Preview
Lawrence E. Skidmore (SBN 137587)
oe
ARONOWITZ SKIDMORE LYON
A PROFESSIONAL CORPORATION
FILED
HNO
SUPERIOR COURT OF CALIFOR
200 Auburn Folsom Road, Suite 305 COUNTY OF PLACER MIA
Auburn, CA 95603
WY)
Telephone: 530-823-9736 JUL 03 2019
Facsimile: 530-823-5241
Fe
JAKE CHATTERS
EXECUTIVE OFRIGER & CLERK
MICHAEL A.J. NANGANO (SBN 133999)
OO
By: E. {vazks, Deputy
MICHAEL AJ NANGANO, A LAW CORPORATION
133 No. Altadena Drive, Suite 403
DN
Pasadena, CA 91107
Phone: (626) 796-9998
NY
Fax: (626) 796-9992
Oo
Attorneys for Defendant(s)
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pet
S BeaA =H
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AAaRKGEBH
SUPERIOR COURT OF THE STATE OF CALIFORNIA
me
IN AND FOR THE COUNTY OF PLACER
me
FSAUEC
PACIFIC UNION INTERNATIONAL, Case No. S-CV 0042080
INC.,
Plaintiff, DEFENDANTS’ REPLY BRIEF
IN SUPPORT OF MOTION TO
ee
vs. COMPEL FURTHER RESPONSE
Rw
TO DEFENDANTS’ REQUEST
ee
ERIK LUDWICK, an individual AND FOR ADMISSIONS No. 12
Settlor of The Anything Trust dated October
12, 2007; THE ANYTHING TRUST [CCP §2031.300]
DATED OCTOBER 12, 2007; PAUL D.
NO
BOOTH, in his capacity as Trustee of The
ee
Anything Trust Dated October 12, 2007; and
NO
BS
Does 1 through 50, inclusive, Hearing Date: July 11, 2019
KN
FSO
Dept.: 42
Defendants.
NO
Time: 8:30 a.m.
NO
Trial Date: None Set
RE
PS
l
DEFENDANTS’ REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL
FURTHER RESPONSE TO REQUESTS FOR ADMISSION, SET ONE
This Reply Brief is filed in support of the Motion by Defendants ERIK LUDWICK, et al.
Ke
(hereinafter collectively “DEFENDANTS”)
KYO
to Compel Plaintiff PACIFIC UNION
INTERNATIONAL, INC. (“PUI”) to provide an actual answer to Request For Admission No. 12
WD
(which PUI chose to renumber as “No. 8"); and which is referred to hereinafter for simplicity’s sake
eke
simply as “The Disputed RFA.”
ON
DO
I. “The Disputed RFA.”
NN
“ADMIT Partners Trust, the contractually bound licensed real estate broker(s) (ORE
Oo
License #: 01869103 and 01013548") under the listing agreement has never done business
So
in Placer County, California.”!
COC
eet
The purpose of this Request For Admission is to establish that Partners Trust does not, in fact,
KF
“do business” in Placer County; and, therefore, Placer County is not the proper venue for this action.
NY
mm
WY
mm
II. PUI’s Response to “The Disputed RFA.”
F&F
PUI’s response to The Disputed RFA is an attempt to avoid admitting whether or not Partners
FD
Trust does business in Place County by means of a purely semantic and unjustifiable objection:
HD
“RESPONSE TO REQUEST FOR ADMISSION NO. 12 (Mis-labeled No. 8):
NY
Responding party objects to the Request as overbroad, vague, ambiguous, and
oH
unintelligible, particularly in its reliance on the undefined phrases as “contractually
OO
bound” and “listing agreement” and “done business.” Responding Party further
ODO
RO
objects to this Request on the grounds that it is compound and overbroad in time.
