Preview
~— Lawrence E. Skidmore (SBN 137587)
ARONOWITZ SKIDMORE LYON
A PROFESSIONAL LAW CORPORATION
PH
200 Auburn Folsom Road, Suite 305
Auburn, CA 95603
WD
Telephone: 530-823-9736
Facsimile: 530-823-5241
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JAKE ( 2HATTE
EXECUTIVE OFFICE RS
R & CLERK
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By: C. Waggoner,
Deputy
MICHAEL A.J. NANGANO (SBN 133999)
DOD
MICHAEL AJ NANGANO, A LAW CORPORATION
133 No. Altadena Drive, Suite 403
Pasadena, CA 91107
ON
Phone: (626) 796-9998
Fax: (626) 796-9992
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Attorneys for Defendant(s)
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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IN AND FOR THE COUNTY OF PLACER
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PACIFIC UNION INTERNATIONAL, Case No. S-CV 0042080
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INC.,
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Plaintiff, REQUEST FOR JUDICIAL NOTICE IN
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SUPPORT OF DEFENDANTS’
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VS. DEMURRER TO PLAINTIFF’S
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COMPLAINT
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ERIK LUDWICK, an individual AND
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Settlor of The Anything Trust dated October Date: May 9, 2019
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12, 2007; THE ANYTHING TRUST Time: 8:30 a.m.
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DATED OCTOBER 12, 2007; PAUL D. Dept.: 42
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BOOTH, in his capacity as Trustee of The Complaint Filed: | November 7, 2018
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Anything Trust Dated October 12, 2007; and
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Does | through 50, inclusive,
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Trial Date: None Set
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Defendants.
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REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANTS’ DEMURRER TO PLAINTIFF’S COMPLAINT
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TO THE ABOVE ENTITLED COURT:
DEFENDANTS ERIK LUDWICK and PAUL D. BOOTH, in his capacity as
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Trustee of
The Anything Trust Dated October 12, 2007, PURSUANT TO Evidence Code
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§§ 452 and 453,
request that the Court take judicial notice of:
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1. The corporate license for Plaintiff Pacific Union International, Inc. (Samuel H.
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Kramer as Designated Officer), attached hereto as Exhibit A; and
2. The corporate license for Partners Trust (Nick R. Segal as designated officer),
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attached hereto as Exhibit B.
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Dated: March 29, 2019
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Respectfully submitted,
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Michael AJ Nangano, A Law Corporation
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Attorneys for Defendants
Facsimile signature as original
Pursuant to C.R.C. Kule 2, 305(a)
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REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANTS’ DEMURRER TO PLAINTIFF’S COMPLAINT
EXHIBIT A
http://www?.dre.ca, gemPublicASP/pplinfo.asp?License_id=01866771
STATE OF CALIFORNIA
DEPARTMENT OF REAL ESTATE
The license information shown below represents public information tak
en from the Department of Real Estate(DRE) database at the
time of your inquiry. It will not reflect pending chan ges which are being
reviewed for subsequent database updating. Also, the license
information provided includes formal administrative actions that have
been taken against licensees pursuant to the Business and
Professions Code and/or the Administrative Procedure Act. All of the
information displayed is public information. Although the business
and mailing addresses of real estate licensees are included, th is informati
on is not intended for mass mailing purposes,
License information taken from records of the Department of Real
Estate on 3/15/2019 3:28:29 PM
License Type: CORPORATION
Name: Pacific Union International Inc
Mailing Address: 1699 VAN NESS AVE
SAN FRANCISCO, CA 94109
License ID: 01866771
Expiration Date: 03/15/21
License Status: LICENSED
Corporation License 06/20/09
Issued:
