Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Shannon B. Jones (#149222) / Lindsey A. Morgan (#274214)
Shannon B. Jones Law Group, Inc.
208 W. El Pintado Road
Danville, CA 94526 FILED
TELEPHONE (929) 837-2517 EAR NO: (optonets (925) 83:48 54 SUPERIOR COURT OF CALIFORNIA
E-MAIL ADDRESS (Optional): sbj@sbj-law.com; lam@sbj-law.com COUNTY OF PLACER
ATTORNEY FOR (Name): Plaintiff Pacific Union International, Inc. M AY 0 3 2019
SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER
street avpress: 10820 Justice Center Drive eareeiitive oan UEFA
MAILING ADDRESS:
By: C. Vallan-Brown, Deputy
CITY AND ziP CODE: Roseville, CA 95678
arancH Name: Bill Santucci Justice Center
KB
PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC.
DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): [LX] UNLIMITED CASE [_] LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less) SCV0042080
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: May 21, 2019 Time: 10:00 a.m. Dept.: 40 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Lindsey A. Morgan, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
,
1. Party or parties (answer one): ,
a. This statement is submitted by party (name): Plaintiff Pacific Union International, Inc. ty ; irs
b. [__] This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): November 7, 2018
b. [-_] The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [__] The following parties named in the complaint or cross-complaint
(1) [__] have not been served (specify names and explain why not):
(2) [__] have been served but have not appeared and have not been dismissed (specify names):
(3) (__] have had a default entered against them (specify names):
which
c. [__] The following additional parties may be added (specify names, nature of involvement in case, and date by
they may be served):
4. Description of case
a. Type of case in complaint {-] cross-complaint (Describe, including causes of action):
See Attachment 1
Page 1 of §
Cal. Rules of Court,
for Meatpty ce
Fon fapaptied CASE MANAGEMENT STATEMENT ‘ules 3 720.3796
CM-110 (Rev. July 1, 2011)
LexisNexis® Automated California Judicial Council Forms
~ am,
CM-110
|__- PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. aeimaiiiiaia
DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. SCV0042080
4. b. Providea brief statement of the case, including any damages. (/f personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
eamings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff seeks to recover a contractually agreed upon commission of $978,000, plus interest and attorneys
fees, after selling real property pursuant to written contract. The commission remains in an escrow account
since November 2017 because the Trustee refused to sign commission release instructions and directed
escrow to hold the money. The contractual documents are clear about the amount owed to Plaintiff.
[-_] (if more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request ajury trial [__] anonjurytrial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. [__] The trial has been set for (date):
b. No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
See Attachment 2
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 5-7
b. [_] hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption [__] by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
[__] Additional representation is described in Attachment 8.
9. Preference
[__] This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel has L_] has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party C_] has [_] has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) [7] This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) [-_] Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
Amount requested exceeds limits.
EHC hee CASE MANAGEMENT STATEMENT Page 2 of
LexisNexis® Automated California Judicial Council Forms
CM-110
| PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC, f"“®E®
PEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al a
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):
Mediation session not yet scheduled
Mediation session scheduled for (date):
UU
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
UOUOUU)UU0UU;OUUUU;OUUU|OUUN); Settlement conference scheduled for (date):
(2) Settlement
conference
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date):
(4) Nonbinding judicial
arbitration Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
(5) Binding private
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
| ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
Page 3 of 5
CM-110 [Rev. July 1, 2011]
CASE MANAGEMENT STATEMENT
LexisNexis® Automated California JudiciatCouncil Forms
CM-110
|__-PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. CASE NUMBER:
DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. SC viO02080
11. Insurance
a. [_] Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: [L_] Yes [-_] No
c. [__] Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
[_] Bankruptcy L__] Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. [_] There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
[-_] Additional cases are described in Attachment 13a.
b. [-_]Amotionto [_] consolidate | [7_] coordinate will be filed by (name party):
14. Bifurcation
[_] The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
[x] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Plaintiff anticipates filling a dispositive motion after conducting appropriate discovery..
16. Discovery
a. [__] The party or parties have completed all discovery.
b. LX] The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Pacific Union International Written discovery Per Code
Pacific Union International Deposition discovery Per Code
Pacific Union International Expert discovery Per Code
c. C4 The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
4 of 5
Page
CM-110 [Rev. July 1, 2011]
CASE MANAGEMENT STATEMENT
LexisNexis® Automated California Judicial Council Forms
PLAINTIFFIPETITIONER: PACIFIC UNION INTERNATIONAL, INC, CASE NUMBER:
CM-110
DEFENDANTIRESPONDENT: ERIK LUDWICK, an individual, et al. SEWOOT2080
17. Economic litigation
a. L_] This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in
Code
of Civil Procedure sections 90-98 will apply to this case.
b. L__] This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
[_] The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a. LX _] The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules
of Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any): 1
| am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: May 1, 2019
SHANNON B. JONES >
ZK
7 _>
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
{___] Additional signatures are attached.
