Preview
ELECTRONICALLY FILED
superior Court of California,
County of Placer
SHANNON B. JONES LAW GROUP, INC. 04/01/2021 at 12:58:56 PM
SHANNON B. JONES (Bar No. 149222)
fi bvtarnina C Olivarez Fuentes, Deputy Cle
sbi@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, ) NOTICE OF ENTRY OF ORDER
13 )
Vv.
14 ERIK LUDWICK, an individual and )
beneficiary of The Anything Trust Dated )
15 October 12, 2007; THE ANYTHING TRUST _ ) Complaint Filed: November 7, 2018
DATED OCTOBER 12, 2007; PAUL D. )
16 BOOTH, in his capacity as trustee of The )
Anything Trust Dated October 12, 2007; and _)
17 DOES 1-50, )
18 )
Defendants. )
19 )
20 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
21 PLEASE TAKE NOTICE that on March 11, 2021, the Court entered an Order
22 denying Plaintiff's Motion for Summary Judgment or Summary Adjudication, a copy of which is
23 attached hereto as Exhibit A.
24 Dated: March A 2021 SHANNON B. JONES LAW GROUP, INC.
25 \ |
26 By
x DSEY A>MORGAN
27 ( Attorneys for Pjaintiff,
PACIFIC UNI IN-+ MepITA TIONAL, INC.
28
NOTICE OF ENTRY OF ORDER
Exhibit A
FELED
a
i
Superior Court of
County of PlaCalifornia
cer
#
MAR 11 209]
WN
Jake Chatters
Executive Officer &
Crasr
By: M. Taylor, bef,
BRB
Dm
ON
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF PLACER
Oo
HOC
PACIFIC UNION INTERNATIONAL, CASE NO.: S-CV-0042080
ee
Eu 5 Ruling on Plaintiff’s Motion for.
eh
Plaintiff, Summary Judgment or Summary
BwWNH
Adjudication
SP
vs.
eB
ERIK LUDWICK, et al.
eB
Defendants.
DU
Be
eB
The hearing on plaintiff’s motion for summary judgment or summary
DOAN
BH
adjudication came on for hearing on March 11, 2021. The appearances of
He
the parties for the hearing were as recited in the court’s minutes. The court
NY
TD
has read and considered the moving and opposing papers and heard the oral
NK
arguments of counsel. The court issues the following ruling on the matters
WNHrR
KN
submitted for decision:
NHN
Ruling on Objections
RB
N
Defendants’ objections are overruled in their entirety. Their objections
are not compliant with California Rules of Court, Rule 3.1354(b), which
DAU
NN
requires the party to quote the objectionable statement or material of
evidence. Instead of quoting the evidence, defendants point to portions of
SCN
NN
plaintiff's opposition.
Plaintiff’s objection nos. 1 to the factual statements made in defendants‘
request for judicial notice are sustained. The objection is overruled as to the
NY
court documents. Plaintiff’s objection no. 2 is sustained.
HRW
Plaintiff's objections nos. 2, 3, 6-19 to the Ludwick declaration are sustained.
Plaintiff’s objection no. 1, 4, 5, 20, 21, 22, 23, 24, 25, 26 are overruled.
DH
Ruling on Request for Judicial Notice
Defendants’ request for judicial notice is granted as to the documents in
ON
request no. 1. The objections to request no. 2 were sustained in their entirety.
Plaintiff’s request for judicial notice is granted under Evidence Code section
Oo
452.
