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1 SHANNON B, JONES LAW GROUP, INC,
SHANNON B. JONES (Bar No. 149222)
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sbiCcbsbi-law.corn
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LINDSEY A. MORGAN (Bar No. 2742 I 4)
lam@sbi-law.corn
4 208 W. El Pintado Road
Danville, California 94526
Telephone: (925) 837-2317
Facsimile: (925) 837-4831
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Attorneys for Plaintiff
PACIFIC UNION INTERNATIONAL, INC.
8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE COUNTY OF PLACER
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PACIFIC UNION INTERNATIONAL, INC., ) Case No. SCV0042080
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Plaintiff, NOTICE OF WAIVER OF JURY TRIAL
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ERIK LUDWICK, an individual and ) Complaint Filed: November 7, 2018
beneficiary of The Anything Trust Dated ) Trial Date: August 8, 2022
October 12, 2007; THE ANYTHING TRUST )
DATED OCTOBER 12, 2007; PAUL D. )
BOOTH, in his capacity as trustee of The )
Anything Trust Dated October 12, 2007; and )
DOES 1-50, )
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Defendants. )
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Plaintiff PACIFIC UNION INTERNATIONAL, INC. (*'Plaintiff ') hereby notifies
the Court that the parties have agreed to waive jury trial in this matter.
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Plaintiff waives its right to a jury trial in this matter and submits this matter to be
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tried by the Court. Defendants ERIK LUDWICK, an individual and beneficiary of The
Anything Trust Dated October 12, 2007, THE ANYTHING TRUST DATED OCTOBER 12,
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2007 and PAUL D. BOOTH, in his capacity as trustee of The Anything Trust Dated October 12,
2007 (collectively, **Defendants" ) verbally agreed to waive jury trial in telephone
communications with counsel for Plaintiff multiple times during the week of August I, 2022.
Defendants also advised the Court at the Civil Trial Conference that they had agreed to waive
jury trial.
NOTICE OF WAIVER OF JURY TRIAL
Accordingly, Plaintiff respectfully informs the Court that both parties have
waived their right to jury trial in this matter.
Dated: August 8, 2022 S HANNON B. JONES LAW GROUP, INC.
SHANNON B. JONES
LINDSEY A. MORGAN
Attorneys for Plaintiff,
PACIFIC UNION INTERNATIONAL, INC.
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NOTICE OF WAIVER OF JURY TRIAL
PROOF OF SERVICE
I, the undersigned, declare:
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I am aresident of the State of California and over the age of eighteen years, and
4 not a party to the within action; my business address is 208 W. El Pintado Road, Danville, CA
94526. On August 8, 2022, I served the within document(s):
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NOTICE OF WAIVER OF JURY TRIAL
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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Attornevs for Defendants Erik Ludwick The Co-Counsel for Defendants Erik Ludwick. The
Anvthine Trust and Paul Booth as Trustee of Anvthina Trust and Paul Bootlt as Trustee of
tlte Anvthint. Trust the Anvthine Trust
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Michael A.J. Nangano, Esq. Lawrence E. Skidmore, Esq.
12 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
mnanaano&a,lacounsel.corn IskidmoreQasilaw.ora
nattiSlacounsel.corn ImeltonAt.asilaw.ora
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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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Executed on August 8, 2022, at Danville, California
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EAGAN d
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NOTICE OF WAIVER OF IURY TRIAL
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1 SHANNON B, JONES LAW GROUP, INC, SHANNON B. JONES (Bar No. 149222) 2 sbiCcbsbi-law.corn 3 LINDSEY A. MORGAN (Bar No. 2742 I 4) lam@sbi-law.corn 4 208 W. El Pintado Road Danville, California 94526 Telephone: (925) 837-2317 Facsimile: (925) 837-4831 6 Attorneys for Plaintiff PACIFIC UNION INTERNATIONAL, INC. 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF PLACER 10 PACIFIC UNION INTERNATIONAL, INC., ) Case No. SCV0042080 11 ) Plaintiff, NOTICE OF WAIVER OF JURY TRIAL 12 13 ) ) ERIK LUDWICK, an individual and ) Complaint Filed: November 7, 2018 beneficiary of The Anything Trust Dated ) Trial Date: August 8, 2022 October 12, 2007; THE ANYTHING TRUST ) DATED OCTOBER 12, 2007; PAUL D. ) BOOTH, in his capacity as trustee of The ) Anything Trust Dated October 12, 2007; and ) DOES 1-50, ) ) Defendants. ) 18 ) 19 20 Plaintiff PACIFIC UNION INTERNATIONAL, INC. (*'Plaintiff ') hereby notifies the Court that the parties have agreed to waive jury trial in this matter. 22 Plaintiff waives its right to a jury trial in this matter and submits this matter to be 23 tried by the Court. Defendants ERIK LUDWICK, an individual and beneficiary of The Anything Trust Dated October 12, 2007, THE ANYTHING TRUST DATED OCTOBER 12, 24 2007 and PAUL D. BOOTH, in his capacity as trustee of The Anything Trust Dated October 12, 2007 (collectively, **Defendants" ) verbally agreed to waive jury trial in telephone communications with counsel for Plaintiff multiple times during the week of August I, 2022. Defendants also advised the Court at the Civil Trial Conference that they had agreed to waive jury trial. NOTICE OF WAIVER OF JURY TRIAL Accordingly, Plaintiff respectfully informs the Court that both parties have waived their right to jury trial in this matter. Dated: August 8, 2022 S HANNON B. JONES LAW GROUP, INC. SHANNON B. JONES LINDSEY A. MORGAN Attorneys for Plaintiff, PACIFIC UNION INTERNATIONAL, INC. 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NOTICE OF WAIVER OF JURY TRIAL PROOF OF SERVICE I, the undersigned, declare: 3 I am aresident of the State of California and over the age of eighteen years, and 4 not a party to the within action; my business address is 208 W. El Pintado Road, Danville, CA 94526. On August 8, 2022, I served the within document(s): 5 NOTICE OF WAIVER OF JURY TRIAL 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. 8 Attornevs for Defendants Erik Ludwick The Co-Counsel for Defendants Erik Ludwick. The Anvthine Trust and Paul Booth as Trustee of Anvthina Trust and Paul Bootlt as Trustee of tlte Anvthint. Trust the Anvthine Trust 11 Michael A.J. Nangano, Esq. Lawrence E. Skidmore, Esq. 12 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 mnanaano&a,lacounsel.corn IskidmoreQasilaw.ora nattiSlacounsel.corn ImeltonAt.asilaw.ora 16 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 18 Executed on August 8, 2022, at Danville, California 19 20 EAGAN d 21 22 23 24 25 26 27 28 NOTICE OF WAIVER OF IURY TRIAL