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SUPERIOR COURT OF THE STATE OF CALIFORNIA
yo IN AND FOR THE COUNTY OF PLACER
ec
it We ae i ie? Physical
Address:
Pah 3 nite ~E MailingAddress:
10820Justice
Center Drive PO Box 619072
Roseville,
CA 95678 Roseville,
CA 95661
06/18/2019
Michael Nangano
133 N Altadena Dr Ste 403
Pasadena CA 91107
Re: Pacific Union International, Inc. vs. Ludwick, Erik et al S-CV-0042080
DOCUMENT:
L] Complaint/Petition/Cross-Complaint/Amended LJ Answer/Responsive
L) Default LI Notice of Deposit of Jury Fees
2 MotionYOSC/Demurrer LI Proof of Service
CJ Judgment/Order CJ Request for Dismissal
C) Request for Trial Setting (UD) C1 Notice of Entry of Dismissal
C1 Abstract/Writ C1 Substitution of Attorney
C1 Notice of Unavailability of Counsel C1 Other:
LJ]Check # for $
YOUR PAPERS WERE NOT FILED; REASONS FOR REJECTION:
XI No filing fee/incorrect filing fee was tendered. The correct filing fee is$60.00 0) per person.
C1 Proof of service must include a cover page with the case name, case number and name of the
party filing the proof of service.
L] Incorrect case number listed
LI]No case number listed.
L] Papers were submitted to the wrong county.
CL]No signature on papers.
CINo original signature on papers and papers are not marked as filed by facsimile or electronic
filing.
C1]Conformed copy of Request for Entry of Dismissal must be attached to Notice of Entry of
Dismissal.
L] Your papers do not comply with CRC §3.250.
L] First pages of papers must include all the information required by CRC §2.111(1), including
the name, address, bar number (if applicable), telephone number, and fax number and email
address (ifavailable) of the attorney or party presenting the papers.
C1 Your papers are not inproper filing format . CRC §2.118(a) and §2.100-2.117.
O Per Local Rule 10.9s, when submitting a Writ of Execution or Abstract of Judgment, a copy of
the Judgment must be submitted.
C Must answer as named in complaint/cross-complaint
C1 Your name and/or law office does not appear as the Attorney of Record.
CO Per CRC §3.250(a)(21) Notice of Deposit of Jury Fees are not to be filed with the Court.
CJ Notices of Unavailability (AKA Tenderloin Notices) for civil filing are no longer accepted.
Carl v.Superior Court (Coast Community College Dist.) (2007) 157 Cal. App. 4ih73.
OTHER: No reservation date for the Motion. And an additional 60.00 is required.
Documents were placed in pick-up basket at the Historic Courthouse as no envelope was
provided (Local Rule 10.9(N).
1 Documents were placed in pick-up basket at the Gibson Courthouse as no envelope was
provided (Local Rule 10.9(N).
Documents were placed in pick-up basket at the Tahoe Courthouse as no envelope was
provided (Local Rule 10.9(N).
C1 You may wish to obtain information from the law library or from an attorney or other
professional.
Jake Chatters,
Clerk of the Superior Court
i/ Lund 4 by
R. Brown, Deputy Clerk
Lawrence E. Skidmore (SBN 137587)
ARONOWITZ SKIDMORE LYON
A PROFESSIONAL CORPORATION
PO
200 Auburn Folsom Road, Suite 305
Auburn, CA 95603
WH
Telephone: 530-823-9736
Facsimile: 530-823-5241
B®
MICHAEL A.J. NANGANO (SBN 133999)
NH
MICHAEL AJ NANGANO, A LAW CORPORATION
133 No. Altadena Drive, Suite 403
DWN
Pasadena, CA 91107
Phone: (626) 796-9998
SI
Fax: (626) 796-9992
Oo
Attorneys for Defendant(s)
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KF HBO
SUPERIOR COURT OF THE STATE OF CALIFORNIA
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WH
IN AND FOR THE COUNTY OF PLACER
BR NH
meme
pce IC UNION INTERNATIONAL, Case No. S-CV 0042080
WD
INC.,
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Plaintiff, ) DEFENDANTS’ NOTICE OF MOTION
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) AND MOTION TO COMPEL FURTHER
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vs. ) ANSWERS TO REQUEST FOR
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) ADMISSIONS
ERIK LUDWICK, an individual AND )
Settlor of The Anything Trust dated October ) Hearing Date: July 11, 20019
DD
RO
12, 2007; THE ANYTHING TRUST ) Dept.: 42
DATED OCTOBER 12, 2007; PAUL D. ) Time: 8:30 a.m.