OC
Ruling on Motion
eS
+
The motion is denied. The trial court shall grant a motion for summary
eS
WN
judgment if “all the papers submitted show that there is no triable issue as to
es
any material fact and the moving party is entitled to a judgment as a matter
BR
ee
of law.” (Code of Civil Procedure section 437c(c).) The moving party has the
WH
burden of showing facts establishing every element necessary to sustain a
HD
PH
judgment in favor of the party. (Consumer Cause, Inc. v. Smilecare (2001)
WAN
91 Cal.App.4th 454, 468.) Once a plaintiff proves its prima facie case, the
BBP
burden of proof shifts to the defendant to prove material facts. (Code of Civil
OO
Procedure section 437c(p)(1).) In reviewing the motion, the trial court must
DO
KN
view the supporting evidence, and inferences reasonably drawn from such
FH
NY
evidence, in the light most favorable to the opposing party. (Aguilar v. Atlantic
NY
NN
Richfield Company (2001) 25 Cal.4th 826, 843.) The court reviews the motion
BPW
keeping this in mind.
NN
First, Second, Third, Sixth, Seventh, and Eighth Causes of Action
DM
- Breach of Contract, Breach of the Implied Covenant, Common
NNN
Counts, Intentional Misrepresentation, Specific Performance, and
On
Declaratory Relief
Plaintiff has not met its initial burden as to these six claims. Each of
these causes of action rely on the existence of a contract with a six percent
WN
commission on the purchase price of the subject property. Plaintiff submits
the declaration of Madison Hildebrand, the listing agent who entered into the
FF
listing agreement with the defendant trustee and defendant trust for the
DWH
subject property. In the declaration, Mr. Hildebrand does not attest to ever
informing defendants of plaintiff's acquisition of Partners Trust. (see
ON
generally Hildebrand declaration.) He goes on to state he sent defendant
Erik Ludwick “an email enclosing the final Residential Purchase Agreement
oO
which had just been provided to Toni Antoci, with a purchase price of
Es
FBG
$15,884,375, and commission of four and a half percent (4.5%).”
Ee
(Hildebrand declaration 47.) Mr. Hildebrand also states “On September 17,
eS
2017, Ludwick sent me an email demanding that I accept a commission of
Se
BPW
two and a half percent (2.5%) of the total sale price of the Property. ... []
eB
On September 18, 2017, I responded to Ludwick and indicated that I was
UU
Be
unable to reduce the commission any lower than four and one-half percent
TD
Be
(4.5%) as I represented both sides of the transaction.” (Hildebrand
eB
DWN
declaration 4914, 15.) This evidence, and the reasonable inferences drawn
BB
from it, tends to show Mr. Hildebrand was primarily responsible for the
DO
listing agreement and continued to actively negotiate its terms. Construing
KR
the evidence most favorably to the opposing party, the evidence creates a
NN
HY
reasonable inference that it was unsettled that a six percent commission is
NY
WNY
owed under the terms of the agreement. In light of this, plaintiff has failed
NY
to meet its burden as to the first, second, third, sixth, seventh, and eighth
BP
NY
causes of action.
DMN
NN
Fourth Cause of Action - Intentional Interference with
Contractual Relations
NN
ON
A claim for intentional interference with contractual relations requires
the plaintiff to establish (1) a valid contract between plaintiff and a third party;
WN
(2) defendant’s knowledge of the contract; (3) defendant’s intentional acts
designed to induce a breach or disrupt the contract;
PR
(4) actual breach or
disruption of the contractual relationship; and (5) damages. (Quelamine Co.
DH
v. Stewart Title Guaranty Co. (1998) 19 Cal.4th 26, 55.) However, this claim
is usually applicable against those who are strangers to the contract. (Pacific
AN
Gas & Electric Co. v. Bear Stearns & Co. (1990) 50 Cal.3d 1118, 1126.)
Plaintiff has not made a sufficient showing that defendant Erik Ludwick was a
o
stranger to the contract so as to be liable under the fourth cause of action.