DRO
|§
Responding Party further objects to the request on the grounds that it calls for a legal
NO
NY
conclusion and/or expert conclusion and/or interpretation. Responding Party further
objects to the request as irrelevant and not reasonably calculated to lead to discovery
WY
KN
of admissible evidence. For the reasons identified herein, Responding Party in unable
Ph
NN
to admit or deny this request.”
UN
KN
HK
HR
1
YN
Bh
DEFENDANTS acknowledges that the “ORE” reference in the parenthetical portion of the
Co
mo
Request is a typo for “DRE” which is meant to refer to the California Department of Real Estate.
2
DEFENDANTS’ REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL
FURTHER RESPONSE TO REQUESTS FOR ADMISSION, SET ONE
Ill. PUI’s Objections Are Not Well-Founded.
=
Breaking the Response down by sentence:
HHO
A. First Sentence: “Responding party objects to the Request as overbroad, vague,
WY
ambiguous, and unintelligible, particularly in its reliance on the undefined phrases as
eR
“contractually bound” and “listing agreement” and “done business.”
DO
Simply asking whether or not a company has “done business” in a particular county
is not “overbroad, vague, ambiguous, and unintelligible.”
ON
Likewise, the objection that the “phrases” “contractually bound” and “listing
agreement” and “done business” are not specially is not well-founded.
co
These are not terms
of art, or labels intended to apply to a specific item, document or parcel of land — except for
Ee
SG
the “listing agreement” which is attached to, and the basis for, PUI’s complaint.
we
SH
“Contractually bound” is simply an adjectival phrase confirming that Partners Trust
ew
HH
(identified by its licensing number) is a party to the Listing Agreement
ewe eB
Bw
There is no confusion as to who Partners Trust is, or what “doing business” means.
Nor is there a need for any “legal and/or expert conclusion and/or interpretation.” The
Be
DwH
Request simply asks PUI to admit that Partners Trust (the original dual agency broker for the
Be
real estate sale giving rise to this action) has never done business in Placer County.
IK
S—
B. Second Sentence: “Responding Party further objects to this Request on the grounds
we
S|
that it is compound and overbroad in time.”
He
GO
Again, this is a simple “yes” or “no” question. There is nothing “compound” in the
N
Request — in fact the word “and” does not even appear. Likewise its is not “overbroad” —
KF
NY
simply a “yes” or “no” question as to whether Partners Trust has ever done business in Placer
NY
BF WH
County so as to meet a venue or jurisdictional requirement bringing the action in this County.
NN
Cc, Third Sentence: “Responding Party further objects to the request on the grounds
that it calls for a legal conclusion and/or expert conclusion and/or interpretation.”
NY NY
Co NDA
No “legal conclusion and/or expert conclusion and/or interpretation” is required to
answer whether or not Partners Trust has ever done business in Placer County! This
NN
objection is utterly without merit.
3
DEFENDANTS’ REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL
FURTHER RESPONSE TO REQUESTS FOR ADMISSION, SET ONE
—
D. Fourth Sentence: “Responding party further objects to the request as irrelevant and
not reasonably calculated to lead to discovery of admissible evidence.”
KPO
Whether or not venue and/or jurisdiction is proper in Placer County is neither
WO
“irrelevant” nor “not reasonably calculated to lead to the discovery of admissible evidence.”
BR
Clearly, the issues of venue and jurisdiction are relevant and admissible.
DWH
IV. PUI’s Legal Argument in Opposition to this Motion Is Based On A False Premise.
ON
In Section “B” of its “Legal Argument” in Opposition to LUDWICK’s Motion, PUI claims
that the Request is impermissibly asking for “two admissions” not just one:
So
A.. “... first that Pacific Union agrees that Partners Trust is ‘the contractually bound
CO
licensed real estate broker(s) . . . under the listing agreement . . .” (“Opposition to
KF
meee
Motion...” at p. 5, lines 7 - 14); and
NO
B. “The second part of the Request is: ‘ADMIT Partners Trust has never done business
WO
in Placer County, California” (“Opposition to Motion . . .” at p. 5, lines 15 - 25).