—|§—
DN
BOOTH, in his capacity as Trustee of The ) Trial Date: None Set
Anything Trust Dated October 12,2007; and )_ Filed: November 7, 2018
NHN
HN
Does 1 through 50, inclusive, )
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Defendants. )
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Notice of Motion
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
Ke
PLEASE TAKE NOTICE that on July 11, 2019. at 8:30 a.m. or as soon thereafter as
LO
the matter may be heard in 42 of this Court, located at the Bill Santucci Justice Center,
WD
10820 Justice Center Drive, Roseville, California, Defendants will move the Court for
FR
an
order compelling Plaintiff, Pacific Union International, Inc. to provide further answers to
OH
the Requests for Admissions set forth in the Statement of Requests and Responses in
DN
Dispute filed with this motion.
SN
This motion is made on the ground that the interrogatories
Oo
are relevant to the subject
matter of the action and Plaintiffs refusal to answer or giving and incomplete answer is
So
without substantial justification. The motion will be based upon this notice, and also on the
BS
ltl
Defendants' Motion in Support of Motion to Compel Further Responses to Request for
Admissions, Set One and Defendants’ Separate Statement in Support of Motion to Compel
BP
Further Responses to Requests for Admissions, Set One and the Declaration of Michael AJ
RD
Nangano in Support of Motions to Compel Further Responses to Discovery filed June 13,
mm
2019 and the records and files in this action and on such evidence as may be presented at the
WADA
hearing of the motion.
HA
"Pursuant to Local Rule 20.2.3, the court will issue a tentative ruling for
this matter on the court day before the hearing. The tentative ruling will
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be available after 12:00 noon as an audio recording accessible at (916)
©
SG
408-6480; the tentative ruling will also be available atthe court's website,
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www.placer.courts.ca.gov. The tentative ruling shall become the final
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ruling on the matter and no hearing will be held unless oral argument is
NY
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timely requested or the tentative ruling indicates otherwise. Requests for
BW
NNO
oral argument must be made by calling (530) 584-3463 no laterthan 4:00
B®
NO
p.m. on the court day prior to the hearing."
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Notice of Motion
——
we Dated: June 13, 2019
MICHAEL
pO
A.J. NANGANO,
WwW
A LAW CORPORATION
BP
DWN
IC LAJ.N O
Attorneys for Defendants
Facsimile signature as original
ON
Pursuant to C.R.C. Rule 2.305(d)
So
xe
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®atnteRSRBPYSSRSRABGEBE
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NY
NY
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Notice of Motion
ND PROOF OF SERVICE
Iam employed in the County of Los Angeles, State of California.
and not
Lam over the age of 18
a party to the within action. My business address is 133 N. Altadena
W
Drive, Suite 403,
Pasadena, CA 91107.
On June 14, 2019. I served the following document(s) described as:
NOTICE OF MOTION TO COMPEL FURTHER RESPONSE TO REQUEST FOR
ADMISSIONS, SET ONE
on allinterested parties in this action by placing [X]atrue copy [ ] the original
in sealed
thereof enclosed
envelopes addressed as follows:
SEE ATTACHED MAILING LIST
[ ] (BY FACSIMILE) The facsimile machine Iused complied with Rule 2003(3) and no error
10 was reported by the machine. Pursuant to Rule 2008(e)(4), I caused the machine to print a
record of the transmission.
ll
[x] (BY MAIL, 1013a, 2015.5 C.C.P.) Iam readily familiar with the firm’s practice for
12 collection and processing correspondence for mailing. Under that practice, this document
will be deposited with the U.S. Postal Service on this date with postage thereon fully prepaid
13 at Los Angeles, California in the ordinary course of business. I am aware that on motion of
the party served, service is presumed invalid ifpostal cancellation date or postage meter date
is more than one day afier date of deposit for mailing in affidavit.
15 [] (BY OVERNIGHT DELIVERY/COURIER) I served the above referenced document(s)
enclosed in a sealed package, forcollection and for delivery marked for next day delivery in
16 the ordinary course of business, addressed to the office of the addressee(s) listed above or on
attached sheet.
17
(] (BY E-MAIL) I transmitted a copy of the foregoing document(s) via e-mail to the
18 addressee(s). Courtesy copy
[X]_ (STATE) Ideclare under penalty of perjury under the laws of the State of California that the
above is true and correct.
20
Executed on June 14, 2019, at Pasadena, California.
21
Th?
\RatrieraM. Poole
23
24 Facsimile signature as original
Pursuant to C.R.C. Rule 2.305(d)
25
26
28
1
PROOF OF SERVICE
1 MAILING LIST
Pacific Union International. Inc. v. Ludwick. et al.
ND
Case No. SCV0042080
W
Shannon B. Jones, Esq.
&
Lindsey Morgan, Esq.
Shannon B. Jones Law Group, Inc.
Ww
208 W. El Pintado Road
NON
Danville, CA 94526
~~
10
LL
12
13
14
15
16
17
18
19
20
ZA.