Former Name(s): ML International Inc
Main Office: 1699 VAN NESS AVE
SAN FRANCISCO, CA 94109
01014267 - McOmber, Ferryle Bryant Jr - Division Manager
Licensed Officer(s): DESIGNATED OFFICER
01396547 - Expiration Date: 03/15/21
Kraemer, Samuel H
01708673 - Expiration Date: 04/26/20
Bonner, Christina Ann Ishibashi
OFFICER CANCELED AS OF 06/19/17
00860895 - Expiration Date: 07/10/21
Carroll, Linda Lee
OFFICER CANCELED AS OF 05/21/18
01196606 - Expiration Date: 06/19/21
Mclaughlin, Mark Alexander
OFFICER CANCELED AS OF 05/21/18
00770453 - Expiration Date: 07/24/21
Silvas, Jill Rae
OFFICER CANCELED AS OF 05/21/18
1 of 16 3/15/2019, 3:29 PM
http://www?2.dre.ca.ge@@RublicASP/pplinfo.asp?License_id=01866771
00429787 - Expiration Date: 06/19/13
Silvas, Michael W
OFFICER CANCELED AS OF 06/29/09
DBA BWG Partners
ACTIVE AS OF 10/15/2018
Compass
ACTIVE AS OF 11/08/2018
Compass Commerical
ACTIVE AS OF 11/08/2018
Compass Real Estate
ACTIVE AS OF 11/08/2018
Compass San Francisco
ACTIVE AS OF 11/08/2018
JBS Real Estate Team
ACTIVE AS OF 10/10/2017
L34 Group
ACTIVE AS OF 05/21/2018
Morgan Lane Real Estate
ACTIVE AS OF 04/06/2010
Pacific Union Commercial
ACTIVE AS OF 06/22/2018
Pacific Union Property Management
ACTIVE AS OF 07/24/2017
Pacific Union Real Estate
ACTIVE AS OF 04/06/2010
PT Commercial
ACTIVE AS OF 08/30/2017
Branches: 527 W 7TH ST STE 301
LOS ANGELES, CA 90014
01221146 Ruelas, Gustavo - Branch/Division Manager
5715 NORTH FIGUEROA ST
LOS ANGELES, CA 90042
575 REDWOOD HWY
MILL VALLEY, CA 94941
01221869 Lynch, Edward Louis - Branch/Division Manager
3/15/2019, 3:29 PM
2 of 16
EXHIBIT B
=
http. .ww2.dre.ca.gov/PublicASP/pplinfo.asp?start=1
STATE OF CALIFORNIA
DEPARTMENT OF REAL ESTATE
The license information shown below represents public information taken from the Department of Real Estate(DRE) database at the time of
your Inquiry. It will not reflect pending changes which are being reviewed for subsequent database updating. Also, the license information
provided includes formal administrative actions that have been taken against licensees pursuant to the Business and Professions Code and/or
the Administrative Procedure Act. All of the information displayed is public information, Although the business and malling addresses of real
estate licensees are included, this information Is not intended for mass mailing purposes.
License information taken from records of the Department of Real Estate on 3/15/2019 10:55:47 AM
License Type: CORPORATION
Name: Partners Trust Real Estate Brokerage &
Acquisitions
Mailing Address: 9378 WILSHIRE BLVD STE 200
BEVERLY HILLS, CA 90212
License ID: 01869103
Expiration Date: 07/29/21
License Status: LICENSED
Corporation License Issued: 07/30/09
Former Name(s): NO FORMER NAMES
Main Office: 9378 WILSHIRE BLVD STE 200
BEVERLY HILLS, CA 90212
Licensed Officer(s): DESIGNATED OFFICER
01013548 - Expiration Date: 07/29/21
Segal, Nick R
DBA Partners Trust
ACTIVE AS OF 10/28/2009
The Partners Trust
ACTIVE AS OF 10/28/2009
PT Commercial
ACTIVE AS OF 02/13/2017
PT Escrow a non independent broker
escrow
ACTIVE AS OF 11/12/2010
PT Referral
ACTIVE AS OF 02/13/2017
3/15/2019, 10:56 AM
1 of 2
i i,
http. . ww2.dre.ca.gov/PublicASP/pplinfo.asp?start=1
PT Referral Associates
ACTIVE AS OF 02/13/2017
Branches: 1730 1/2 OCEAN PARK BLVD
SANTA MONICA, CA 90405
23410 CIVIC CENTER WY STE C1
MALIBU, CA 90265
1333 MONTANA AVE
SANTA MONICA, CA 90403
11740 SAN VICENTE BLVD
LOS ANGELES, CA 90049
594 E COLORADO BLVD
PASADENA, CA 91101
01056761 Brown, Scott Gerald - Branch/Division Manager
964 FOOTHILL BLVD
LA CANADA FLINTRIDGE, CA 91011
01056761 Brown, Scott Gerald - Branch/Division Manager
9378 WILSHIRE BLVD 2ND FLOOR
BEVERLY HILLS, CA 90212
00592639 Misraje, Karen A - Branch/Division Manager
Salespersons: 01431214 - Lauder, Todd Patrick
License Expiration Date: 08/27/2019
Comment: NO DISCIPLINARY ACTION
NO OTHER PUBLIC COMMENTS
>>>> Public information request complete <<<<
2 of 2 3/15/2019
/2019, 10:56 AM
PROOF OF SERVICE
I 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 29, 2019, I served the following document(s) described as:
REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANTS’ DEMURRER TO
PLAINTIFF’?S COMPLAINT
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 | 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
[x] (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. I 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 DELIVERY/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 E-MAIL) | transmitted a copy of the foregoing document(s) via e-mail to the
18 addressee(s). Courtesy copy
19 [X] (STATE) I declare under penalty of perjury under the laws of the State of California that the
above is true and correct.
