oa)
6 Responding Party objects to this interrogatory on the grounds that it is overbroad, vague and
ambiguous and seeks information that is not relevant and not likely to lead to the discovery of
admissible evidence. Responding Party further objects to this interrogatory on the grounds that it
is compound and assumes facts not in evidence.
Subject to and without waiving the foregoing objections, Responding Party responds as
follows: The contractually agreed value of value of services provided by the real estate broker -
whether or not that is the “reasonable value.” whatever that undefined phrase means- is Nine
Hundred Seventy-Eight Thousand Dollars ($978,000.00). Responding party declines to respond
with witnesses that support a contention it did not make.
REASON WHY FURTHER RESPONSE IS NEEDED:
16 This Interrogatory simply requests that Responding Party identify all witnesses to the facts
upon which it bases the contention in its Complaint that the reasonable value of the services
Responding Party provided with respect to the sale of the by the real estate broker to the SELLER
was Nine Hundred Seventy-Eight Thousand Dollars ($978.000.00). Responding Party has failed
to do so, even after Moving Party clarified in the meet and confer process the definition of the term
“reasonable value” was its common English language.
Respectfully submitted,
DATED: June| > . 2019 MICHAEL A.J. NANGANO, A LAW CORPORATION
BY:
MICHAEL A.J. NANGANO
Attorneys for Defendants .
Facsimile signature as original
Pur RE: 4305(d)
3
DEFENDANTS’ SEPARATE STATEMENT in SUPPORT OF MOTION TO COMPEL
FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE
MICHAEL A.J. NANGANO (SBN 133999)
=
MICHAEL AJ NANGANO, A LAW CORPORATION
133 No. Altadena Drive, Suite 403
HO
Pasadena, CA 91107
Phone: (626) 796-9998
WY
Fax: (626) 796-9992
ee
Attorneys for Defendant(s)
OH
DO
ON
SUPERIOR COURT OF THE STATE OF CALIFORNIA
co
IN AND FOR THE COUNTY OF PLACER
ee
OS
mm
SY
leo UNION INTERNATIONAL, Case No. S-CV 0042080
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mre
HY
ee
WD
See
Plaintiff, [PROPOSED] ORDER REGARDING
Se
DEFENDANTS’ MOTION TO COMPEL
Se
ee
VS. FURTHER RESPONSE TO SPECIAL
ee
INTERROGATORIES, SET ONE
HN
Se
ERIK LUDWICK, an individual AND
i
Settlor of The Anything Trust dated October
DKON
Date: July 11, 2019
ne
12, 2007; THE ANYTHING TRUST Time: 8:30 a.m.
a
DATED OCTOBER 12, 2007; PAUL D. Dept.: 42
a
BOOTH, in his capacity as Trustee of The
OY
ie
Anything Trust Dated October 12, 2007; and
a
Does 1 through 50, inclusive,
ae
RO
ee
OO
ae
Defendants.
RO
a
a
Trial Date: None Set
DN
ee
NK
Name
NO
The motion by Defendants for an order compelling further response to Special Interrogatories
WwW
NO
came on regularly for hearing, on July 11, 2019, at 8:30 a.m., in this Department. Lawrence E.
Be
NO
Skidmore, Esq. appeared in court and Michael A.J. Nangano, Esq. appeared telephonically for
NW
NO
moving party. ,Esq. from the Law Office of Shannon B. Jones appeared in
ONO
NO
opposition for Plaintiff.
nN
NO
1
Co
NO
[PROPOSED] ORDER REGARDING DEFENDANTS’ MOTION TO COMPEL FURTHER
RESPONSE TO SPECIAL INTERROGATORIES, SET ONE
After considering the papers submitted in support of the motion and those in opposition to
it, as well as oral argument made to the Court, this Court finds as follows:
NY
Plaintiffs motion is granted. This Court finds that there is good cause for an order by this
WY
Court compelling defendant to provide further responses to Special Interrogatories, (Set No. 1)
FSF
without objection. Defendant is ordered to answer fully the following items: 8, 26, 28, 29, 31, 32,
WH
32, 33, 60, 61.
Dn
Defendant is ordered to provide the further responses within 20 days of this order.
NY
Oo
IT IS SO ORDERED
oO
10 DATED: July _, 2019
1] Judge of the Superior Court
12
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15
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17
18
19
20
|
22
23
24
2
26
27
28 2
[PROPOSED] ORDER REGARDING DEFENDANTS’ MOTION TO COMPEL FURTHER
RESPONSE TO SPECIAL INTERROGATORIES, SET ONE
PROOF OF SERVICE
be
| 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 June 13, 2019, I served the following document(s) described as:
DEFENDANTS* MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL
INTERROGATORIES, SET ONE, SEPARATE STATEMENT IN SUPPORT THEREOF
and PROPOSED ORDER
on all interested parties in this action by placing [X] a true 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
was reported by the machine. Pursuant to Rule 2008(e)(4), I caused the machine to print a
record of the transmission.