22
23
24
25
26
27
28
2
PROOF OF SERVICE
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Preview
SUPERIOR COURT OF THE STATE OF CALIFORNIA yo IN AND FOR THE COUNTY OF PLACER ec it We ae i ie? Physical Address: Pah 3 nite ~E MailingAddress: 10820Justice Center Drive PO Box 619072 Roseville, CA 95678 Roseville, CA 95661 06/18/2019 Michael Nangano 133 N Altadena Dr Ste 403 Pasadena CA 91107 Re: Pacific Union International, Inc. vs. Ludwick, Erik et al S-CV-0042080 DOCUMENT: L] Complaint/Petition/Cross-Complaint/Amended LJ Answer/Responsive L) Default LI Notice of Deposit of Jury Fees 2 MotionYOSC/Demurrer LI Proof of Service CJ Judgment/Order CJ Request for Dismissal C) Request for Trial Setting (UD) C1 Notice of Entry of Dismissal C1 Abstract/Writ C1 Substitution of Attorney C1 Notice of Unavailability of Counsel C1 Other: LJ]Check # for $ YOUR PAPERS WERE NOT FILED; REASONS FOR REJECTION: XI No filing fee/incorrect filing fee was tendered. The correct filing fee is$60.00 0) per person. C1 Proof of service must include a cover page with the case name, case number and name of the party filing the proof of service. L] Incorrect case number listed LI]No case number listed. L] Papers were submitted to the wrong county. CL]No signature on papers. CINo original signature on papers and papers are not marked as filed by facsimile or electronic filing. C1]Conformed copy of Request for Entry of Dismissal must be attached to Notice of Entry of Dismissal. L] Your papers do not comply with CRC §3.250. L] First pages of papers must include all the information required by CRC §2.111(1), including the name, address, bar number (if applicable), telephone number, and fax number and email address (ifavailable) of the attorney or party presenting the papers. C1 Your papers are not inproper filing format . CRC §2.118(a) and §2.100-2.117. O Per Local Rule 10.9s, when submitting a Writ of Execution or Abstract of Judgment, a copy of the Judgment must be submitted. C Must answer as named in complaint/cross-complaint C1 Your name and/or law office does not appear as the Attorney of Record. CO Per CRC §3.250(a)(21) Notice of Deposit of Jury Fees are not to be filed with the Court. CJ Notices of Unavailability (AKA Tenderloin Notices) for civil filing are no longer accepted. Carl v.Superior Court (Coast Community College Dist.) (2007) 157 Cal. App. 4ih73. OTHER: No reservation date for the Motion. And an additional 60.00 is required. Documents were placed in pick-up basket at the Historic Courthouse as no envelope was provided (Local Rule 10.9(N). 1 Documents were placed in pick-up basket at the Gibson Courthouse as no envelope was provided (Local Rule 10.9(N). Documents were placed in pick-up basket at the Tahoe Courthouse as no envelope was provided (Local Rule 10.9(N). C1 You may wish to obtain information from the law library or from an attorney or other professional. Jake Chatters, Clerk of the Superior Court i/ Lund 4 by R. Brown, Deputy Clerk Lawrence E. Skidmore (SBN 137587) ARONOWITZ SKIDMORE LYON A PROFESSIONAL CORPORATION PO 200 Auburn Folsom Road, Suite 305 Auburn, CA 95603 WH Telephone: 530-823-9736 Facsimile: 530-823-5241 B® MICHAEL A.J. NANGANO (SBN 133999) NH MICHAEL AJ NANGANO, A LAW CORPORATION 133 No. Altadena Drive, Suite 403 DWN Pasadena, CA 91107 Phone: (626) 796-9998 SI Fax: (626) 796-9992 Oo Attorneys for Defendant(s) COoOo le KF HBO SUPERIOR COURT OF THE STATE OF CALIFORNIA mmm WH IN AND FOR THE COUNTY OF PLACER BR NH meme pce IC UNION INTERNATIONAL, Case No. S-CV 0042080 WD INC., ) HQ Plaintiff, ) DEFENDANTS’ NOTICE OF MOTION www ) AND MOTION TO COMPEL FURTHER wo vs. ) ANSWERS TO REQUEST FOR ODO ) ADMISSIONS ERIK LUDWICK, an individual AND ) Settlor of The Anything Trust dated October ) Hearing Date: July 11, 20019 DD RO 12, 2007; THE ANYTHING TRUST ) Dept.: 42 DATED OCTOBER 12, 2007; PAUL D. ) Time: 8:30 a.m. —|§— DN BOOTH, in his capacity as Trustee of The ) Trial Date: None Set Anything Trust Dated October 12,2007; and )_ Filed: November 7, 2018 NHN HN Does 1 through 50, inclusive, ) ) Ww NO ) Defendants. ) Fe HPO ) ) NW NO ) NO NN NO ao NO ] Notice of Motion TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: Ke PLEASE TAKE NOTICE that on July 11, 2019. at 8:30 a.m. or as soon thereafter as LO the matter may be heard in 42 of this Court, located