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
TELEPHONE NO: (925) 837-2317 FAX NO. (Optional): (925) 837-483 1
EMAIL ADDRESS (Optional): shj @sbj-law.com; lam@sbj-law.com
ATTORNEY FOR (Name): Plaintiff Pacific Union International, Inc.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER SURE F A L i Db ORNIA
street aporess: 1 (820 Justice Center Drive RGOUNTY OF PLACER
MAILING ADDRESS:
CITY AND ZIP CODE: Roseville, CA 95678 JUN 14 2019 OR
BRANCH NAME: Bill Santucci Justice Center JAKE CHATTERS
EXECUTIVE OFFICER & CLERK
PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. By: C. Vallan-Brown, Deputy
DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE [__] LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less) Be OU2080
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: July 2, 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.
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):
c. L_] The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of case in complaint LC] cross-complaint (Describe, including causes of action):
See Attachment 1
Page 1 of §
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California CASE MA NAG EMENT STATEM E NT rules 3.720-3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
LexisNexis® Automated California Judicial Council Forms
CM-110
|__ PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. CASE NUMBER:
DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. SCV0042080
4. b. Providea brief statement of the case, including any damages. (If 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 eamings. 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.
L (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 a jury trial L_ ja nonjury trial. (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 [__] 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) [__] 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.
CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page
2 of §
LexisNexis® Automated California Judicial Council Forms
CM-110
|. PLAINTIFFIPETITIONER: PACIFIC UNION INTERNATIONAL, INC, [© SoMBER
DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. scvoranse
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
UUUU;UUUU;UUUOU;OUUUU;UUUU;O00O
Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
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
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
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):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
LexisNexis® Automated California Judicial Council Forms
CM-110
| __ PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. ane Ete
DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. SCV0042080
11. Insurance
a. L__] Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: L_] Yes [-_]No
ec L_] 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 [__] 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 [_] coordinate will be filed by (name party):
14. Bifurcation
L__} 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
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. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Pacific Union International Written discovery In Progress
Pacific Union International Deposition discovery In Progress
Pacific Union International Expert discovery Per Code
c. [__]| The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rew uty 1, 2011] CASE MANAGEMENT STATEMENT reacts
LexisNexis® Automated California Judicial Council Forms
PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. CASE NUMBER:
CM-110
DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al, SOMO=ZOS0
17. Economic litigation
a.L_] This is a limited civil case (i.e., the amount demandedis $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, e xplain specifically why economic litigation procedur
es relating to discovery or trial
should not apply to this case):
18. Other issues
L__] 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. 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: June 12, 2019
SHANNON B. JONES
(TYPE OR PRINT NAME) ( oy OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
[__] Additional signatures are attached.
CM-190 Rev. Jy 1, 2041) CASE MANAGEMENT STATEMENT Page Sof 5
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
6/17/19 Hearing; 6/18/19 Mediation; 6/19/19 Seminar; 6/20/19 Vacation; 6/25/19
Mediation; 6/26/19 Mediation; 6/28/19 Meeting; 7/2/19 Mediation 7/3/19-7/5/19 Vacation;
7/10/19 Settlement Conference; 7/10/19 Mediation; 7/17/19-7/18/19 Vacation; 7/19/19
Mediation; 7/22/19 Seminar; 7/23/19 Hearing; 7/24/19 Vacation; 7/29/19 Hearing; 7/30/19
Mediation; 7/31/19 Mediation; 8/2/19 Trial Conference; 8/2/19 Hearing; 8/5/19-8/12/19
Trial; 8/9/19 Settlement Conference; 8/13/19-8/16/19 Arbitration; 8/19/19 Settlement
Conference; 8/20/19 Mediation; 8/21/19 Issue Conference; 8/22/19 Mediation;
9/3/19-9/17/19 Trial; 9/5/19 Hearing; 9/10/19 Conference; 9/11/19 Seminar; 9/17/19
Mediation; 9/18/19 Seminar; 9/19/19 Settlement Conference; 9/23/19 to 10/4/19 Trial;
9/26/19 to 9/27/19 Meetings; 9/27/19 Trial Conference; 9/30/19-10/11/19 Trial; 10/2/19
Seminar; 10/7/19-10/18/19 Trial; 10/7/19-10/21/19 Trial; 10/8/19 Settlement Conference;
10/16/19 Seminar; 10/16/19 Settlement Conference: 10/17/19 Trial Conference; 10/21/19
Seminar; 10/21/19 Settlement Conference; 10/21/19—11/1/19 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; 2/3/20-2/14/20 Trial; 2/1 1/20-2/21/20 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; 4/9/20
Conference: 5/7/20 Conference; 5/11/20 - 5/22/20 Trial; 1/25/21-2/5/21 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 June 12, 2019, I served the within document(s):
CASE MANAGEMENT STATEMENT
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.
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 June 12, 2019, at Danville, California.
