Motion-Secondary: Pacific Union International, Inc. vs. Ludwick, Erik et al

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                                ELECTRONICALLY               FILED
                                                                                    superior Court of California,
                                                                                            County of Placer
                                                                                                07/30/2020
     SHANNON B. JONES LAW GROUP, INC.
                                                                                      By: Laurel Sanders, Deputy Clerk
     SHANNON B. JONES (Bar No. 149222)
     sbj@sbj-law.com
     LINDSEY A. MORGAN (Bar No. 274214)
     lam(@sbj-law.com
     208 W. El Pintado Road
     Danville, California 94526
     Telephone: (925) 837-2317
     Facsimile: (925) 837-4831

     Attorneys for Plaintiff
     PACIFIC UNION INTERNATIONAL, INC.


                   IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                 IN AND FOR THE COUNTY OF PLACER
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11   PACIFIC UNION INTERNATIONAL, INC.,                                          Case No.   SCV0042080

                                                  one” Sema” Ngee! “nent! Seay
12                 Plaintiff,                                                    PROOF OF SERVICE OF PACIFIC
13                                                                               UNION INTERNATIONAL, INC.’S
            V.                                                                   OPPOSITION TO DEFENDANTS’
14                                                                               MOTION FOR SUMMARY JUDGMENT
                                                  Soomro” Samer” See” Seer”




     ERIK LUDWICK,      an individual and
     beneficiary of The Anything Trust Dated
15   October 12, 2007; THE ANYTHING TRUST
     DATED OCTOBER 12, 2007; PAUL D.                                              Date:      August 13, 2020
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                                                  Nene” Sree” Sree” Se”




     BOOTH, in his capacity as trustee of The                                     Time:      9:30 a.m.
     Anything Trust Dated October 12, 2007; and                                   Dept:      42
17   DOES 1-50,
18                                                                               Complaint Filed: November 7, 2018
                                                  nee” Nee




                   Defendants.
                                                                                 Trial Date: September 21, 2020
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     PROOF OF SERVICE OF PACIFIC UNION INTERNATIONAL,                               INC.’S OPPOSITION TO DEFENDANTTS’
     MOTION FOR SUMMARY JUDGMENT
       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 July 30, 2020, I served the following document(s):
 a




       1.      PACIFIC UNION INTERNATIONAL, INC."S MEMORANDUM OF POINTS
               AND AUTHORITIES IN SUPPORT OF OPPOSITION TO DEFENDANTS’
 DN




               MOTION FOR SUMMARY JUDGMENT

       a       PACIFIC UNION INTERNATIONAL, INC.’S SEPARATE STATEMENT OF
 NSN




               DISPUTED MATERIALS FACTS AND ADDITIONAL UNDISPUTED
               MATERIAL FACTS IN SUPPORT OF OPPOSITION TO DEFENDANTS’
 Se




               MOTION FOR SUMMARY JUDGMENT
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       3.      PACIFIC UNION INTERNATIONAL, INC.’S EVIDENCE IN OPPOSITION TO
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               DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT
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       4.      DECLARATION OF SHANNON B. JONES IN SUPPORT OF PACIFIC UNION
12             INTERNATIONAL, INC.’S OPPOSITION TO DEFENDANTS’ MOTION FOR
               SUMMARY JUDGMENT
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       5.      PACIFIC UNION INTERNATIONAL, INC.’S REQUEST FOR JUDICIAL
14             NOTICE IN SUPPORT OF OPPOSITION TO DEFENDANTS’ MOTION FOR
               SUMMARY JUDGMENT
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       6.      PACIFIC UNION INTERNATIONAL, INC.’S EVIDENTIARY OBJECTIONS TO
16             DOCUMENTS AND OPINION TESTIMONY PRESENTED IN SUPPORT OF
               DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT
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       7,      [PROPOSED] ORDER DENYING DEFENDANTS’ MOTION FOR SUMMARY
18             JUDGMENT AND GRANTING SUMMARY JUDMGENT FOR PACIFIC UNION
               INTERNATIONAL, INC.
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       8.      PROOF OF SERVICE OF PACIFIC UNION INTERNATIONAL, INC.’S
20             OPPOSITION TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT

21        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.
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23       x      by transmitting via email the above listed document(s) to the email address(es) set forth
       below on this date before 5:00 p.m.
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       PROOF OF SERVICE OF PACIFIC UNION INTERNATIONAL,           INC.’S OPPOSITION TO DEFENDANTTS’
       MOTION FOR SUMMARY JUDGMENT
     Attorneys for Defendants Erik Ludwick,    The         Co-Counsel for Defendants Erik Ludwick, The
     Anything Trust and Paul Booth as Trustee of           Anything Trust and Paul Booth as Trustee of
     the Anything Trust                                    the Anything Trust
     Michael A.J. Nangano, Esq.                            Lawrence E. Skidmore, Esq.
     Michael A.J. Nangano, A Law Corporation               Aronowitz, Skidmore, Lyon
     133 North Altadena Drive, Suite 403                   200 Auburn Folsom Road, Suite 305
     Pasadena, CA 91107                                    Auburn, CA 95603
     Tel: (626) 796-9998                                   Tel: (530) 823-9736
     Fax: (213) 232-3252                                   Fax: (530) 823-5241
     mnangano(@lacounsel.com                               Iskidmore(@asilaw.org
     patti(@lacounsel.com

                     I declare under penalty of perjury under the laws of the State of California that the
     above is true and correct.

                     Executed on July 30, 2020, at Danville, California.
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     PROOF OF SERVICE OF PACIFIC UNION INTERNATIONAL,            INC.’S OPPOSITION TO DEFENDANTTS’
     MOTION FOR SUMMARY JUDGMENT