On November 07, 2018 a
Party Discovery
was filed
involving a dispute between
Pacific Union International, Inc.,
and
Booth, Paul D., Trustee Of The Anything Trust,
Erik Ludwick,
The Anything Trust Dated Oct. 12, 2007,
for Civil-Roseville
in the District Court of Placer County.
Preview
SHANNON B. JONES LAW GROUP, INC.
SHANNON B. JONES (Bar No. 149222)
sbiPa.sbi-law.corn
LINDSEY A. MORGAN (Bar No. 274214)
lamia.sbi-law.corn
208 W. El Pintado Road
Danville, California 94526
Telephone: (925) 837-2317
Facsimile: (925) 837-4831
Attorneys for Plaintiff
PACIFIC UNION INTERNATIONAL, INC.
9 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 IN AND FOR THE COUNTY OF PLACER
PACIFIC UNION INTERNATIONAL, INC., ) Case No. SCV0042080
)
12 Plaintiff, PROOF OF SERVICE OF MOTION TO
)
QUASH, OR ALTERNATIVELY, FOR
13 )
)
FOR PROTECTIVE ORDER
14 ERIK LUDWICK, an individual and ) REGARDING THE NOTICE OF TAKING
beneficiary of The Anything Trust Dated ) THE DEPOSITION OF SAMUEL H.
15 October 12, 2007; THE ANYTHING TRUST ) KRAEMER WITH REQUEST FOR
DATED OCTOBER 12, 2007; PAUL D. PRODUCTION OF DOCUMENTS
16 BOOTH, in his capacity as trustee of The
Anything Trust Dated October 12, 2007; and )
17 DOES 1-50, )
)
Defendants. ) Complaint Filed: November 7, 2018
) Trial Date: August 8, 2022
19
20 I, the undersigned, declare:
21 I am a resident of the State of California and over the age of eighteen years, and not
22 a party to the within action; my business address is 208 W. El Pintado Road, Danville, CA 94526.
On June 29, 2022, I served the within document(s):
23
1. PLAINTIFF'S NOTICE OF MOTION AND MOTION TO QUASH, OR
24 ALTERNATIVELY, FOR PROTECTIVE ORDER REGARDING THE NOTICE OF
TAKING THE DEPOSITION OF SAMUEL H. KRAEMER WITH REQUEST FOR
25
PRODUCTION OF DOCUMENTS
26
2. MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PACIFIC
27 UNION INTERNATIONAL, INC.'S MOTION TO QUASH, OR
ALTERNATIVELY, FOR PROTECTIVE ORDER REGARDING THE NOTICE OF
28 TAKING THE DEPOSITION OF SAMUEL H. KRAEMER WITH REQUEST FOR
PRODUCTION OF DOCUMENTS
PROOF OF SERVICE
3. DECLARATION OF LINDSEY A. MORGAN IN SUPPORT OF MOTION TO
QUASH, OR ALTERNATIVELY, FOR PROTECTIVE ORDER REGARDING THE
NOTICE OF TAKING THE DEPOSITION OF SAMUEL H. KRAEMER WITH
REQUEST FOR PRODUCTION OF DOCUMENTS
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.
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.
.4ttorneus for Defendonts Erik Ludwictc The Co-Cotrnsel for Defendants Erik Ludwick. The
Attt thine Trust and Paul Booth as Trustee of Anvthinu Trust and Paul Booth as Trustee of
the Anvthinu Trust the Anvthinu Trust
10 Lawrence E. Skidmore, Esq.
Michael A.J. Nangano, Esq.
Michael A.J. Nangano, A Law Corporation Aronowitz, Skidmore, Lyon
133 North Altadena Drive, Suite 403 200 Auburn Folsom Road, Suite 305
12 Pasadena, CA 91107 Auburn, CA 95603
Tel: (626) 796-9998 Tel: (530) 823-9736
13 Fax: (213) 232-3252 Fax: (530) 823-5241
mnanaanoFadacounsekcom IskidmoreSasilaw.ore
14 nattiPadacounsekcom ImeltonPa.asilaw.orv.
15
declare under penalty of perjury under the laws of the State of California that the
I
16 above is true and correct.
17 Executed on June 29, 2022, at Danville, California.
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@REAGAN
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PROOF OF SERVICE
Document Filed Date
June 29, 2022
Case Filing Date
November 07, 2018
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