FBP
But, PUI’s alleged “first admission request” is not a request for admission at all; as the phrase
Wn
“the contractually bound licensed real estate broker(s),” while perhaps not the simplest manner in
WDB
wm
which to refer to Partners Trust, must still necessarily apply only to Partners Trust as it is the sole
NY
“broker” identified in the Listing Agreement and is identified by DRE Number. (See FN 1, above.)
fF
PUI filed this case in Placer County on the grounds that the former Trustee of the Defendant
OO
wm
Anything Trust (Paul Booth) is a resident of Placer County. Since Mr. Booth is no longer the
TD
RO
Trustee of the Trust; and since the property at issue is located in, and all other Defendants are
K§
RO
residents of, Los Angeles County, Moving Party is entitled to know if there is any other basis for
NH
NRO
continuing this action in Placer County.
WY
KR
FF
KN
Vv. PUI’s Legal Argument in Opposition to this Motion Has Been Made in Bad Faith.
OW
NO
LUDWICK’s Request for Admission No. 2 which was part of the same set of Requests as
Dn
BO
Request for Admission No. 8 which is the subject of this Motion, stated:
NI
NY
//
oo
NO
4
DEFENDANTS’ REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL
FURTHER RESPONSE TO REQUESTS FOR ADMISSION, SET ONE
“ADMIT that Pacific Union International. Inc. (DRE License #: 01866771 and
01396547) (hereinafter “PUI”) has never done BUSINESS (defined as used in the
Complaint, at 2:3) in Placer County. California.”
PUL responded to that Request for Admission, without objection, by stating that PUI had two
(2) offices in Placer County, in Tahoe City and Squaw Valley. Thus the argument that PUI cannot
answer as to whether or not “Partners Trust has never done business in Placer County, California”
for the various “reasons” stated in its responding papers has clearly not been made in good faith.
VI. PLAINTIFF’s Sanctions Request is Utterly Unjustified.
PLAINTIFF seeks sanctions in excess of Fifteen Hundred Dollars ($1,530.00) for allegedly
having to spend four (4) hours preparing the Opposition to LUDWICK’s Motion and anticipating
spending two (2) more hours preparing for the hearing on this single issue Motion. This is ludicrous
for the following reasons:
bi The Opposition relates to a single Request for Admission, not multiple items;
oF The only “authority” cited is the basic “requirements” language of Code of Civil
Procedure §2030.060 and §2033.220 et seq.:
» Neither DEFENDANTS’ Motion, nor PLAINTIFF’ s Opposition, presents any novel,
or even complicated, issues of law or fact; and
4. DEFENDANTS did not even request sanctions in their Motion — notwithstanding the
fact that PLAINTIFF had failed to provide the barest bones of a meaningful answer.
The Motion should be granted; and PUI should be ordered to provide a “yes” or “no” answer.
bo
ho
i)
oo
Respectfully submitted,
ho
\ulyy
-
> 3
DATED: May , 2019 MICHAEL A.J. NANGANO, A LAW CORPORATION
MAL I-E MICHAEL A.J. NANGANO
Attorneys for Defendants
Facsimile signature as original
P.
5
DEFENDANTS’ REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL
FURTHER RESPONSE TO REQUESTS FOR ADMISSION, SET ONE
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 July 3, 2019, I served the following document(s) described as:
DEFENDANTS’ REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL FURTHER
RESPONSE TO DEFENDANTS’ REQUEST FOR ADMISSION NO. 12
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
10 was reported by the machine. Pursuant to Rule 2008(e)(4), I caused the machine to print a
record of the transmission.
11
(BY MAIL, 1013a, 2015.5 C.C.P.) | am 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) | 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.
(BY E-MAIL) I transmitted a copy of the foregoing document(s) via e-mail to the
18 addressee(s). Courtesy copy
19 (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 July 3, 2019, at Pasadena, California.