Sa SE ty. OT CASE MANAGEMENT STATEMENT Page
6 of §
LexisNexis® Automated California Judicial Council Forms
Attachments
Attachment 1
The Complaint alleges claims against a trust, its trustee, and the beneficiary of the trust for
breach of contract, breach of implied covenant of good faith and fair dealing, common
count, intentional interference with contractual relations, intentional interference with
prospective economic advantage, intentional misrepresentation, specific performance, and
declaratory relief, based upon their interference with the payment of a contractually agreed
upon commission from the sale of a home.
Attachment 2
5/22/19 Seminar; 5/29/19 Seminar; 5/30/19 Mediation; 6/4/19 Mediation; 6/5/19-6/14/19
Vacation; 6/10/19 to 6/24/19 Trial; 6/12/19 Seminar; 6/17/19 Hearing; 6/18/19 Mediation;
6/19/19 Seminar; 6/20/19 Mediation; 6/25/19 Mediation; 6/26/19 Mediation; 6/28/19
Meeting; 7/5/19-7/12/19 Vacation; 7/10/19 Settlement Conference; 7/17/19-7/18/19
Vacation; 7/23/19 Hearing; 7/24/19 Mediation; 7/30/19 Mediation; 7/31/19 Mediation;
8/2/19 Trial Conference; 8/2/19 Hearing; 8/5/19-8/16/19 Trial; 8/9/19 Settlement
Conference; 8/13/19-8/16/19 Arbitration; 8/19/19 Settlement Conference; 8/21/19 Issue
Conference: 8/21/19 Settlement Conference; 9/3/19-9/17/19 Trial; 9/11/19 Seminar;
9/17/19 Mediation; 9/18/19 Seminar; 9/19/19 Settlement Conference; 9/20/19 -10/4/19
Trial; 9/25/19 to 9/28/19 Meetings; 9/27/19 Trial Conference; 9/30/19-10/11/19 Trial;
10/2/19 Seminar; 10/7/19-10/21/19 Trial; 10/7/19-10/18/19 Trial; 10/8/19 Settlement
Conference; 10/11/19 Settlement Conference; 10/16/19 Seminar; 10/16/19 Settlement
Conference: 10/17/19 Trial Conference; 10/18/19 Trial; 10/21/19 Seminar; 10/21/19
Settlement Conference; 10/21/19—11/1/19 Trial; 10/28/19-11/7/19 Trial; 11/4/19-11/15/19
Trial; 11/8/19 Conference; 11/15/19-11/27/19 Trial; 12/11/19 Seminar; 12/20/19 -1/13/20
Vacation; 1/14/20 Pre-Trial Conference; 1/23/20 Trial Conference; 1/27/20 Trial;
2/11/20-2/21/20 Trial; 3/2/20-3/13/20 Trial; 3/16/20-4/3/20 Trial; 3/16/20 Trial
Conference; 3/27/20 Trial Call; 4/1/20-4/24/20 Trial
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 May 2, 2019, I served the within document(s):
CASE MANAGEMENT STATEMENT
ND
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.
wo
oO
Attorneys for Defendants Erik Ludwick, The Co-Counsel for Defendants Erik Ludwick, The
Anything Trust and Erik Arthur Ludwick as Anything Trust and Erik Arthur Ludwick as
10
Trustee of the Anything Trust Trustee of the Anything Trust
11 Michael A.J. Nangano, Esq. Lawrence E. Skidmore, Esq.
Michael A.J. Nangano, A Law Corporation Aronowitz, Skidmore, Lyon
12 133 North Altadena Drive, Suite 403 200 Auburn Folsom Road, Suite 305
Pasadena, CA 91107 Auburn, CA 95603
13 Tel: (626) 796-9998 Tel: (530) 823-9736
Fax: (213) 232-3252 Fax: (530) 823-5241
14 mnangano@lacounsel.com Iskidmore@asilaw.org
15
I declare under penalty of perjury under the laws of the State of California that the
16 above is true and correct.