(BY MAIL, 1013a, 2015.5 C.C.P.) Lam readily familiar with the firm’s practice for
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
at Los Angeles, California in the ordinary course of business. I am aware that on motion of
the party served, service is presumed invalid if postal cancellation date or postage meter date
is more than one day after date of deposit for mailing in affidavit.
(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
the ordinary course of business. addressed to the office of the addressee(s) listed above or on
attached sheet.
(BY E-MAIL) | transmitted a copy of the foregoing document(s) via e-mail to the
addressee(s). Courtesy copy
[Xx] (STATE) I declare under penalty of perjury under the laws of the State of California that the
above is true and correct.
Executed on June 13, 2019, at Pasadena. California.
Patricia M. Poole
Facsimile Signature as
original
Pursuant to C.R.C. Rul
e 2.305¢1)
PROOP OF SERVICE
MAILING LIST
Pacific Union International, Inc. v. Ludwick, et al.
NN
Case No. SCV0042080
Ww
Shannon B. Jones, Esq.
r=
Lindsey Morgan, Esq.
Shannon B. Jones Law Group, Inc.
wT
208 W. El Pintado Road
HD
Danville, CA 94526
SY
OO
©
mo
12
13
14
1
16
17
18
19
20
21
22
23
24
25
26
27
28
2
PROOF OF SERVICE
Preview
& Lawrence E. Skidmore (SBN 137587) ARONOWITZ SKIDMORE LYON Arp ek eg a ola CORPORATION pO Auburn Folsom Road, Suite 305 i= Auburn, CA 95603 WD Superior TL. ED. ee County of Placer acsimile: -823-5241 BP JUN 13 2019 MICHAEL A.J. NANGANO (SBN 133999) WNW MICHAEL AJ NANGANO, A LAW CORPORATION 9 DEFENDANTS’ SEPARATE STATEMENT in SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE ground that this interrogatory is unintelligible as phrased. Accordingly, Responding Party is unable — to respond to this interrogatory. NYO REASON WHY FURTHER RESPONSE IS NEEDED: WY California Civil Code §2079.16 requires that while acting in a “dual agent” capacity, FP Responding Party and its affiliated agents (including, in particular, PARTNERS TRUST and On MADISON HILDEBRAND) had a fiduciary duty of the highest level to LUDWICK. Dn Notwithstanding this fiduciary duty, and in breach thereof, HILDEBRAND proceeded to engage in a series of actions oN which were designed to ENRICH HILDEBRAND personally at the expense of LUDWICK - in an amount totaling hundreds of thousands of dollars. LUDWICK is entitled to know if, when and to oOo whom Responding Party fulfilled its dual agency disclosure obligations. OO This Interrogatory requests that Responding Party “ identify who was present” at any time KY eee when any employee, real estate agent and/or broker for Responding Party provided LUDWICK with YB any document regarding the dual agency of the participating brokers and agents in the sale of the WwW REAL PROPERTY. Responding Party has failed to provide any response FB identifying who was present when the documents were delivered. WH Further, neither Responding Party’s objections that this interrogatory seeks or assumes facts DH not in evidence nor its objection that “this interrogatory ... seeks confidential information of non- NI parties to this lawsuit” is accurate and/or applicable. Oo Rm O DOD SPECIAL INTERROGATORY NO. 33: Please FULLY IDENTIFY by the address of the REAL PROPERTY involved, and the name KH NR and address of all participating parties for each and every time that YOU, asa NY licensed broker and/or NR real estate agent, acted in dual agency in the sale of any real property at any time during the past 2 Ww RD years. ee NY // YN NYY H/ DN KN RESPONSE TO SPECIAL INTERROGATORY NO. 33: NY oN No 10 DEFENDANTS’ SEPARATE STATEMENT in SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE Responding Party objects to this interrogatory on the grounds that it is overbroad, vague and ambiguous and seeks information that is not relevant and not likely to lead to the discovery of NY admissible evidence. Responding Party further objects to this interrogatory on the grounds that is WY assumes facts not in evidence. Responding Party objects to this interrogatory on the grounds that FSF it seeks facts not in evidence. Responding Party objects to this interrogatory on the grounds it seeks WH confidential information of non-parties to this lawsuit. Responding Party further objects on the HD ground that this interrogatory is unintelligible as phrased. Accordingly, Responding Party is unable NY to respond to this interrogatory. eo Subject to and without waiving those privacy objections, Responding Party responds as oOo 10 follows: Responding Party frequently acts as a dual agency in the sale of real property, and has ll conducted four (4) dual agency transactions since 2017. Responding Party declines to provide the 12 information and physical addresses of non-party clients. Responding Party represented Propounding 13 Party in a dual Agency offer for the listing at 6237 Bonsall Canyon in Malibu, but that transaction 14 did not conclude. 