18 Xx
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LAMIDA
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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 TELEPHONE NO: (925) 837-2317 FAX NO. (Optional): (925) 837-483 1 EMAIL ADDRESS (Optional): shj @sbj-law.com; lam@sbj-law.com ATTORNEY FOR (Name): Plaintiff Pacific Union International, Inc. SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER SURE F A L i Db ORNIA street aporess: 1 (820 Justice Center Drive RGOUNTY OF PLACER MAILING ADDRESS: CITY AND ZIP CODE: Roseville, CA 95678 JUN 14 2019 OR BRANCH NAME: Bill Santucci Justice Center JAKE CHATTERS EXECUTIVE OFFICER & CLERK PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. By: C. Vallan-Brown, Deputy DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE [__] LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) Be OU2080 A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: July 2, 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. 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): c. L_] The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type of case in complaint LC] cross-complaint (Describe, including causes of action): See Attachment 1 Page 1 of § Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MA NAG EMENT STATEM E NT rules 3.720-3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov LexisNexis® Automated California Judicial Council Forms CM-110 |__ PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. CASE NUMBER: DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. SCV0042080 4. b. Providea brief statement of the case, including any damages. (If 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 eamings. 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. L (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 a jury trial L_ ja nonjury trial. (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 [__] 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) [__] 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. CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 of § LexisNexis® Automated California Judicial Council Forms CM-110 |. PLAINTIFFIPETITIONER: PACIFIC UNION INTERNATIONAL, INC, [© SoMBER DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. scvoranse 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 UUUU;UUUU;UUUOU;OUUUU;UUUU;O00O Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): 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 (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): 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): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT LexisNexis® Automated California Judicial Council Forms CM-110 | __ PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. ane Ete DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al. SCV0042080 11. Insurance a. L__] Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: L_] Yes [-_]No ec L_] 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 [__] 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 [_] coordinate will be filed by (name party): 14. Bifurcation L__} 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 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. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Pacific Union International Written discovery In Progress Pacific Union International Deposition discovery In Progress Pacific Union International Expert discovery Per Code c. [__]| The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rew uty 1, 2011] CASE MANAGEMENT STATEMENT reacts LexisNexis® Automated California Judicial Council Forms PLAINTIFF/PETITIONER: PACIFIC UNION INTERNATIONAL, INC. CASE NUMBER: CM-110 DEFENDANT/RESPONDENT: ERIK LUDWICK, an individual, et al, SOMO=ZOS0 17. Economic litigation a.L_] This is a limited civil case (i.e., the amount demandedis $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, e xplain specifically why economic litigation procedur es relating to discovery or trial should not apply to this case): 18. Other issues L__] 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. 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: June 12, 2019 SHANNON B. JONES (TYPE OR PRINT NAME) ( oy OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) [__] Additional signatures are attached. CM-190 Rev. Jy 1, 2041) CASE MANAGEMENT STATEMENT Page Sof 5 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 6/17/19 Hearing; 6/18/19 Mediation; 6/19/19 Seminar; 6/20/19 Vacation; 6/25/19 Mediation; 6/26/19 Mediation; 6/28/19 Meeting; 7/2/19 Mediation 7/3/19-7/5/19 Vacation; 7/10/19 Settlement Conference; 7/10/19 Mediation; 7/17/19-7/18/19 Vacation; 7/19/19 Mediation; 7/22/19 Seminar; 7/23/19 Hearing; 7/24/19 Vacation; 7/29/19 Hearing; 7/30/19 Mediation; 7/31/19 Mediation; 8/2/19 Trial Conference; 8/2/19 Hearing; 8/5/19-8/12/19 Trial; 8/9/19 Settlement Conference; 8/13/19-8/16/19 Arbitration; 8/19/19 Settlement Conference; 8/20/19 Mediation; 8/21/19 Issue Conference; 8/22/19 Mediation; 9/3/19-9/17/19 Trial; 9/5/19 Hearing; 9/10/19 Conference; 9/11/19 Seminar; 9/17/19 Mediation; 9/18/19 Seminar; 9/19/19 Settlement Conference; 9/23/19 to 10/4/19 Trial; 9/26/19 to 9/27/19 Meetings; 9/27/19 Trial Conference; 9/30/19-10/11/19 Trial; 10/2/19 Seminar; 10/7/19-10/18/19 Trial; 10/7/19-10/21/19 Trial; 10/8/19 Settlement Conference; 10/16/19 Seminar; 10/16/19 Settlement Conference: 10/17/19 Trial Conference; 10/21/19 Seminar; 10/21/19 Settlement Conference; 10/21/19—11/1/19 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; 2/3/20-2/14/20 Trial; 2/1 1/20-2/21/20 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; 4/9/20 Conference: 5/7/20 Conference; 5/11/20 - 5/22/20 Trial; 1/25/21-2/5/21 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 June 12, 2019, I served the within document(s): CASE MANAGEMENT STATEMENT 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. 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 June 12, 2019, at Danville, California. 18 Xx 19 LAMIDA 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE — CASE MANAGEMENT STATEMENT