17 Executed on May 2, 2019, at Danville, California.
18
19 “dN EL. pe Lay
MON
20
21
22
23
24
25
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PROOF OF SERVICE ~ CASE MANAGEMENT STATEMENT
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Shannon B. Jones (#149222) / Lindsey A. Morgan (#274214) Shannon B. Jones Law Group, Inc. 208 W. El Pintado Road Danville, CA 94526 FILED TELEPHONE (929) 837-2517 EAR NO: (optonets (925) 83:48 54 SUPERIOR COURT OF CALIFORNIA E-MAIL ADDRESS (Optional): sbj@sbj-law.com; lam@sbj-law.com COUNTY OF PLACER ATTORNEY FOR (Name): Plaintiff Pacific Union International, Inc. M AY 0 3 2019 SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER street avpress: 10820 Justice Center Drive eareeiitive oan UEFA MAILING ADDRESS: By: C. Vallan-Brown, Deputy CITY AND ziP CODE: Roseville, CA 95678 arancH Name: Bill Santucci Justice Center KB PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): [LX] UNLIMITED CASE [_] LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) SCV0042080 A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 21, 2019 Time: 10:00 a.m. Dept.: 40 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Lindsey A. Morgan, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. , 1. Party or parties (answer one): , a. This statement is submitted by party (name): Plaintiff Pacific Union International, Inc. ty ; irs b. [__] This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): November 7, 2018 b. [-_] The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [__] The following parties named in the complaint or cross-complaint (1) [__] have not been served (specify names and explain why not): (2) [__] have been served but have not appeared and have not been dismissed (specify names): (3) (__] have had a default entered against them (specify names): which c. [__] The following additional parties may be added (specify names, nature of involvement in case, and date by they may be served): 4. Description of case a. Type of case in complaint {-] cross-complaint (Describe, including causes of action): See Attachment 1 Page 1 of § Cal. Rules of Court, for Meatpty ce Fon fapaptied CASE MANAGEMENT STATEMENT ‘ules 3 720.3796 CM-110 (Rev. July 1, 2011) LexisNexis® Automated California Judicial Council Forms ~ am, CM-110 |__- PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. aeimaiiiiaia DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. SCV0042080 4. b. Providea brief statement of the case, including any damages. (/f personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost eamings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff seeks to recover a contractually agreed upon commission of $978,000, plus interest and attorneys fees, after selling real property pursuant to written contract. The commission remains in an escrow account since November 2017 because the Trustee refused to sign commission release instructions and directed escrow to hold the money. The contractual documents are clear about the amount owed to Plaintiff. [-_] (if more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request ajury trial [__] anonjurytrial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. [__] The trial has been set for (date): b. No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): See Attachment 2 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 5-7 b. [_] hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption [__] by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: [__] Additional representation is described in Attachment 8. 9. Preference [__] This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel has L_] has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party C_] has [_] has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) [7] This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) [-_] Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): Amount requested exceeds limits. EHC hee CASE MANAGEMENT STATEMENT Page 2 of LexisNexis® Automated California Judicial Council Forms CM-110 | PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC, f"“®E® PEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al a 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): Mediation session not yet scheduled Mediation session scheduled for (date): UU (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled UOUOUU)UU0UU;OUUUU;OUUU|OUUN); Settlement conference scheduled for (date): (2) Settlement conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled Judicial arbitration scheduled for (date): (4) Nonbinding judicial arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled Private arbitration scheduled for (date): (5) Binding private arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled | ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): Page 3 of 5 CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT LexisNexis® Automated California JudiciatCouncil Forms CM-110 |__-PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. CASE NUMBER: DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. SC viO02080 11. Insurance a. [_] Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: [L_] Yes [-_] No c. [__] Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. [_] Bankruptcy L__] Other (specify): Status: 13. Related cases, consolidation, and coordination a. [_] There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: [-_] Additional cases are described in Attachment 13a. b. [-_]Amotionto [_] consolidate | [7_] coordinate will be filed by (name party): 14. Bifurcation [_] The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions [x] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Plaintiff anticipates filling a dispositive motion after conducting appropriate discovery.. 