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1 MICHAEL A.J. NANGANO, CSB #133999
mnangano@lacounsel.com
2 Michael AJ Nangano, A Law Corporation
133 N Altadena Dr, Ste 403
3 Pasadena, California 91107
Telephone: (626) 796-9998
4 Fax: (626) 796-9992
5 LAWRENCE E. SKIDMORE, CSB #137587
lskidmore@asilaw.org
6 ARONOWITZ SKIDMORE LYON
A Professional Law Corporation
7 200 Auburn Folsom Road, Suite 305
Auburn, California 95603
8 Telephone: (530) 823-9736
Fax: (530) 823-5241
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Attorneys for Defendants
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11 SUPERIOR COURT OF THE STATE OF CALIFORNIA
12 IN AND FOR THE COUNTY OF PLACER
13 PACIFIC UNION INTERNATIONAL, Case No.: S-CV-0042080
INC.,
14 NOTICE TO CALL ADVERSE PARTY
Plaintiffs, AND AFFILIATED NON-PARTY
15 v. WITNESSES TO TESTIFY PURSUANT
TO EVIDENCE CODE § 776; AND IN
16 ERIK LUDWICK, an individual AND LIEU OF SUBPOENA (CCP § 1987(b), (c))
Settlor of The Anything Trust dated October
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12,2007; THE ANYTHING TRUST
18 DATED OCTOBER 12, 2007; PAUL D.
BOOTH, in his capacity as Trustee of The [Unlimited Civil Case]
19 Anything Trust Dated October 12, 2007; and
Does 1 through 50, inclusive.
20 Trial: August 8, 2022
Defendants.
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Notice to Call Adverse Party and Affiliated Non-party Witnesses to Testify
Pursuant to Evidence Code § 776; and in Lieu of Subpoena (Ccp § 1987(b), (C))
TO THE COURT, ALL PARTIES AND THEIR COUNSEL OF RECORD:
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3 GIVE NOTICE that, pursuant to Evidence Code § 776 to call an treat adverse parties
4 and/or non-party witnesses who have a mutuality of interest with an adverse party; and,
5 pursuant to Code of Civil Procedure § 1987 to appear in lieu of subpoena whether appearing in
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person or remotely, Defendants hereby demand that Plaintiff’s witnesses as identified below if
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call to testify by Defendants at trial in the above-referenced matter, whether during cross-
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examination and/or if called during Defendants case in chief are identified as adverse witnesses
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10 whom may at any and/or all times be questioned by and/or with leading questions.
200 Auburn Folsom Road, Suite 305, Auburn, CA 95603
11 Said adverse witnesses are informed and given notice of that they may be called to
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Tel (530)823-9736, Fax (530) 823-5241
testify at trial which is presently scheduled to commence on August 8, 2022, at or about 9:00
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a.m. in the above-entitled court, located at 10820 Justice Center Drive Roseville, CA 95678
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This request is made pursuant to Code of Civil Procedure § 1987(b), which provides that
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“[t]he giving of the notice shall have the same effect as service of a subpoena on the witness,
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and the parties shall have those rights and the court may make those orders, including the
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18 imposition of sanctions, as in the case of a subpoena for attendance before the court.” The
19 adverse witnesses are as follows:
20 Madison Hildebrand Representative of Terra Coastal escrow
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Cynthia Schmon Paul D. Booth
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Sarah Kosasky Erik Ludwick
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Gina Kirkpatrick Sonja Ludwick
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25 Jennifer Chrisman Nick Segal
26 Tony Antoci Patrick Barber
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Defendants Opposition to PUI’s Motion in Limine No. 3
NOTICE IS FURTHER GIVEN that, pursuant to Code of Civil Procedure § 1987(c),
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2 that if the witness is requested to produce documents and/or materials and things, that are within
3 witness’ possession, or under the custody or control of any of such agents, representatives,
4 and/or attorneys:
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Dated August 4, 2022 Respectfully submitted,
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MICHAEL AJ NANGANO,
8 A LAW CORPORATION
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By:_______________________________
200 Auburn Folsom Road, Suite 305, Auburn, CA 95603
11 MICHAEL AJ NANGANO
12 Attorney for Defendants
Tel (530)823-9736, Fax (530) 823-5241
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Defendants Opposition to PUI’s Motion in Limine No. 3