20
Executed on March 29, 2019, at Pasadena, California.
21 4
f°
c{
Patricia MPoole
Facsimile signature as original
Pursuant to C.R.C. Rule 2.305(d)
PROOF OF SERVICE
MAILING LIST
Pacific Union International, Inc. v. Ludwick, et al.
dh
Case No. SCV0042080
WW
Shannon B. Jones, Esq.
m=
Lindsey Morgan, Esq.
Shannon B. Jones Law Group, Inc.
Wm
208 W. El Pintado Road
Danville, CA 94526
nD
Lawrence E. Skidmore, Esq.
Aronowitz Skidmore Lyon
A Professional Law Corporation
200 Auburn Folsom Road, Suite 305
Auburn, CA 95603
10
ll
12
L3
14
LS
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19
20
21
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2
PROOF OF SERVICE
Preview
~— Lawrence E. Skidmore (SBN 137587) ARONOWITZ SKIDMORE LYON A PROFESSIONAL LAW CORPORATION PH 200 Auburn Folsom Road, Suite 305 Auburn, CA 95603 WD Telephone: 530-823-9736 Facsimile: 530-823-5241 BP JAKE ( 2HATTE EXECUTIVE OFFICE RS R & CLERK WNW By: C. Waggoner, Deputy MICHAEL A.J. NANGANO (SBN 133999) DOD MICHAEL AJ NANGANO, A LAW CORPORATION 133 No. Altadena Drive, Suite 403 Pasadena, CA 91107 ON Phone: (626) 796-9998 Fax: (626) 796-9992 So Attorneys for Defendant(s) CO mel KF YH mm WD SUPERIOR COURT OF THE STATE OF CALIFORNIA BR me IN AND FOR THE COUNTY OF PLACER HN DRO PACIFIC UNION INTERNATIONAL, Case No. S-CV 0042080 NT wm eee” INC., See Oe Nee Plaintiff, REQUEST FOR JUDICIAL NOTICE IN nee ODO SUPPORT OF DEFENDANTS’ ee VS. DEMURRER TO PLAINTIFF’S ne COMPLAINT OD RO ee ERIK LUDWICK, an individual AND a Settlor of The Anything Trust dated October Date: May 9, 2019 KH RO ee 12, 2007; THE ANYTHING TRUST Time: 8:30 a.m. a DATED OCTOBER 12, 2007; PAUL D. Dept.: 42 NHN KN re BOOTH, in his capacity as Trustee of The Complaint Filed: | November 7, 2018 a Anything Trust Dated October 12, 2007; and Ww NO ae Does | through 50, inclusive, a Trial Date: None Set FP NO a a Defendants. NYO UN a a NO Nee NN Name NO oOo tO REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANTS’ DEMURRER TO PLAINTIFF’S COMPLAINT we TO THE ABOVE ENTITLED COURT: DEFENDANTS ERIK LUDWICK and PAUL D. BOOTH, in his capacity as HO Trustee of The Anything Trust Dated October 12, 2007, PURSUANT TO Evidence Code WW §§ 452 and 453, request that the Court take judicial notice of: BP 1. The corporate license for Plaintiff Pacific Union International, Inc. (Samuel H. DO Kramer as Designated Officer), attached hereto as Exhibit A; and 2. The corporate license for Partners Trust (Nick R. Segal as designated officer), NN Oe attached hereto as Exhibit B. Oo Dated: March 29, 2019 ZS Respectfully submitted, a Michael AJ Nangano, A Law Corporation DARBESOHR mmm ELI na et AJ Nangan Attorneys for Defendants Facsimile signature as original Pursuant to C.R.C. Kule 2, 305(a) Sek eXRkRBRBSBRBRB DRO 2 REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANTS’ DEMURRER TO PLAINTIFF’S COMPLAINT EXHIBIT A http://www?.dre.ca, gemPublicASP/pplinfo.asp?License_id=01866771 STATE OF CALIFORNIA DEPARTMENT OF REAL ESTATE The license information shown below represents public information tak en from the