OS
To reiterate, the declaration of Mr. Hildebrand attests to negotiations with Mr.
eS
BONE
Ludwick regarding the sale of the property. (Hildebrand declaration 947, 14,
ee
15.) Even if Mr. Ludwick could be considered a stranger to the contract,
plaintiff has not submitted sufficient evidence showing he intended to disrupt
Be
or cause breach of the listing agreement. Again, Mr. Hildebrand attests to
AH
discussing a four and a half percent commission for the sale of the subject
eB
property. (Hildebrand declaration 414, 15.) This evidence, and the
BBB
DOAN
reasonable inferences drawn from it, tends to show Mr. Hildebrand continued
to negotiate the commission amount rather than establishing the commission
was set at six percent. Plaintiff has failed to meet its burden as to the fourth
NNN
cause of action.
BPWNHPH
Fifth Cause of Action — Intentional Interference with Prospective
Economic Advantage
NNN
Finally, plaintiff has failed to meet its burden as to the fifth cause of
action. A claim for intentional interference with prospective economic
DH
advantage requires the plaintiff to show (1) an economic relationship between
NNN
the plaintiff and some third party with the probability of future economid
ON
benefits; (2) the defendant’s knowledge of the relationship; (3) intentional
wrongful acts by the defendant designed to disrupt the relationship; (4) actual
disruption of the relationship; and (5) economic harm. (Korea Supply Co. v.
WN
Lockheed Martin Corp. (2003) 29 Cal.4th 1134, 1153-1154; Della Pena v.
Toyota Motor Sales, U.S.A. (1995) 11 Cal.4th 376.) Again, plaintiff has not
KR
shown Mr. Ludwick was unassociated with the listing agreement. (Hildebrand
DMN
declaration 4/7, 14, 15.) Plaintiff's submitted evidence also fails to sufficiently
establish wrongful acts, intentional or otherwise, on the part of Mr. Ludwick;
ODN
any disruption of a relationship; or economic harm. To reiterate, the
submitted evidence and the reasonable inferences drawn from it tends to show
Oo
Mr. Hildebrand was in charge of the listing agreement and continued to
BO
actively negotiate the terms of the commission. (Hildebrand declaration 9414,
Pp
15.)
Se
WN
Disposition
SP
BR
In sum, plaintiff has failed to meet its initial burden. Both the request
me
for summary judgment and the request for summary adjudication are denied.
ew
DH
BH
DATED: B-//-2/ _ Wii. [Wc B-
WAN
BB
Hort. Charles D. Wachob
Judge of the Superior Court
HB
ODO
NH
FH
NYNHN
WN
NY
PF
NN
DU
NNN
oN
SUPERIOR COURT OF CALIFORNIA
IN AND FOR THE COUNTY OF PLACER
CLERK’S CERTIFICATE OF MAILING (C.C.P. §1013a(4))
Case No.: S-CV-0042080
Case Name: Pacific Union International, Inc. vs. Ludwick, Erik et al
I, the undersigned, certify that I am the clerk of the Superior Court of Califomia, County of
Placer, and I am not a party to this action.
I mailed copies of the documents(s) indicated below:
Ruling on Plaintiff’s Motion for Summary Judgment or Summary Adjudication
True copies of the documents were mailed following standard court practices in a sealed
envelope with postage fully prepaid, addressed as follows:
Lawrence Skidmore
200 Aubum Folsom Rd, Ste 305
Auburn, CA 95603
Michael Nangano
133 N Altadena Dr, Ste 403
Pasadena, CA 91107
Shannon Jones
208 W EI Pintado Rd
Danville, CA 94526
Tam readily familiar with the court’s business practices for collecting and processing
correspondence for mailing; pursuant to those practices, these documents are delivered to
the US Postal Service
[ ] UPS
[|] FedEx
[_] Interoffice mail
[_] Other
on 4. }2. >| in Placer County, California.
JAKE CHATTERS
Clerk of the Superigy/Court
Dated: 3 Df by:
A. Taytor, Députy Clerk
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 April 1, 2021, I served the within document(s):
NOTICE OF ENTRY OF ORDER
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.