1 Case Name: PUI v. ERIK LUDWICK et al.
2 Case Number: S-CV-0042080
3 PROOF OF SERVICE
4 I, the undersigned, declare as follows:
I am a citizen of the United States, over the age of eighteen years, and not a party to the
5 within action. My business address is 200 Auburn Folsom Road, Suite 305, Auburn, California
95603.
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7 On August 5, 2022, I served a copy of the within document(s):
8 NOTICE TO CALL ADVERSE PARTY AND AFFILIATED NON-PARTY
WITNESSES TO TESTIFY PURSUANT TO EVIDENCE CODE § 776; AND IN LIEU
9 OF SUBPOENA (CCP § 1987(b), (c))
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in the above-entitled action by:
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ELECTRONIC SERVICE: I caused the document(s) to be sent to the person(s) at the
12 electronic notification address(es) listed below and in accordance with amended CA Civ
Pro Code § 1010.6(e)(1)-(2). If, within a reasonable time, the transmission was reported as
13 complete and without error, service will be deemed effectively delivered and received
pursuant to CA Civ Pro Code § 1010.6(a)(4)-(5).
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15 Shannon B. Jones, Esq. Email:
Lindsey Morgan, Esq. sbjlg@sbj-law.com
16 SHANNON B. JONES LAW GROUP, INC. sbj@sbj-law.com
lam@sbj-law.com
208 W. El Pintado Road
17 Danville, CA 94526
Attorneys for Plaintiff
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19 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct. Executed this 5th day of August, 2022, at Auburn, California.
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_______________________________
22 Lorien Melton
lmelton@asilaw.org
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Proof of Service
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1 MICHAEL A.J. NANGANO, CSB #133999 mnangano@lacounsel.com 2 Michael AJ Nangano, A Law Corporation 133 N Altadena Dr, Ste 403 3 Pasadena, California 91107 Telephone: (626) 796-9998 4 Fax: (626) 796-9992 5 LAWRENCE E. SKIDMORE, CSB #137587 lskidmore@asilaw.org 6 ARONOWITZ SKIDMORE LYON A Professional Law Corporation 7 200 Auburn Folsom Road, Suite 305 Auburn, California 95603 8 Telephone: (530) 823-9736 Fax: (530) 823-5241 9 Attorneys for Defendants 10 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 IN AND FOR THE COUNTY OF PLACER 13 PACIFIC UNION INTERNATIONAL, Case No.: S-CV-0042080 INC., 14 NOTICE TO CALL ADVERSE PARTY Plaintiffs, AND AFFILIATED NON-PARTY 15 v. WITNESSES TO TESTIFY PURSUANT TO EVIDENCE CODE § 776; AND IN 16 ERIK LUDWICK, an individual AND LIEU OF SUBPOENA (CCP § 1987(b), (c)) Settlor of The Anything Trust dated October 17 12,2007; THE ANYTHING TRUST 18 DATED OCTOBER 12, 2007; PAUL D. BOOTH, in his capacity as Trustee of The [Unlimited Civil Case] 19 Anything Trust Dated October 12, 2007; and Does 1 through 50, inclusive. 20 Trial: August 8, 2022 Defendants. 21 22 23 24 25 26 27 28 1 Notice to Call Adverse Party and Affiliated Non-party Witnesses to Testify Pursuant to Evidence Code § 776; and in Lieu of Subpoena (Ccp § 1987(b), (C)) TO THE COURT, ALL PARTIES AND THEIR COUNSEL OF RECORD: 1 2 3 GIVE NOTICE that, pursuant to Evidence Code § 776 to call an treat adverse parties 4 and/or non-party witnesses who have a mutuality of interest with an adverse party; and, 5 pursuant to Code of Civil Procedure § 1987 to appear in lieu of subpoena whether appearing in 6 person or remotely, Defendants hereby demand that Plaintiff’s witnesses as identified below if 7 call to testify by Defendants at trial in the above-referenced matter, whether during cross- 8 examination and/or if called during Defendants case in chief are identified as adverse witnesses 9 10 whom may at any and/or all times be questioned by and/or with leading questions. 