22
PXtrtGia M. Poole
23
24 Facsimile signature as original
Pursuant to C.R.C. Rule 2.305(d)
25
26
27
28
1
PROOF OF SERVICE
MAILING LIST
Pacific Union International, Inc. v. Ludwick. et al.
HO
Case No. SCV0042080
WO
Shannon B. Jones, Esq.
Lindsey Morgan, Esq.
Shannon B. Jones Law Group, Inc.
208 W. El Pintado Road
Danville, CA 94526
2
PROOF OF SERVICE
Preview
Lawrence E. Skidmore (SBN 137587) oe ARONOWITZ SKIDMORE LYON A PROFESSIONAL CORPORATION FILED HNO SUPERIOR COURT OF CALIFOR 200 Auburn Folsom Road, Suite 305 COUNTY OF PLACER MIA Auburn, CA 95603 WY) Telephone: 530-823-9736 JUL 03 2019 Facsimile: 530-823-5241 Fe JAKE CHATTERS EXECUTIVE OFRIGER & CLERK MICHAEL A.J. NANGANO (SBN 133999) OO By: E. {vazks, Deputy MICHAEL AJ NANGANO, A LAW CORPORATION 133 No. Altadena Drive, Suite 403 DN Pasadena, CA 91107 Phone: (626) 796-9998 NY Fax: (626) 796-9992 Oo Attorneys for Defendant(s) Oo pet S BeaA =H te AAaRKGEBH SUPERIOR COURT OF THE STATE OF CALIFORNIA me IN AND FOR THE COUNTY OF PLACER me FSAUEC PACIFIC UNION INTERNATIONAL, Case No. S-CV 0042080 INC., Plaintiff, DEFENDANTS’ REPLY BRIEF IN SUPPORT OF MOTION TO ee vs. COMPEL FURTHER RESPONSE Rw TO DEFENDANTS’ REQUEST ee ERIK LUDWICK, an individual AND FOR ADMISSIONS No. 12 Settlor of The Anything Trust dated October 12, 2007; THE ANYTHING TRUST [CCP §2031.300] DATED OCTOBER 12, 2007; PAUL D. NO BOOTH, in his capacity as Trustee of The ee Anything Trust Dated October 12, 2007; and NO BS Does 1 through 50, inclusive, Hearing Date: July 11, 2019 KN FSO Dept.: 42 Defendants. NO Time: 8:30 a.m. NO Trial Date: None Set RE PS l DEFENDANTS’ REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSE TO REQUESTS FOR ADMISSION, SET ONE This Reply Brief is filed in support of the Motion by Defendants ERIK LUDWICK, et al. Ke (hereinafter collectively “DEFENDANTS”) KYO to Compel Plaintiff PACIFIC UNION INTERNATIONAL, INC. (“PUI”) to provide an actual answer to Request For Admission No. 12 WD (which PUI chose to renumber as “No. 8"); and which is referred to hereinafter for simplicity’s sake eke simply as “The Disputed RFA.” ON DO I. “The Disputed RFA.” NN “ADMIT Partners Trust, the contractually bound licensed real estate broker(s) (ORE Oo License #: 01869103 and 01013548") under the listing agreement has never done business So in Placer County, California.”! COC eet The purpose of this Request For Admission is to establish that Partners Trust does not, in fact, KF “do business” in Placer County; and, therefore, Placer County is not the proper venue for this action. NY mm WY mm II. PUI’s Response to “The Disputed RFA.” F&F PUI’s response to The Disputed RFA is an attempt to avoid admitting whether or not Partners FD Trust does business in Place County by means of a purely semantic and unjustifiable objection: HD “RESPONSE TO REQUEST FOR ADMISSION NO. 12 (Mis-labeled No. 8): NY Responding party objects to the Request as overbroad, vague, ambiguous, and oH unintelligible, particularly in its reliance on the undefined phrases as “contractually OO bound” and “listing agreement” and “done business.” Responding Party further ODO RO objects to this Request on the grounds that it is compound and overbroad in time. DRO |§ Responding Party further objects to the request on the grounds that it calls for a legal NO NY conclusion and/or expert conclusion and/or interpretation. Responding Party further objects to the request as irrelevant and not reasonably calculated to lead to discovery WY KN of admissible evidence. For the reasons identified herein, Responding Party in unable Ph NN to admit or deny this request.” UN KN HK HR 1 YN Bh DEFENDANTS acknowledges that the “ORE” reference in the parenthetical portion of the Co mo Request is a typo for “DRE” which is meant to refer to the California Department of Real Estate. 