Department of Real Estate(DRE) database at the time of your inquiry. It will not reflect pending chan ges which are being reviewed for subsequent database updating. Also, the license information provided includes formal administrative actions that have been taken against licensees pursuant to the Business and Professions Code and/or the Administrative Procedure Act. All of the information displayed is public information. Although the business and mailing addresses of real estate licensees are included, th is informati on is not intended for mass mailing purposes, License information taken from records of the Department of Real Estate on 3/15/2019 3:28:29 PM License Type: CORPORATION Name: Pacific Union International Inc Mailing Address: 1699 VAN NESS AVE SAN FRANCISCO, CA 94109 License ID: 01866771 Expiration Date: 03/15/21 License Status: LICENSED Corporation License 06/20/09 Issued: Former Name(s): ML International Inc Main Office: 1699 VAN NESS AVE SAN FRANCISCO, CA 94109 01014267 - McOmber, Ferryle Bryant Jr - Division Manager Licensed Officer(s): DESIGNATED OFFICER 01396547 - Expiration Date: 03/15/21 Kraemer, Samuel H 01708673 - Expiration Date: 04/26/20 Bonner, Christina Ann Ishibashi OFFICER CANCELED AS OF 06/19/17 00860895 - Expiration Date: 07/10/21 Carroll, Linda Lee OFFICER CANCELED AS OF 05/21/18 01196606 - Expiration Date: 06/19/21 Mclaughlin, Mark Alexander OFFICER CANCELED AS OF 05/21/18 00770453 - Expiration Date: 07/24/21 Silvas, Jill Rae OFFICER CANCELED AS OF 05/21/18 1 of 16 3/15/2019, 3:29 PM http://www?2.dre.ca.ge@@RublicASP/pplinfo.asp?License_id=01866771 00429787 - Expiration Date: 06/19/13 Silvas, Michael W OFFICER CANCELED AS OF 06/29/09 DBA BWG Partners ACTIVE AS OF 10/15/2018 Compass ACTIVE AS OF 11/08/2018 Compass Commerical ACTIVE AS OF 11/08/2018 Compass Real Estate ACTIVE AS OF 11/08/2018 Compass San Francisco ACTIVE AS OF 11/08/2018 JBS Real Estate Team ACTIVE AS OF 10/10/2017 L34 Group ACTIVE AS OF 05/21/2018 Morgan Lane Real Estate ACTIVE AS OF 04/06/2010 Pacific Union Commercial ACTIVE AS OF 06/22/2018 Pacific Union Property Management ACTIVE AS OF 07/24/2017 Pacific Union Real Estate ACTIVE AS OF 04/06/2010 PT Commercial ACTIVE AS OF 08/30/2017 Branches: 527 W 7TH ST STE 301 LOS ANGELES, CA 90014 01221146 Ruelas, Gustavo - Branch/Division Manager 5715 NORTH FIGUEROA ST LOS ANGELES, CA 90042 575 REDWOOD HWY MILL VALLEY, CA 94941 01221869 Lynch, Edward Louis - Branch/Division Manager 3/15/2019, 3:29 PM 2 of 16 EXHIBIT B = http. .ww2.dre.ca.gov/PublicASP/pplinfo.asp?start=1 STATE OF CALIFORNIA DEPARTMENT OF REAL ESTATE The license information shown below represents public information taken from the Department of Real Estate(DRE) database at the time of your Inquiry. It will not reflect pending changes which are being reviewed for subsequent database updating. Also, the license information provided includes formal administrative actions that have been taken against licensees pursuant to the Business and Professions Code and/or the Administrative Procedure Act. All of the information