Attorneys for Defendants Erik Ludwick, The Co-Counsel for Defendants Erik Ludwick,
Anything Trust and Paul Booth as Trustee of | The Anything Trust and Paul Booth as
the Anything Trust Trustee of the Anything Trust
10
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
patti@lacounsel.com
15
16 I declare under penalty of perjury under the laws of the State of California that the
above is true and correct.
17
Executed on April 1, 2021, at Danville, California.
18
19
20 Y. MEMAGER d
21
22
23
24
25
26
27
28
NOTICE OF ENTRY OF ORDER
Preview
ELECTRONICALLY FILED superior Court of California, County of Placer SHANNON B. JONES LAW GROUP, INC. 04/01/2021 at 12:58:56 PM SHANNON B. JONES (Bar No. 149222) fi bvtarnina C Olivarez Fuentes, Deputy Cle sbi@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, ) NOTICE OF ENTRY OF ORDER 13 ) Vv. 14 ERIK LUDWICK, an individual and ) beneficiary of The Anything Trust Dated ) 15 October 12, 2007; THE ANYTHING TRUST _ ) Complaint Filed: November 7, 2018 DATED OCTOBER 12, 2007; PAUL D. ) 16 BOOTH, in his capacity as trustee of The ) Anything Trust Dated October 12, 2007; and _) 17 DOES 1-50, ) 18 ) Defendants. ) 19 ) 20 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 21 PLEASE TAKE NOTICE that on March 11, 2021, the Court entered an Order 22 denying Plaintiff's Motion for Summary Judgment or Summary Adjudication, a copy of which is 23 attached hereto as Exhibit A. 24 Dated: March A 2021 SHANNON B. JONES LAW GROUP, INC. 25 \ | 26 By x DSEY A>MORGAN 27 ( Attorneys for Pjaintiff, PACIFIC UNI IN-+ MepITA TIONAL, INC. 28 NOTICE OF ENTRY OF ORDER Exhibit A FELED a i Superior Court of County of PlaCalifornia cer # MAR 11 209] WN Jake Chatters Executive Officer & Crasr By: M. Taylor, bef, BRB Dm ON SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF PLACER Oo HOC PACIFIC UNION INTERNATIONAL, CASE NO.: S-CV-0042080 ee Eu 5 Ruling on Plaintiff’s Motion for. eh Plaintiff, Summary Judgment or Summary BwWNH Adjudication SP vs. eB ERIK LUDWICK, et al. eB Defendants. DU Be eB The hearing on plaintiff’s motion for summary judgment or summary DOAN BH adjudication came on for hearing on March 11, 2021. The appearances of He the parties for the hearing were as recited in the court’s minutes. The court NY TD has read and considered the moving and opposing papers and heard the oral NK arguments of counsel. The court issues the following ruling on the matters WNHrR KN submitted for decision: NHN Ruling on Objections RB N Defendants’ objections are overruled in their entirety. Their objections are not compliant with California Rules of Court, Rule 3.1354(b), which DAU NN requires the party to quote the objectionable statement or material of evidence. Instead of quoting the evidence, defendants point to portions of SCN NN plaintiff's opposition. Plaintiff’s objection nos. 1 to the factual statements made in defendants‘ request for judicial notice are sustained. The objection is overruled as to the NY court documents. Plaintiff’s objection no. 2 is sustained. HRW Plaintiff's objections nos. 2, 3, 6-19 to the Ludwick declaration are sustained. Plaintiff’s objection no. 1, 4, 5, 20, 21, 22, 23, 24, 25, 26 are overruled. DH Ruling on Request for Judicial Notice Defendants’ request for judicial notice is granted as to the documents in ON request no. 1. The objections to request no. 2 were sustained in their entirety. Plaintiff’s request for judicial notice is granted under Evidence Code section Oo 452. OC Ruling on Motion eS + The motion is denied. The trial court shall grant a motion for summary eS WN judgment if “all the papers submitted show that there is no triable issue as to es any material fact and the moving party is entitled to a judgment as a matter BR ee of law.” (Code of Civil Procedure section 437c(c).) The moving party has the WH burden of showing facts establishing every element necessary to sustain a HD PH judgment in favor