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ELECTRONICALLY FILED
superior Court of California,
County of Placer
SHANNON B. JONES LAW GROUP, INC. 08/14/2020
SHANNON B. JONES (Bar No. 149222) By: Laurel Sanders, Deputy Clerk
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
10
11 PACIFIC UNION INTERNATIONAL, INC., Case No. SCV0042080
12 Plaintiff, PROOF OF SERVICE OF PACIFIC
13 V. UNION INTERNATOINAL, INC.’S
MOTION FOR SUMMARY JUDGMENT
14 ERIK LUDWICK, an individual and OR, ALTERNATIVELY, SUMMARY
beneficiary of The Anything Trust Dated ADJUDICATION OF ISSUES
15 October 12, 2007; THE ANYTHING TRUST
DATED OCTOBER 12, 2007; PAUL D. Date: August 20, 2020
16 BOOTH, in his capacity as trustee of The
Time: 9:30 a.m.
Anything Trust Dated October 12, 2007; and
Dept: 42
a
17 DOES 1-50,
18 Defendants. Complaint Filed: November 7, 2018
i
Trial Date: September 21, 2020
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PROOF OF SERVICE OF PACIFIC UNION INTERNATOINAL, INC.°S MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY,
SUMMARY ADJUDICATION OF ISSUES
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 August 14, 2020, I served the within document(s):
1. PACIFIC UNION INTERNATIONAL, INC.’S REPLY BRIEF IN SUPPORT OF
MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY, SUMMARY
ADJUDICATION OF ISSUES
2. DECLARATION OF LINDSEY A. MORGAN IN SUPPORT OF PACIFIC UNION
INTERNATIONAL, INC.’S MOTION FOR SUMMARY JUDGMENT OR,
ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES
3. PACIFIC UNION INTERNATIONAL, INC.’S EVIDENTIARY OBJECTIONS TO
10 DOCUMENTS AND OPINION TESTIMONY PRESENTED IN SUPPORT OF
11 DEFENDANTS’ OPPOSITION TO MOTION FOR SUMMARY JUDGMENT
12 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.
13
X____ by transmitting via email the above listed document(s) to the email address(es) set forth
14 below on this date before 5:00 p.m.
15
Attornevs for Defendants Erik Ludwick, The Co-Counsel for Defendants Erik Ludwick,
16 Anything Trust and Paul Booth as Trustee of The Anything Trust and Paul Booth as
the Anything Trust Trustee of the Anything Trust
17 Michael A.J. Nangano, Esq. Lawrence E. Skidmore, Esq.
Michael] A.J. Nangano, A Law Corporation Aronowitz, Skidmore, Lyon
18 133 North Altadena Drive, Suite 403 200 Auburn Folsom Road, Suite 305
19 Pasadena, CA 91107 Auburn, CA 95603
Tel: (626) 796-9998 Tel: (530) 823-9736
20 Fax: (213) 232-3252 Fax: (530) 823-5241
mnangano@lacounsel.com Iskidmore@asilaw.org
21 patti@lacounsel.com :
22 I declare under penalty of perjury under the laws of the State of California that the
above is true and correct.
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24 Executed on August 14, 2020, at Danville, California.
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QJ
A. GSIOVANNONI
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PROOF OF SERVICE OF PACIFIC UNION INTERNATOINAL, INC.’'S MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY,
SUMMARY ADJUDICATION OF ISSUES
Preview
ELECTRONICALLY FILED superior Court of California, County of Placer SHANNON B. JONES LAW GROUP, INC. 08/14/2020 SHANNON B. JONES (Bar No. 149222) By: Laurel Sanders, Deputy Clerk 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 10 11 PACIFIC UNION INTERNATIONAL, INC., Case No. SCV0042080 12 Plaintiff, PROOF OF SERVICE OF PACIFIC 13 V. UNION INTERNATOINAL, INC.’S MOTION FOR SUMMARY JUDGMENT 14 ERIK LUDWICK, an individual and OR, ALTERNATIVELY, SUMMARY beneficiary of The Anything Trust Dated ADJUDICATION OF ISSUES 15 October 12, 2007; THE ANYTHING TRUST DATED OCTOBER 12, 2007; PAUL D. Date: August 20, 2020 16 BOOTH, in his capacity as trustee of The Time: 9:30 a.m. Anything Trust Dated October 12, 2007; and Dept: 42 a 17 DOES 1-50, 18 Defendants. Complaint Filed: November 7, 2018 i Trial Date: September 21, 2020 19 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// PROOF OF SERVICE OF PACIFIC UNION INTERNATOINAL, INC.°S MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES 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 August 14, 2020, I served the within document(s): 1. PACIFIC UNION INTERNATIONAL, INC.’S REPLY BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES 2. DECLARATION OF LINDSEY A. MORGAN IN SUPPORT OF PACIFIC UNION INTERNATIONAL, INC.’S MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES 3. PACIFIC UNION INTERNATIONAL, INC.’S EVIDENTIARY OBJECTIONS TO 10 DOCUMENTS AND OPINION TESTIMONY PRESENTED IN SUPPORT OF 11 DEFENDANTS’ OPPOSITION TO MOTION FOR SUMMARY JUDGMENT 12 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. 13 X____ by transmitting via email the above listed document(s) to the email address(es) set forth 14 below on this date before 5:00 p.m. 15 Attornevs for Defendants Erik Ludwick, The Co-Counsel for Defendants Erik Ludwick, 16 Anything Trust and Paul Booth as Trustee of The Anything Trust and Paul Booth as the Anything Trust Trustee of the Anything Trust 17 Michael A.J. Nangano, Esq. Lawrence E. Skidmore, Esq. Michael] A.J. Nangano, A Law Corporation Aronowitz, Skidmore, Lyon 18 133 North Altadena Drive, Suite 403 200 Auburn Folsom Road, Suite 305 19 Pasadena, CA 91107 Auburn, CA 95603 Tel: (626) 796-9998 Tel: (530) 823-9736 20 Fax: (213) 232-3252 Fax: (530) 823-5241 mnangano@lacounsel.com Iskidmore@asilaw.org 21 patti@lacounsel.com : 22 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 23 24 Executed on August 14, 2020, at Danville, California. 25 26 QJ A. GSIOVANNONI 27 28 2 PROOF OF SERVICE OF PACIFIC UNION INTERNATOINAL, INC.’'S MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES