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SHANNON B. JONES LAW GROUP, INC.
SHANNON B. JONES (Bar No. 149222)
sbj@sbj-law.com EFYTLen
a wis 3 Bice 5
LINDSEY A. MORGAN (Bar No. 274214) SUPERIOR COURT
COUNTY OF
OF CALIFORNIA
PLACER
lam@sbj-law.com
CED NA 9749
ALAN PALMER JACOBUS (Bar No. 206954) SEP 04 2Ui3
A
apj(@sbj-law.com JAKE CHAI ITERS
208 W. El Pintado Road
WN
EXECUTIVE OF! R & CLERK
Danville, California 94526 By: Nes Deputy
ND
Telephone: (925) 837-2317
Facsimile: (925) 837-4831
YN
Attorneys for Plaintiff
Oo
PACIFIC UNION INTERNATIONAL, INC.
0
10 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 IN AND FOR THE COUNTY OF PLACER
12 PACIFIC UNION INTERNATIONAL, INC., . No. SCV0042080
13 Plaintiff, ) DECLARATION OF SHANNON B.
14 y } JONES IN SUPPORT OF PLAINTIFF
) PACIFIC UNION INTERNATIONAL,
15 ERIK LUDWICK, an individual and ) INC.’S MOTION TO TRANSFER
beneficiary of The Anything Trust Dated ) ACTION FILED IN LOS ANGELES
16 October 12, 2007; THE ANYTHING TRUST ) SUPERIOR COURT TO THIS COURT
DATED OCTOBER 12, 2007; PAUL D. ) AND TO CONSOLID ATE, OR
17 nay eee te Seah and ALTERNATIVELY COORDINATE, THE
18 DOES 1-50, coe ) LOS ANGELES ACTION WITH THE
) PLACER COUNTY ACTION
19 Defendants. )
) Date: October 3, 2019
20 ) Time: 8:30 a.m.
Dept: 42
21
22 Complaint Filed: November 7, 2018
) Trial Date: None Set
23
24 I, Shannon B. Jones, declare:
25 1. I am an attorney licensed to practice in the State of California and am the
26 managing partner at the Shannon B. Jones Law Group, Inc., counsel of record in this action for
27 Plaintiff Pacific Union International, Inc. (“Pacific Union”). By virtue of my firm’s
28 representation of Pacific Union, I have personal knowledge of the facts set forth in this
DECLARATION OF SHANNON B. JONES ISO MOTION TO TRANSFER AND CONSOLIDATE ACTIONS
declaration and ifcalled upon to testify, |could and would competently testify thereto, except as
i) to those matters stated upon information and belief and as to those matters, Iam informed and
believe them to be true.
2. This lawsuit arises out of a dispute over whether defendant Erik Ludwick
ma
owes plaintiff Pacific Union International, Inc. compensation under a Residential Listing
Ww
SYN
Agreement contract. The lawsuit that Mr. Ludwick
HD
has filed in Los Angeles Superior Court
(Erik Ludwick vs.Partners’ Trust Real Estate Brokerage & Acquisitions, et al., Los Angeles
County Superior Court number 19 STCV 25331 (the “Los Angeles Lawsuit”)) involves the same
dispute under the same contract.
Oo
10 3. On August 23, 2019, I sent to counsel for the parties in the Los Angeles
11 Lawsuit a letter explaining the grounds for transfer and consolidation and requesting their
agreement to the transfer and consolidation. A copy of the letter isattached to this declaration as
13 Exhibit A.
14 4. Counsel for Mr. Ludwick responded on August 28, 2019, and declined to
15 stipulate to transfer the Los Angeles Action. A true and correct copy of this correspondence is
16 attached hereto as Exhibit B.
17 5 My office notified all parties in this lawsuit and the Los Angeles Action of
18 their obligations to disclose to this Court any information they have concerning any other
19 motions requesting transfer of any case that would be affected by granting of the motion before
20 this Court by email on September 3, 2019. A true and correct copy of this communication is
21 attached hereto as Exhibit C.
I declare under the penalty of perjury under the laws of the State of California that
23 the foregoing istrue and correct.
24 vswe Q ‘ ; ‘
Executed this u day of pillars. 2019, at Danville, California.
25
26
27
SFR
Len
SHANNON B. JONES
28
2
DECLARATION OF SHANNON B.JONES ISO MOTION TO TRANSFER AND CONSOLIDATE ACTIONS
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
fb
94526. On September | ,2019, I served the within document(s):
WNW
DECLARATION OF SHANNON B. JONES IN SUPPORT PLAINTIFF PACIFIC UNION
DA
INTERNATIONAL, INC.’S MOTION TO TRANSFER ACTION FILED IN LOS
ANGELES SUPERIOR COURT TO THIS COURT AND TO CONSOLIDATE, OR
NY
ALTERNATIVELY COORDINATE, THE LOS ANGELES ACTION WITH THE
PLACER COUNTY ACTION
Oo
X___ by transmitting via email the above listed document(s) to the email address(es) set forth
0
below on this date before 5:00 p.m.
10
11 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.
12
Attorneys for Defendants Erik Ludwick, The Co-Counsel for Defendants Erik Ludwick, The
13 Anything Trust and Paul Booth as Trustee of Anything Trust and Paul Booth as Trustee of
the Anything Trust the Anything Trust
14
Lawrence E. Skidmore, Esq.
15 Michael A.J. Nangano, Esq. Aronowitz, Skidmore, Lyon
Franklin T. Bigelow, Esq. 200 Auburn Folsom Road, Suite 305
16 Law Offices of Michael A.J. Nangano Auburn, CA 95603
133 No. Altadena Drive, Suite 403 Tel: (530) 823-9736
l7 Pasadena, CA 91107 Fax: (530) 823-5241
Tel: (626) 796-9998 Iskidmore@asilaw.org
18
Fax: (626) 796-9992
19 mnangano@lacounsel.com
20 Civil Clerk
Los Angeles Superior Court
21 Stanley Mosk Courthouse
111 North Hill Street
22
Los Angeles, CA 90012
23
Ideclare under penalty of perjury under the laws of the State of California that the
24 above istrue and correct.
25 Executed on September «|, 2019, at Danville, California.
26
ar
if SALAMIDA
ubewh
28 \
\ /
f
f
‘ od
3
DECLARATION OF SHANNON B. JONES ISO MOTION TO TRANSFER AND CONSOLIDATE ACTIONS
Exhibit A
SHANNON B. JONES LAW GROUP, INC.
Writer’sDirectNo.: (925)837-2315
Writer'sDirectEmail: sbj@sbj-law.com
August 23, 2019
Via Email and U.S. Mail
mnangano@lacounsel.com
Michael A.J. Nangano, Esq.
A Law Corporation
133 North Altadena Drive, Suite 403
Pasadena, CA 91107
Re: Ludwick v.Partners Trust, et al.
Los Angeles Superior Court Case No. 19STCV25331
Dear Mr. Nangano:
We are inreceipt of the complaint you filed on behalf of Erik Ludwick in Los
Angeles Superior Court on July 19, 2019.
As acknowledged inthe textof the complaint, and as you know by virtue of your
representation of Mr. Ludwick in the existing action pending in the Superior Court of the State of
California, County of Placer, case number S-CV-0042080, an active lawsuit is pending arising
from the same transaction and facts.
Putting aside, for the moment, the other problems riddling Mr. Ludwick’s newly-
filed complaint, we write to ask whether you will stipulateto transfer and consolidate the
complaint you improperly filed from Los Angeles Superior Court to Placer Superior Court. If
you do not agree, we will prepare and filea motion to transfer on behalf of the defendants.
Very truly yours,
SHANNON B. JONES
SBJ:lam
Danville| 208W. El PintadoRoad, Danville,
CA 94526 - Tel:(925)837-2317 - Fax: (925)837-4831
Sacramento | 8880CalCenter Drive,Suite400,Sacramento,CA 95826 - Tel:(916)368-1000
San Jose| 111North MarketStreet,Suite300,San Jose,
CA 95113 - Tel:(408)363-3635
(Pleaserespond toDanvilleOffice)| www.calrealestatelaw.com
Exhibit B
MICHAEL A.J. NANGANO
A Law CORPORATION
133 NORTH ALTADENA DRIVE, SUITE 403
PASADENA, CA 91107
Tel.(626) 796-9998
Fax: (213) 232-3252
August 28, 2019
Via Email
Shannon B. Jones, Esq.
Shannon B. Jones Law Group, Inc.
208 W. El Pintado Road
Danville, CA 94526
Re: Pacific Union International, Inc. v. Ludwick, et al
Case No.SCV0042080 (in Placer County, Superior Court)
Dear Ms. Jones:
We are in receipt of your correspondence of August 23, 2019. We will not stipulate to
transfer and consolidate LASC Case No. 19STCV25331 with the current case pending in Placer
County. Venue is proper in Los Angeles for the case we filed as, forthat matter, with the case your
client chose to bring in Placer County. We will be moving in the near future to bring the Placer
County action to the venue itshould have been filed inthe firstplace, the Los Angeles Superior
Court.
Ifyou have any questions or comments, please do not hesitate to contact the undersigned. We
remain,
Very truly yours,
MALIA Michael AJ Nangano
MAJN:pmp
ce: Lindsey A. Morgan, Esq. (via email)
Lawrence E. Skidmore (via email)
Exhibit C
Lindsey Morgan
IS
From: Lindsey Morgan
Sent: Tuesday, September 3, 2019 5:29 PM
To: PattiPoole
Ce: mnangano@lacounsel.com; Lawrence Skidmore; Shannon B. Jones
Subject: RE: PacificUnion v. Ludwick
Thank you for your response.
Pursuant toCRC 3.500, please note that allparties have an obligation to disclose to the Court any information
concerning other motions requesting transfer of any case that would be affected by the granting ofthe motion before
the Court.
Thank you,
Lindsey A. Morgan
Shannon B.,
Jones Law Group, Inc.
Direct: (925) 837-5577 ext.317
lam@sbj-law.com
From: PattiPoole
Sent: Wednesday, August 28, 2019 2:05 PM
To: Shannon B.Jones
Cc: mnangano@lacounsel.com; Lawrence Skidmore ; Lindsey Morgan
Subject: PacificUnion v. Ludwick
Dear Counsel:
Please see Mike Nangano’s letterto you today.
Regards,
Patti Poole
Paralegal to Michael A.J. Nangano, Esq.
MICHAEL AJ NANGANO, A LAW CORPORATION
133 North Altadena Drive, Suite403
Pasadena, CA 91107
626/796-9998
213/232-3252 fax
Thise-mail may contain or attachprivileged,confidential
or protected informationintended only forthe use ofthe intended
recipient.
If youare not theintended recipient,
any review oruse of it is
strictly
prohibited.If youhave received thise-mailin error,
you are requiredto notifythe sender,then delete thisemailand any attachment from your computer and any of your electronic
deviceswhere the message isstored.
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SHANNON B. JONES LAW GROUP, INC. SHANNON B. JONES (Bar No. 149222) sbj@sbj-law.com EFYTLen a wis 3 Bice 5 LINDSEY A. MORGAN (Bar No. 274214) SUPERIOR COURT COUNTY OF OF CALIFORNIA PLACER lam@sbj-law.com CED NA 9749 ALAN PALMER JACOBUS (Bar No. 206954) SEP 04 2Ui3 A apj(@sbj-law.com JAKE CHAI ITERS 208 W. El Pintado Road WN EXECUTIVE OF! R & CLERK Danville, California 94526 By: Nes Deputy ND Telephone: (925) 837-2317 Facsimile: (925) 837-4831 YN Attorneys for Plaintiff Oo PACIFIC UNION INTERNATIONAL, INC. 0 10 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 IN AND FOR THE COUNTY OF PLACER 12 PACIFIC UNION INTERNATIONAL, INC., . No. SCV0042080 13 Plaintiff, ) DECLARATION OF SHANNON B. 14 y } JONES IN SUPPORT OF PLAINTIFF ) PACIFIC UNION INTERNATIONAL, 15 ERIK LUDWICK, an individual and ) INC.’S MOTION TO TRANSFER beneficiary of The Anything Trust Dated ) ACTION FILED IN LOS ANGELES 16 October 12, 2007; THE ANYTHING TRUST ) SUPERIOR COURT TO THIS COURT DATED OCTOBER 12, 2007; PAUL D. ) AND TO CONSOLID ATE, OR 17 nay eee te Seah and ALTERNATIVELY COORDINATE, THE 18 DOES 1-50, coe ) LOS ANGELES ACTION WITH THE ) PLACER COUNTY ACTION 19 Defendants. ) ) Date: October 3, 2019 20 ) Time: 8:30 a.m. Dept: 42 21 22 Complaint Filed: November 7, 2018 ) Trial Date: None Set 23 24 I, Shannon B. Jones, declare: 25 1. I am an attorney licensed to practice in the State of California and am the 26 managing partner at the Shannon B. Jones Law Group, Inc., counsel of record in this action for 27 Plaintiff Pacific Union International, Inc. (“Pacific