16. Discovery a. [__] The party or parties have completed all discovery. b. LX] The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Pacific Union International Written discovery Per Code Pacific Union International Deposition discovery Per Code Pacific Union International Expert discovery Per Code c. C4 The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): 4 of 5 Page CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT LexisNexis® Automated California Judicial Council Forms PLAINTIFFIPETITIONER: PACIFIC UNION INTERNATIONAL, INC, CASE NUMBER: CM-110 DEFENDANTIRESPONDENT: ERIK LUDWICK, an individual, et al. SEWOOT2080 17. Economic litigation a. L_] This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. L__] This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues [_] The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. LX _] The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 1 | am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: May 1, 2019 SHANNON B. JONES > ZK 7 _> (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) {___] Additional signatures are attached. Sa SE ty. OT CASE MANAGEMENT STATEMENT Page 6 of § LexisNexis® Automated California Judicial Council Forms Attachments Attachment 1 The Complaint alleges claims against a trust, its trustee, and the beneficiary of the trust for breach of contract, breach of implied covenant of good faith and fair dealing, common count, intentional interference with contractual relations, intentional interference with prospective economic advantage, intentional misrepresentation, specific performance, and declaratory relief, based upon their interference with the payment of a contractually agreed upon commission from the sale of a home. Attachment 2 5/22/19 Seminar; 5/29/19 Seminar; 5/30/19 Mediation; 6/4/19 Mediation; 6/5/19-6/14/19 Vacation; 6/10/19 to 6/24/19 Trial; 6/12/19 Seminar; 6/17/19 Hearing; 6/18/19 Mediation; 6/19/19 Seminar; 6/20/19 Mediation; 6/25/19 Mediation; 6/26/19 Mediation; 6/28/19 Meeting; 7/5/19-7/12/19 Vacation; 7/10/19 Settlement Conference; 7/17/19-7/18/19 Vacation; 7/23/19 Hearing; 7/24/19 Mediation; 7/30/19 Mediation; 7/31/19 Mediation; 8/2/19 Trial Conference; 8/2/19 Hearing; 8/5/19-8/16/19 Trial; 8/9/19 Settlement Conference; 8/13/19-8/16/19 Arbitration; 8/19/19 Settlement Conference; 8/21/19 Issue Conference: 8/21/19 Settlement Conference; 9/3/19-9/17/19 Trial; 9/11/19 Seminar; 9/17/19 Mediation; 9/18/19 Seminar; 9/19/19 Settlement Conference; 9/20/19 -10/4/19 Trial; 9/25/19 to 9/28/19 Meetings; 9/27/19 Trial Conference; 9/30/19-10/11/19 Trial; 10/2/19 Seminar; 10/7/19-10/21/19 Trial; 10/7/19-10/18/19 Trial; 10/8/19 Settlement Conference; 10/11/19 Settlement Conference; 10/16/19 Seminar; 10/16/19 Settlement Conference: 10/17/19 Trial Conference; 10/18/19 Trial; 10/21/19 Seminar; 10/21/19 Settlement Conference; 10/21/19—11/1/19 Trial; 10/28/19-11/7/19 Trial; 11/4/19-11/15/19 Trial; 11/8/19 Conference; 11/15/19-11/27/19 Trial; 12/11/19 Seminar; 12/20/19 -1/13/20 Vacation; 1/14/20 Pre-Trial Conference; 1/23/20 Trial Conference; 1/27/20 Trial; 2/11/20-2/21/20 Trial; 3/2/20-3/13/20 Trial; 3/16/20-4/3/20 Trial; 3/16/20 Trial Conference; 3/27/20 Trial Call; 4/1/20-4/24/20 Trial 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 May 2, 2019, I served the within document(s): CASE MANAGEMENT STATEMENT ND 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. wo oO Attorneys for Defendants Erik Ludwick, The Co-Counsel for Defendants Erik Ludwick, The Anything Trust and Erik Arthur Ludwick as Anything Trust and Erik Arthur Ludwick as 10 Trustee of the Anything Trust Trustee of the Anything Trust 11 Michael A.J. Nangano, Esq. Lawrence E. Skidmore, Esq. Michael A.J. Nangano, A Law Corporation Aronowitz, Skidmore, Lyon 12 133 North Altadena Drive, Suite 403 200 Auburn Folsom Road, Suite 305 Pasadena, CA 91107 Auburn, CA 95603 13 Tel: (626) 796-9998 Tel: (530) 823-9736 Fax: (213) 232-3252 Fax: (530) 823-5241 14 mnangano@lacounsel.com Iskidmore@asilaw.org 15 I declare under penalty of perjury under the laws of the State of California that the 16 above is true and correct. 17 Executed on May 2, 2019, at Danville, California. 18 19 “dN EL. pe Lay MON 20 21 22 23 24 25 26 Zi 28 PROOF OF SERVICE ~ CASE MANAGEMENT STATEMENT