of the party. (Consumer Cause, Inc. v. Smilecare (2001) WAN 91 Cal.App.4th 454, 468.) Once a plaintiff proves its prima facie case, the BBP burden of proof shifts to the defendant to prove material facts. (Code of Civil OO Procedure section 437c(p)(1).) In reviewing the motion, the trial court must DO KN view the supporting evidence, and inferences reasonably drawn from such FH NY evidence, in the light most favorable to the opposing party. (Aguilar v. Atlantic NY NN Richfield Company (2001) 25 Cal.4th 826, 843.) The court reviews the motion BPW keeping this in mind. NN First, Second, Third, Sixth, Seventh, and Eighth Causes of Action DM - Breach of Contract, Breach of the Implied Covenant, Common NNN Counts, Intentional Misrepresentation, Specific Performance, and On Declaratory Relief Plaintiff has not met its initial burden as to these six claims. Each of these causes of action rely on the existence of a contract with a six percent WN commission on the purchase price of the subject property. Plaintiff submits the declaration of Madison Hildebrand, the listing agent who entered into the FF listing agreement with the defendant trustee and defendant trust for the DWH subject property. In the declaration, Mr. Hildebrand does not attest to ever informing defendants of plaintiff's acquisition of Partners Trust. (see ON generally Hildebrand declaration.) He goes on to state he sent defendant Erik Ludwick “an email enclosing the final Residential Purchase Agreement oO which had just been provided to Toni Antoci, with a purchase price of Es FBG $15,884,375, and commission of four and a half percent (4.5%).” Ee (Hildebrand declaration 47.) Mr. Hildebrand also states “On September 17, eS 2017, Ludwick sent me an email demanding that I accept a commission of Se BPW two and a half percent (2.5%) of the total sale price of the Property. ... [] eB On September 18, 2017, I responded to Ludwick and indicated that I was UU Be unable to reduce the commission any lower than four and one-half percent TD Be (4.5%) as I represented both sides of the transaction.” (Hildebrand eB DWN declaration 4914, 15.) This evidence, and the reasonable inferences drawn BB from it, tends to show Mr. Hildebrand was primarily responsible for the DO listing agreement and continued to actively negotiate its terms. Construing KR the evidence most favorably to the opposing party, the evidence creates a NN HY reasonable inference that it was unsettled that a six percent commission is NY WNY owed under the terms of the agreement. In light of this, plaintiff has failed NY to meet its burden as to the first, second, third, sixth, seventh, and eighth BP NY causes of action. DMN NN Fourth Cause of Action - Intentional Interference with Contractual Relations NN ON A claim for intentional interference with contractual relations requires the plaintiff to establish (1) a valid contract between plaintiff and a third party; WN (2) defendant’s knowledge of the contract; (3) defendant’s intentional acts designed to induce a breach or disrupt the contract; PR (4) actual breach or disruption of the contractual relationship; and (5) damages. (Quelamine Co. DH v. Stewart Title Guaranty Co. (1998) 19 Cal.4th 26, 55.) However, this claim is usually applicable against those who are strangers to the contract. (Pacific AN Gas & Electric Co. v. Bear Stearns & Co. (1990) 50 Cal.3d 1118, 1126.) Plaintiff has not made a sufficient showing that defendant Erik Ludwick was a o stranger to the contract so as to be liable under the fourth cause of action. OS To reiterate, the declaration of Mr. Hildebrand attests to negotiations with Mr. eS BONE Ludwick regarding the sale of the property. (Hildebrand declaration 947, 14, ee 15.) Even if Mr. Ludwick could be considered a stranger to the contract, plaintiff has not submitted sufficient evidence showing he intended to disrupt Be or cause breach of the listing agreement. Again, Mr. Hildebrand