15 16 REASON WHY FURTHER RESPONSE IS NEEDED: 17 California Civil Code §2079.16 requires that while acting in a “dual agent” capacity, 18 Responding Party and its affiliated agents (including, in particular, PARTNERS TRUST and 19 MADISON HILDEBRAND) had a fiduciary duty of the highest level to LUDWICK. Notwithstanding 20 this fiduciary duty, and in breach thereof, HILDEBRAND proceeded to engage in a series of actions 21 which were designed to enrich HILDEBRAND personally at the expense of LUDWICK - in an 22 amount totaling hundreds of thousands of dollars. LUDWICK is entitled to know if, when and to 23 whom Responding Party fulfilled its dual agency disclosure obligations. 24 This Interrogatory requests that Responding Party identify other dual agency transactions in 25 which Responding Party has participated in the past two years. Responding Party references four 26 (4) suchtransactions but fails to provide the requested detail with respect to any of them. 27 LUDWICK is informed and believes that Responding Party (including, in particular, PARTNERS 28 1] DEFENDANTS’ SEPARATE STATEMENT in SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE TRUST and MADISON HILDEBRAND) have a pattern and practice of ignoring their fiduciary duties when acting ina “dual agent” capacity. LUDWICK is entitled to discovery with respect to any such WN “pattern and practice.” WY Further, neither Responding Party’s objections that this interrogatory seeks or assumes facts Fe. not in evidence nor its objection that “this interrogatory ... seeks confidential information of non- YH parties to this lawsuit” is accurate and/or applicable. Dn ON SPECIAL INTERROGATORY NO. 60: If YOU contend that the reasonable value of services provided by the real estate broker to the oo 10 SELLER was Nine Hundred Seventy-Eight Thousand Dollars ($978,000.00), please state all 11 FACTS on which YOU base that contention. 12 RESPONSE TO SPECIAL INTERROGATORY NO. 60: 13 Responding Party objects to this interrogatory on the grounds that it is overbroad, vague and 14 ambiguous and seeks information that is not relevant and not likely to lead to the discovery of 15 admissible evidence. Responding Party further objects to this interrogatory on the grounds that it 16 assumes facts not in evidence. 17 Subject to and without waiving the foregoing objections, Responding Party responds as 18 follows: The contractually agreed value of value of services provided by the real estate broker - 19 whether or not that is the “reasonable value,” whatever that undefined phrase means- is Nine 20 Hundred Seventy-Eight Thousand Dollars ($978,000.00). 21 REASON WHY FURTHER RESPONSE IS NEEDED: 22 This Interrogatory simply requests that Responding Party identify the facts upon which it 23 bases the contention in its Complaint that the reasonable value of the services Responding Party 24 provided to SELLER with respect to the sale of the Toyopa Property was Nine Hundred Seventy- 25 Eight Thousand Dollars ($978,000.00). Responding Party has failed to do so, even after Moving 26 Party clarified, in the meet and confer process, the definition of the term “reasonable value” was its 27 common English usage. 28 12 DEFENDANTS’ SEPARATE STATEMENT in SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE SPECIAL INTERROGATORY NO. 61: If YOU contend that the reasonable value of services provided by the real estate broker to bo the SELLER was Nine Hundred Seventy-Eight Thousand Dollars ($978,000.00), please fully IDENTIFY all WITNESSES to the facts on which YOU base that contention. RESPONSE TO SPECIAL INTERROGATORY NO. 61: oa) 6 Responding Party objects to this interrogatory on the grounds that it is overbroad, vague and ambiguous and seeks information that is not relevant and not likely to lead to the discovery of admissible evidence. Responding Party further objects to this interrogatory on the grounds that it is compound and assumes facts not in evidence. Subject to and without waiving the foregoing objections, Responding Party responds as follows: The contractually agreed value of value of services provided by the real estate broker - whether or not that is the “reasonable value.” whatever that undefined phrase means- is Nine Hundred Seventy-Eight Thousand Dollars ($978,000.00). Responding party declines to respond with witnesses that support a contention it did not make. REASON WHY FURTHER RESPONSE IS NEEDED: 16 This Interrogatory simply requests that Responding Party identify all witnesses to the facts upon which it bases the contention in its Complaint that the reasonable value of the services Responding Party provided with respect to the sale of the by the real estate broker to the SELLER was Nine Hundred Seventy-Eight Thousand Dollars ($978.000.00). Responding Party has failed to do so, even after Moving Party clarified in the meet and confer process the definition of the term “reasonable value” was its common English language. Respectfully submitted, DATED: June| > . 