2 DEFENDANTS’ REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSE TO REQUESTS FOR ADMISSION, SET ONE Ill. PUI’s Objections Are Not Well-Founded. = Breaking the Response down by sentence: HHO A. First Sentence: “Responding party objects to the Request as overbroad, vague, WY ambiguous, and unintelligible, particularly in its reliance on the undefined phrases as eR “contractually bound” and “listing agreement” and “done business.” DO Simply asking whether or not a company has “done business” in a particular county is not “overbroad, vague, ambiguous, and unintelligible.” ON Likewise, the objection that the “phrases” “contractually bound” and “listing agreement” and “done business” are not specially is not well-founded. co These are not terms of art, or labels intended to apply to a specific item, document or parcel of land — except for Ee SG the “listing agreement” which is attached to, and the basis for, PUI’s complaint. we SH “Contractually bound” is simply an adjectival phrase confirming that Partners Trust ew HH (identified by its licensing number) is a party to the Listing Agreement ewe eB Bw There is no confusion as to who Partners Trust is, or what “doing business” means. Nor is there a need for any “legal and/or expert conclusion and/or interpretation.” The Be DwH Request simply asks PUI to admit that Partners Trust (the original dual agency broker for the Be real estate sale giving rise to this action) has never done business in Placer County. IK S— B. Second Sentence: “Responding Party further objects to this Request on the grounds we S| that it is compound and overbroad in time.” He GO Again, this is a simple “yes” or “no” question. There is nothing “compound” in the N Request — in fact the word “and” does not even appear. Likewise its is not “overbroad” — KF NY simply a “yes” or “no” question as to whether Partners Trust has ever done business in Placer NY BF WH County so as to meet a venue or jurisdictional requirement bringing the action in this County. NN Cc, Third Sentence: “Responding Party further objects to the request on the grounds that it calls for a legal conclusion and/or expert conclusion and/or interpretation.” NY NY Co NDA No “legal conclusion and/or expert conclusion and/or interpretation” is required to answer whether or not Partners Trust has ever done business in Placer County! This NN objection is utterly without merit. 3 DEFENDANTS’ REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSE TO REQUESTS FOR ADMISSION, SET ONE — D. Fourth Sentence: “Responding party further objects to the request as irrelevant and not reasonably calculated to lead to discovery of admissible evidence.” KPO Whether or not venue and/or jurisdiction is proper in Placer County is neither WO “irrelevant” nor “not reasonably calculated to lead to the discovery of admissible evidence.” BR Clearly, the issues of venue and jurisdiction are relevant and admissible. DWH IV. PUI’s Legal Argument in Opposition to this Motion Is Based On A False Premise. ON In Section “B” of its “Legal Argument” in Opposition to LUDWICK’s Motion, PUI claims that the Request is impermissibly asking for “two admissions” not just one: So A.. “... first that Pacific Union agrees that Partners Trust is ‘the contractually bound CO licensed real estate broker(s) . . . under the listing agreement . . .” (“Opposition to KF meee Motion...” at p. 5, lines 7 - 14); and NO B. “The second part of the Request is: ‘ADMIT Partners Trust has never done business WO in Placer County, California” (“Opposition to Motion . . .” at p. 5, lines 15 - 25). FBP But, PUI’s alleged “first admission request” is not a request for admission at all; as the phrase Wn “the contractually bound licensed real estate broker(s),” while perhaps not the simplest manner in WDB wm which to refer to Partners Trust, must still necessarily apply only to Partners Trust as it is the sole NY “broker” identified in the Listing