Union”). By virtue of my firm’s 28 representation of Pacific Union, I have personal knowledge of the facts set forth in this DECLARATION OF SHANNON B. JONES ISO MOTION TO TRANSFER AND CONSOLIDATE ACTIONS declaration and ifcalled upon to testify, |could and would competently testify thereto, except as i) to those matters stated upon information and belief and as to those matters, Iam informed and believe them to be true. 2. This lawsuit arises out of a dispute over whether defendant Erik Ludwick ma owes plaintiff Pacific Union International, Inc. compensation under a Residential Listing Ww SYN Agreement contract. The lawsuit that Mr. Ludwick HD has filed in Los Angeles Superior Court (Erik Ludwick vs.Partners’ Trust Real Estate Brokerage & Acquisitions, et al., Los Angeles County Superior Court number 19 STCV 25331 (the “Los Angeles Lawsuit”)) involves the same dispute under the same contract. Oo 10 3. On August 23, 2019, I sent to counsel for the parties in the Los Angeles 11 Lawsuit a letter explaining the grounds for transfer and consolidation and requesting their agreement to the transfer and consolidation. A copy of the letter isattached to this declaration as 13 Exhibit A. 14 4. Counsel for Mr. Ludwick responded on August 28, 2019, and declined to 15 stipulate to transfer the Los Angeles Action. A true and correct copy of this correspondence is 16 attached hereto as Exhibit B. 17 5 My office notified all parties in this lawsuit and the Los Angeles Action of 18 their obligations to disclose to this Court any information they have concerning any other 19 motions requesting transfer of any case that would be affected by granting of the motion before 20 this Court by email on September 3, 2019. A true and correct copy of this communication is 21 attached hereto as Exhibit C. I declare under the penalty of perjury under the laws of the State of California that 23 the foregoing istrue and correct. 24 vswe Q ‘ ; ‘ Executed this u day of pillars. 2019, at Danville, California. 25 26 27 SFR Len SHANNON B. JONES 28 2 DECLARATION OF SHANNON B.JONES ISO MOTION TO TRANSFER AND CONSOLIDATE ACTIONS 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 fb 94526. On September | ,2019, I served the within document(s): WNW DECLARATION OF SHANNON B. JONES IN SUPPORT PLAINTIFF PACIFIC UNION DA INTERNATIONAL, INC.’S MOTION TO TRANSFER ACTION FILED IN LOS ANGELES SUPERIOR COURT TO THIS COURT AND TO CONSOLIDATE, OR NY ALTERNATIVELY COORDINATE, THE LOS ANGELES ACTION WITH THE PLACER COUNTY ACTION Oo X___ by transmitting via email the above listed document(s) to the email address(es) set forth 0 below on this date before 5:00 p.m. 10 11 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. 12 Attorneys for Defendants Erik Ludwick, The Co-Counsel for Defendants Erik Ludwick, The 13 Anything Trust and Paul Booth as Trustee of Anything Trust and Paul Booth as Trustee of the Anything Trust the Anything Trust 14 Lawrence E. Skidmore, Esq. 15 Michael A.J. Nangano, Esq. Aronowitz, Skidmore, Lyon Franklin T. Bigelow, Esq. 200 Auburn Folsom Road, Suite 305 16 Law Offices of Michael A.J. Nangano Auburn, CA 95603 133 No. Altadena Drive, Suite 403 Tel: (530) 823-9736 l7 Pasadena, CA 91107 Fax: (530) 823-5241 Tel: (626) 796-9998 Iskidmore@asilaw.org 18 Fax: (626) 796-9992 19 mnangano@lacounsel.com 20 Civil Clerk Los Angeles Superior Court 21 Stanley Mosk Courthouse 111 North Hill Street 22 Los Angeles, CA 90012 23 Ideclare under penalty of perjury under the laws of the State of California that the 24 above istrue and correct. 25 Executed on September «|, 2019, at Danville, California. 