at the Bill Santucci Justice Center, WD 10820 Justice Center Drive, Roseville, California, Defendants will move the Court for FR an order compelling Plaintiff, Pacific Union International, Inc. to provide further answers to OH the Requests for Admissions set forth in the Statement of Requests and Responses in DN Dispute filed with this motion. SN This motion is made on the ground that the interrogatories Oo are relevant to the subject matter of the action and Plaintiffs refusal to answer or giving and incomplete answer is So without substantial justification. The motion will be based upon this notice, and also on the BS ltl Defendants' Motion in Support of Motion to Compel Further Responses to Request for Admissions, Set One and Defendants’ Separate Statement in Support of Motion to Compel BP Further Responses to Requests for Admissions, Set One and the Declaration of Michael AJ RD Nangano in Support of Motions to Compel Further Responses to Discovery filed June 13, mm 2019 and the records and files in this action and on such evidence as may be presented at the WADA hearing of the motion. HA "Pursuant to Local Rule 20.2.3, the court will issue a tentative ruling for this matter on the court day before the hearing. The tentative ruling will wm ww be available after 12:00 noon as an audio recording accessible at (916) © SG 408-6480; the tentative ruling will also be available atthe court's website, RO www.placer.courts.ca.gov. The tentative ruling shall become the final |= NO ruling on the matter and no hearing will be held unless oral argument is NY NN timely requested or the tentative ruling indicates otherwise. Requests for BW NNO oral argument must be made by calling (530) 584-3463 no laterthan 4:00 B® NO p.m. on the court day prior to the hearing." NPY KNAW \\ NHN \\ NYO oN \\\ Oo 2 Notice of Motion —— we Dated: June 13, 2019 MICHAEL pO A.J. NANGANO, WwW A LAW CORPORATION BP DWN IC LAJ.N O Attorneys for Defendants Facsimile signature as original ON Pursuant to C.R.C. Rule 2.305(d) So xe ea ea ®atnteRSRBPYSSRSRABGEBE Ne NY NY NO NHN NY NH 2x 3 Notice of Motion ND PROOF OF SERVICE Iam employed in the County of Los Angeles, State of California. and not Lam over the age of 18 a party to the within action. My business address is 133 N. Altadena W Drive, Suite 403, Pasadena, CA 91107. On June 14, 2019. I served the following document(s) described as: NOTICE OF MOTION TO COMPEL FURTHER RESPONSE TO REQUEST FOR ADMISSIONS, SET ONE on allinterested parties in this action by placing [X]atrue copy [ ] the original in sealed thereof enclosed envelopes addressed as follows: SEE ATTACHED MAILING LIST [ ] (BY FACSIMILE) The facsimile machine Iused complied with Rule 2003(3) and no error 10 was reported by the machine. Pursuant to Rule 2008(e)(4), I caused the machine to print a record of the transmission. ll [x] (BY MAIL, 1013a, 2015.5 C.C.P.) Iam readily familiar with the firm’s practice for 12 collection and processing correspondence for mailing. Under that practice, this document will be deposited with the U.S. Postal Service on this date with postage thereon fully prepaid 13 at Los Angeles, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid ifpostal cancellation date or postage meter date is more than one day afier date of deposit for mailing in affidavit. 15 [] (BY OVERNIGHT DELIVERY/COURIER) I served the above referenced document(s) enclosed in a sealed package, forcollection and for delivery marked for next day delivery in 16 the ordinary course of business, addressed to the office of the addressee(s) listed above or on attached sheet. 17 (] (BY E-MAIL) I transmitted a copy of the foregoing document(s) via e-mail to the 18 addressee(s). Courtesy copy [X]_ (STATE) Ideclare under penalty of perjury under the laws of the State of California that the above is true and correct. 20 Executed on June 14, 2019, at Pasadena, California. 21 Th? \RatrieraM. Poole 23 24 Facsimile signature as original Pursuant to C.R.C. Rule 2.305(d) 25 26 28 1 PROOF OF SERVICE 1 MAILING LIST Pacific Union International. Inc. v. Ludwick. et al. ND Case No. SCV0042080 W Shannon B. Jones, Esq. & Lindsey Morgan, Esq. Shannon B. Jones Law Group, Inc. Ww 208 W. El Pintado Road NON Danville, CA 94526 ~~ 10 LL 12 13 14 15 16 17 18 19 20 ZA. 22 23 24 25 26 27 28 2 PROOF OF SERVICE ee ee