200 Auburn Folsom Road, Suite 305, Auburn, CA 95603 11 Said adverse witnesses are informed and given notice of that they may be called to 12 Tel (530)823-9736, Fax (530) 823-5241 testify at trial which is presently scheduled to commence on August 8, 2022, at or about 9:00 13 a.m. in the above-entitled court, located at 10820 Justice Center Drive Roseville, CA 95678 14 This request is made pursuant to Code of Civil Procedure § 1987(b), which provides that 15 “[t]he giving of the notice shall have the same effect as service of a subpoena on the witness, 16 and the parties shall have those rights and the court may make those orders, including the 17 18 imposition of sanctions, as in the case of a subpoena for attendance before the court.” The 19 adverse witnesses are as follows: 20 Madison Hildebrand Representative of Terra Coastal escrow 21 Cynthia Schmon Paul D. Booth 22 Sarah Kosasky Erik Ludwick 23 Gina Kirkpatrick Sonja Ludwick 24 25 Jennifer Chrisman Nick Segal 26 Tony Antoci Patrick Barber 27 28 2 Defendants Opposition to PUI’s Motion in Limine No. 3 NOTICE IS FURTHER GIVEN that, pursuant to Code of Civil Procedure § 1987(c), 1 2 that if the witness is requested to produce documents and/or materials and things, that are within 3 witness’ possession, or under the custody or control of any of such agents, representatives, 4 and/or attorneys: 5 6 Dated August 4, 2022 Respectfully submitted, 7 MICHAEL AJ NANGANO, 8 A LAW CORPORATION 9 10 By:_______________________________ 200 Auburn Folsom Road, Suite 305, Auburn, CA 95603 11 MICHAEL AJ NANGANO 12 Attorney for Defendants Tel (530)823-9736, Fax (530) 823-5241 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 Defendants Opposition to PUI’s Motion in Limine No. 3 1 Case Name: PUI v. ERIK LUDWICK et al. 2 Case Number: S-CV-0042080 3 PROOF OF SERVICE 4 I, the undersigned, declare as follows: I am a citizen of the United States, over the age of eighteen years, and not a party to the 5 within action. My business address is 200 Auburn Folsom Road, Suite 305, Auburn, California 95603. 6 7 On August 5, 2022, I served a copy of the within document(s): 8 NOTICE TO CALL ADVERSE PARTY AND AFFILIATED NON-PARTY WITNESSES TO TESTIFY PURSUANT TO EVIDENCE CODE § 776; AND IN LIEU 9 OF SUBPOENA (CCP § 1987(b), (c)) 10 in the above-entitled action by: 11 ELECTRONIC SERVICE: I caused the document(s) to be sent to the person(s) at the 12 electronic notification address(es) listed below and in accordance with amended CA Civ Pro Code § 1010.6(e)(1)-(2). If, within a reasonable time, the transmission was reported as 13 complete and without error, service will be deemed effectively delivered and received pursuant to CA Civ Pro Code § 1010.6(a)(4)-(5). 14 15 Shannon B. Jones, Esq. Email: Lindsey Morgan, Esq. sbjlg@sbj-law.com 16 SHANNON B. JONES LAW GROUP, INC. sbj@sbj-law.com lam@sbj-law.com 208 W. El Pintado Road 17 Danville, CA 94526 Attorneys for Plaintiff 18 19 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 5th day of August, 2022, at Auburn, California. 20 21 _______________________________ 22 Lorien Melton lmelton@asilaw.org 23 24 25 26 27 28 Proof of Service