26 ar if SALAMIDA ubewh 28 \ \ / f f ‘ od 3 DECLARATION OF SHANNON B. JONES ISO MOTION TO TRANSFER AND CONSOLIDATE ACTIONS Exhibit A SHANNON B. JONES LAW GROUP, INC. Writer’sDirectNo.: (925)837-2315 Writer'sDirectEmail: sbj@sbj-law.com August 23, 2019 Via Email and U.S. Mail mnangano@lacounsel.com Michael A.J. Nangano, Esq. A Law Corporation 133 North Altadena Drive, Suite 403 Pasadena, CA 91107 Re: Ludwick v.Partners Trust, et al. Los Angeles Superior Court Case No. 19STCV25331 Dear Mr. Nangano: We are inreceipt of the complaint you filed on behalf of Erik Ludwick in Los Angeles Superior Court on July 19, 2019. As acknowledged inthe textof the complaint, and as you know by virtue of your representation of Mr. Ludwick in the existing action pending in the Superior Court of the State of California, County of Placer, case number S-CV-0042080, an active lawsuit is pending arising from the same transaction and facts. Putting aside, for the moment, the other problems riddling Mr. Ludwick’s newly- filed complaint, we write to ask whether you will stipulateto transfer and consolidate the complaint you improperly filed from Los Angeles Superior Court to Placer Superior Court. If you do not agree, we will prepare and filea motion to transfer on behalf of the defendants. Very truly yours, SHANNON B. JONES SBJ:lam Danville| 208W. El PintadoRoad, Danville, CA 94526 - Tel:(925)837-2317 - Fax: (925)837-4831 Sacramento | 8880CalCenter Drive,Suite400,Sacramento,CA 95826 - Tel:(916)368-1000 San Jose| 111North MarketStreet,Suite300,San Jose, CA 95113 - Tel:(408)363-3635 (Pleaserespond toDanvilleOffice)| www.calrealestatelaw.com Exhibit B MICHAEL A.J. NANGANO A Law CORPORATION 133 NORTH ALTADENA DRIVE, SUITE 403 PASADENA, CA 91107 Tel.(626) 796-9998 Fax: (213) 232-3252 August 28, 2019 Via Email Shannon B. Jones, Esq. Shannon B. Jones Law Group, Inc. 208 W. El Pintado Road Danville, CA 94526 Re: Pacific Union International, Inc. v. Ludwick, et al Case No.SCV0042080 (in Placer County, Superior Court) Dear Ms. Jones: We are in receipt of your correspondence of August 23, 2019. We will not stipulate to transfer and consolidate LASC Case No. 19STCV25331 with the current case pending in Placer County. Venue is proper in Los Angeles for the case we filed as, forthat matter, with the case your client chose to bring in Placer County. We will be moving in the near future to bring the Placer County action to the venue itshould have been filed inthe firstplace, the Los Angeles Superior Court. Ifyou have any questions or comments, please do not hesitate to contact the undersigned. We remain, Very truly yours, MALIA Michael AJ Nangano MAJN:pmp ce: Lindsey A. Morgan, Esq. (via email) Lawrence E. Skidmore (via email) Exhibit C Lindsey Morgan IS From: Lindsey Morgan Sent: Tuesday, September 3, 2019 5:29 PM To: PattiPoole Ce: mnangano@lacounsel.com; Lawrence Skidmore; Shannon B. Jones Subject: RE: PacificUnion v. Ludwick Thank you for your response. Pursuant toCRC 3.500, please note that allparties have an obligation to disclose to the Court any information concerning other motions requesting transfer of any case that would be affected by the granting ofthe motion before the Court. Thank you, Lindsey A. Morgan Shannon B., Jones Law Group, Inc. Direct: (925) 837-5577 ext.317 lam@sbj-law.com From: PattiPoole Sent: Wednesday, August 28, 2019 2:05 PM To: Shannon B.Jones Cc: mnangano@lacounsel.com; Lawrence Skidmore ; Lindsey Morgan Subject: PacificUnion v. Ludwick Dear Counsel: Please see Mike Nangano’s letterto you today. Regards, Patti Poole Paralegal to Michael A.J. Nangano, Esq. MICHAEL AJ NANGANO, A LAW CORPORATION 133 North Altadena Drive, Suite403 Pasadena, CA 91107 626/796-9998 213/232-3252 fax Thise-mail may contain or attachprivileged,confidential or protected informationintended only forthe use ofthe intended recipient. If youare not theintended recipient, any review oruse of it is strictly prohibited.If youhave received thise-mailin error, you are requiredto notifythe sender,then delete thisemailand any attachment from your computer and any of your electronic deviceswhere the message isstored.