Agreement and is identified by DRE Number. (See FN 1, above.) fF PUI filed this case in Placer County on the grounds that the former Trustee of the Defendant OO wm Anything Trust (Paul Booth) is a resident of Placer County. Since Mr. Booth is no longer the TD RO Trustee of the Trust; and since the property at issue is located in, and all other Defendants are K§ RO residents of, Los Angeles County, Moving Party is entitled to know if there is any other basis for NH NRO continuing this action in Placer County. WY KR FF KN Vv. PUI’s Legal Argument in Opposition to this Motion Has Been Made in Bad Faith. OW NO LUDWICK’s Request for Admission No. 2 which was part of the same set of Requests as Dn BO Request for Admission No. 8 which is the subject of this Motion, stated: NI NY // oo NO 4 DEFENDANTS’ REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSE TO REQUESTS FOR ADMISSION, SET ONE “ADMIT that Pacific Union International. Inc. (DRE License #: 01866771 and 01396547) (hereinafter “PUI”) has never done BUSINESS (defined as used in the Complaint, at 2:3) in Placer County. California.” PUL responded to that Request for Admission, without objection, by stating that PUI had two (2) offices in Placer County, in Tahoe City and Squaw Valley. Thus the argument that PUI cannot answer as to whether or not “Partners Trust has never done business in Placer County, California” for the various “reasons” stated in its responding papers has clearly not been made in good faith. VI. PLAINTIFF’s Sanctions Request is Utterly Unjustified. PLAINTIFF seeks sanctions in excess of Fifteen Hundred Dollars ($1,530.00) for allegedly having to spend four (4) hours preparing the Opposition to LUDWICK’s Motion and anticipating spending two (2) more hours preparing for the hearing on this single issue Motion. This is ludicrous for the following reasons: bi The Opposition relates to a single Request for Admission, not multiple items; oF The only “authority” cited is the basic “requirements” language of Code of Civil Procedure §2030.060 and §2033.220 et seq.: » Neither DEFENDANTS’ Motion, nor PLAINTIFF’ s Opposition, presents any novel, or even complicated, issues of law or fact; and 4. DEFENDANTS did not even request sanctions in their Motion — notwithstanding the fact that PLAINTIFF had failed to provide the barest bones of a meaningful answer. The Motion should be granted; and PUI should be ordered to provide a “yes” or “no” answer. bo ho i) oo Respectfully submitted, ho \ulyy - > 3 DATED: May , 2019 MICHAEL A.J. NANGANO, A LAW CORPORATION MAL I-E MICHAEL A.J. NANGANO Attorneys for Defendants Facsimile signature as original P. 5 DEFENDANTS’ REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSE TO REQUESTS FOR ADMISSION, SET ONE 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 July 3, 2019, I served the following document(s) described as: DEFENDANTS’ REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSE TO DEFENDANTS’ REQUEST FOR ADMISSION NO. 12 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 10 was reported by the machine. Pursuant to Rule 2008(e)(4), I caused the machine to print a record of the transmission. 11 (BY MAIL, 1013a, 2015.5 C.C.P.) | am 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) | 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. (BY E-MAIL) I transmitted a copy of the foregoing document(s) via e-mail to the 18 addressee(s). Courtesy copy 19 (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 July 3, 2019, at Pasadena, California. 22 PXtrtGia M. Poole 23 24 Facsimile signature as original Pursuant to C.R.C. Rule 2.305(d) 25 26 27 28 1 PROOF OF SERVICE MAILING LIST Pacific Union International, Inc. v. Ludwick. et al. HO Case No. SCV0042080 WO Shannon B. Jones, Esq. Lindsey Morgan, Esq. Shannon B. Jones Law Group, Inc. 208 W. El Pintado Road Danville, CA 94526 2 PROOF OF SERVICE