attests to AH discussing a four and a half percent commission for the sale of the subject eB property. (Hildebrand declaration 414, 15.) This evidence, and the BBB DOAN reasonable inferences drawn from it, tends to show Mr. Hildebrand continued to negotiate the commission amount rather than establishing the commission was set at six percent. Plaintiff has failed to meet its burden as to the fourth NNN cause of action. BPWNHPH Fifth Cause of Action — Intentional Interference with Prospective Economic Advantage NNN Finally, plaintiff has failed to meet its burden as to the fifth cause of action. A claim for intentional interference with prospective economic DH advantage requires the plaintiff to show (1) an economic relationship between NNN the plaintiff and some third party with the probability of future economid ON benefits; (2) the defendant’s knowledge of the relationship; (3) intentional wrongful acts by the defendant designed to disrupt the relationship; (4) actual disruption of the relationship; and (5) economic harm. (Korea Supply Co. v. WN Lockheed Martin Corp. (2003) 29 Cal.4th 1134, 1153-1154; Della Pena v. Toyota Motor Sales, U.S.A. (1995) 11 Cal.4th 376.) Again, plaintiff has not KR shown Mr. Ludwick was unassociated with the listing agreement. (Hildebrand DMN declaration 4/7, 14, 15.) Plaintiff's submitted evidence also fails to sufficiently establish wrongful acts, intentional or otherwise, on the part of Mr. Ludwick; ODN any disruption of a relationship; or economic harm. To reiterate, the submitted evidence and the reasonable inferences drawn from it tends to show Oo Mr. Hildebrand was in charge of the listing agreement and continued to BO actively negotiate the terms of the commission. (Hildebrand declaration 9414, Pp 15.) Se WN Disposition SP BR In sum, plaintiff has failed to meet its initial burden. Both the request me for summary judgment and the request for summary adjudication are denied. ew DH BH DATED: B-//-2/ _ Wii. [Wc B- WAN BB Hort. Charles D. Wachob Judge of the Superior Court HB ODO NH FH NYNHN WN NY PF NN DU NNN oN SUPERIOR COURT OF CALIFORNIA IN AND FOR THE COUNTY OF PLACER CLERK’S CERTIFICATE OF MAILING (C.C.P. §1013a(4)) Case No.: S-CV-0042080 Case Name: Pacific Union International, Inc. vs. Ludwick, Erik et al I, the undersigned, certify that I am the clerk of the Superior Court of Califomia, County of Placer, and I am not a party to this action. I mailed copies of the documents(s) indicated below: Ruling on Plaintiff’s Motion for Summary Judgment or Summary Adjudication True copies of the documents were mailed following standard court practices in a sealed envelope with postage fully prepaid, addressed as follows: Lawrence Skidmore 200 Aubum Folsom Rd, Ste 305 Auburn, CA 95603 Michael Nangano 133 N Altadena Dr, Ste 403 Pasadena, CA 91107 Shannon Jones 208 W EI Pintado Rd Danville, CA 94526 Tam readily familiar with the court’s business practices for collecting and processing correspondence for mailing; pursuant to those practices, these documents are delivered to the US Postal Service [ ] UPS [|] FedEx [_] Interoffice mail [_] Other on 4. }2. >| in Placer County, California. JAKE CHATTERS Clerk of the Superigy/Court Dated: 3 Df by: A. Taytor, Députy Clerk 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 April 1, 2021, I served the within document(s): NOTICE OF ENTRY OF ORDER 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. Attorneys for Defendants Erik Ludwick, The Co-Counsel for Defendants Erik Ludwick, Anything Trust and Paul Booth as Trustee of | The Anything Trust and Paul Booth as the Anything Trust Trustee of the Anything Trust 10 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 patti@lacounsel.com 15 16 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 17 Executed on April 1, 2021, at Danville, California. 18 19 20 Y. MEMAGER d 21 22 23 24 25 26 27 28 NOTICE OF ENTRY OF ORDER