2019 MICHAEL A.J. NANGANO, A LAW CORPORATION BY: MICHAEL A.J. NANGANO Attorneys for Defendants . Facsimile signature as original Pur RE: 4305(d) 3 DEFENDANTS’ SEPARATE STATEMENT in SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE MICHAEL A.J. NANGANO (SBN 133999) = MICHAEL AJ NANGANO, A LAW CORPORATION 133 No. Altadena Drive, Suite 403 HO Pasadena, CA 91107 Phone: (626) 796-9998 WY Fax: (626) 796-9992 ee Attorneys for Defendant(s) OH DO ON SUPERIOR COURT OF THE STATE OF CALIFORNIA co IN AND FOR THE COUNTY OF PLACER ee OS mm SY leo UNION INTERNATIONAL, Case No. S-CV 0042080 eee” mre HY ee WD See Plaintiff, [PROPOSED] ORDER REGARDING Se DEFENDANTS’ MOTION TO COMPEL Se ee VS. FURTHER RESPONSE TO SPECIAL ee INTERROGATORIES, SET ONE HN Se ERIK LUDWICK, an individual AND i Settlor of The Anything Trust dated October DKON Date: July 11, 2019 ne 12, 2007; THE ANYTHING TRUST Time: 8:30 a.m. a DATED OCTOBER 12, 2007; PAUL D. Dept.: 42 a BOOTH, in his capacity as Trustee of The OY ie Anything Trust Dated October 12, 2007; and a Does 1 through 50, inclusive, ae RO ee OO ae Defendants. RO a a Trial Date: None Set DN ee NK Name NO The motion by Defendants for an order compelling further response to Special Interrogatories WwW NO came on regularly for hearing, on July 11, 2019, at 8:30 a.m., in this Department. Lawrence E. Be NO Skidmore, Esq. appeared in court and Michael A.J. Nangano, Esq. appeared telephonically for NW NO moving party. ,Esq. from the Law Office of Shannon B. Jones appeared in ONO NO opposition for Plaintiff. nN NO 1 Co NO [PROPOSED] ORDER REGARDING DEFENDANTS’ MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES, SET ONE After considering the papers submitted in support of the motion and those in opposition to it, as well as oral argument made to the Court, this Court finds as follows: NY Plaintiffs motion is granted. This Court finds that there is good cause for an order by this WY Court compelling defendant to provide further responses to Special Interrogatories, (Set No. 1) FSF without objection. Defendant is ordered to answer fully the following items: 8, 26, 28, 29, 31, 32, WH 32, 33, 60, 61. Dn Defendant is ordered to provide the further responses within 20 days of this order. NY Oo IT IS SO ORDERED oO 10 DATED: July _, 2019 1] Judge of the Superior Court 12 13 14 15 16 17 18 19 20 | 22 23 24 2 26 27 28 2 [PROPOSED] ORDER REGARDING DEFENDANTS’ MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES, SET ONE PROOF OF SERVICE be | 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 June 13, 2019, I served the following document(s) described as: DEFENDANTS* MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES, SET ONE, SEPARATE STATEMENT IN SUPPORT THEREOF and PROPOSED ORDER on all interested parties in this action by placing [X] a true 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 was reported by the machine. Pursuant to Rule 2008(e)(4), I caused the machine to print a record of the transmission. (BY MAIL, 1013a, 2015.5 C.C.P.) Lam readily familiar with the firm’s practice for 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 at Los Angeles, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. (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 the ordinary course of business. addressed to the office of the addressee(s) listed above or on attached sheet. (BY E-MAIL) | transmitted a copy of the foregoing document(s) via e-mail to the addressee(s). Courtesy copy [Xx] (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on June 13, 2019, at Pasadena. California. Patricia M. Poole Facsimile Signature as original Pursuant to C.R.C. Rul e 2.305¢1) PROOP OF SERVICE MAILING LIST Pacific Union International, Inc. v. Ludwick, et al. NN Case No. SCV0042080 Ww Shannon B. Jones, Esq. r= Lindsey Morgan, Esq. Shannon B. Jones Law Group, Inc. wT 208 W. El Pintado Road HD Danville, CA 94526 SY OO © mo 12 13 14 1 16 17 18 19 20 21 22 23 24 25 26 27 28 2 PROOF OF SERVICE