displayed is public information, Although the business and malling addresses of real estate licensees are included, this information Is not intended for mass mailing purposes. License information taken from records of the Department of Real Estate on 3/15/2019 10:55:47 AM License Type: CORPORATION Name: Partners Trust Real Estate Brokerage & Acquisitions Mailing Address: 9378 WILSHIRE BLVD STE 200 BEVERLY HILLS, CA 90212 License ID: 01869103 Expiration Date: 07/29/21 License Status: LICENSED Corporation License Issued: 07/30/09 Former Name(s): NO FORMER NAMES Main Office: 9378 WILSHIRE BLVD STE 200 BEVERLY HILLS, CA 90212 Licensed Officer(s): DESIGNATED OFFICER 01013548 - Expiration Date: 07/29/21 Segal, Nick R DBA Partners Trust ACTIVE AS OF 10/28/2009 The Partners Trust ACTIVE AS OF 10/28/2009 PT Commercial ACTIVE AS OF 02/13/2017 PT Escrow a non independent broker escrow ACTIVE AS OF 11/12/2010 PT Referral ACTIVE AS OF 02/13/2017 3/15/2019, 10:56 AM 1 of 2 i i, http. . ww2.dre.ca.gov/PublicASP/pplinfo.asp?start=1 PT Referral Associates ACTIVE AS OF 02/13/2017 Branches: 1730 1/2 OCEAN PARK BLVD SANTA MONICA, CA 90405 23410 CIVIC CENTER WY STE C1 MALIBU, CA 90265 1333 MONTANA AVE SANTA MONICA, CA 90403 11740 SAN VICENTE BLVD LOS ANGELES, CA 90049 594 E COLORADO BLVD PASADENA, CA 91101 01056761 Brown, Scott Gerald - Branch/Division Manager 964 FOOTHILL BLVD LA CANADA FLINTRIDGE, CA 91011 01056761 Brown, Scott Gerald - Branch/Division Manager 9378 WILSHIRE BLVD 2ND FLOOR BEVERLY HILLS, CA 90212 00592639 Misraje, Karen A - Branch/Division Manager Salespersons: 01431214 - Lauder, Todd Patrick License Expiration Date: 08/27/2019 Comment: NO DISCIPLINARY ACTION NO OTHER PUBLIC COMMENTS >>>> Public information request complete <<<< 2 of 2 3/15/2019 /2019, 10:56 AM PROOF OF SERVICE I 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 29, 2019, I served the following document(s) described as: REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANTS’ DEMURRER TO PLAINTIFF’?S COMPLAINT 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 | 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 [x] (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. I 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 DELIVERY/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 E-MAIL) | transmitted a copy of the foregoing document(s) via e-mail to the 18 addressee(s). Courtesy copy 19 [X] (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 20 Executed on March 29, 2019, at Pasadena, California. 21 4 f° c{ Patricia MPoole Facsimile signature as original Pursuant to C.R.C. Rule 2.305(d) PROOF OF SERVICE MAILING LIST Pacific Union International, Inc. v. Ludwick, et al. dh Case No. SCV0042080 WW Shannon B. Jones, Esq. m= Lindsey Morgan, Esq. Shannon B. Jones Law Group, Inc. Wm 208 W. El Pintado Road Danville, CA 94526 nD Lawrence E. Skidmore, Esq. Aronowitz Skidmore Lyon A Professional Law Corporation 200 Auburn Folsom Road, Suite 305 Auburn, CA 95603 10 ll 12 L3 14 LS 16 17 18 19 20 21 ae 23 24 25 26 27 28 2 PROOF OF SERVICE