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SHANNON B. JONES LAW GROUP, INC.
SHANNON B. JONES (Bar No. 149222)
sbj‘@sbj-law.com
SUPERIOR
LED
COURT
LINDSEY A. MORGAN (Bar No. 274214) COUNTY OF
OF CALIF
PLACER ORNIA
lam@sbj-law.com
ALAN,PALMER JACOBUS (Bar No. 206954) SEP 26 2019
apj@sbj-law.com JAKE CHATTERS
208 W. El Pintado Road EXECUTIVE OFFICER & CLERK
Danville, California 94526 By: N. Rahs. Deputy
DN
Telephone: (925) 837-2317
Facsimile: (925) 837-4831
nN
Attorneys for Plaintiff
ao
PACIFIC UNION INTERNATIONAL, INC.
\o
10 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 IN AND FOR THE COUNTY OF PLACER
12 PACIFIC UNION INTERNATIONAL, INC., ee No. SCV0042080
13 Plaintiff,
SUPPLEMENTAL DECLARATION OF
ee
14 V. SHANNON B. JONES IN SUPPORT OF
ae
PLAINTIFF PACIFIC UNION
15
Ne
ERIK LUDWICK, an individual and INTERNATIONAL, INC.’S MOTION TO
Ne
beneficiary of The Anything Trust Dated TRANSFER ACTION FILED IN T.0S
Se
16 October 12, 2007; THE ANYTHING TRUST ANGELES SUPERIOR COURT TO THIS
Ne
DATED OCTOBER 12, 2007; PAUL D. COURT AND TO CONSOLIDATE, OR
ae
17 BOOTH, in his capacity as trustee of The
ALTERNATIVELY COORDINATE, THE
Ne
Anything Trust Dated October 12, 2007; and
ee
18 DOES 1-50, LOS ANGELES ACTION WITH THE
Ne
PLACER COUNTY ACTION
Se
19 Defendants.
ae
Date: October 3, 2019 BY FAX
ae
20 Time: 8:30 a.m.
ae
Dept: 42
ae
21
Ne
ee
22 Complaint Filed: November 7, 2018
Trial Date: None Set
ee
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
SUPPLEMENTAL DECLARATION OF SHANNON B. JONES ISO MOTION TO TRANSFER AND CONSOLIDATE}
ACTIONS
declaration and ifcalled upon to testify, I could and would competently testify thereto, except as
to those matters stated upon information and belief and as to those matters, I am informed and
believe them to be true.
BS
2. My office represents the defendants in the action Erik Ludwick filed in
Wn
Los Angeles Superior Court (Erik Ludwick vs. Partners’ Trust Real Estate Brokerage &
ON DR
Acquisitions, et al., Los Angeles County Superior Court number 19 STCV 25331 (the “Los
Angeles Lawsuit”)), including Partners Trust Real Estate Brokerage & Acquisitions, Pacific
Union International, Inc., Madison Hildebrand, individually and dba The Malibu Life Team,
So
Malibu Life, Inc., Nick R. Segal, Samuel H. Kraemer, Gina Kirkpatrick, and Jennifer Chrisman.
10
3. Partners Trust Real Estate Brokerage & Acquisitions, Madison
11
Hildebrand, individually and dba The Malibu Life Team, Malibu Life, Inc., Nick R. Segal,
YW,
Samuel H. Kraemer, Gina Kirkpatrick, and Jennifer Chrisman each agree with Pacific Union’s
13
request to transfer and coordinate, or alternatively, consolidate both actions to Placer Superior
14
Court.
4. Neither Partners Trust Real Estate Brokerage & Acquisitions, Pacific
16
Union International, Inc., Madison Hildebrand, individually and dba The Malibu Life Team,
17
Malibu Life, Inc., Nick R. Segal, Samuel H. Kraemer, Gina Kirkpatrick, or Jennifer Chrisman
18
objects to Pacific Union’s motion to transfer the Los Angeles Action to Placer Superior Court for
19
coordination, or alternatively, consolidation.
20
21 I declare under the penalty of perjury under the laws of the State of California that
22 the foregoing is true and correct.
Ae —
23 Executed this2V day of Atay", 2019, at Danville, California.
24
25
26
SHANNON B. JONES
27
28
2
DECLARATION OF SHANNON B. JONES ISO MOTION TO TRANSFER AND CONSOLIDATE ACTIONS
PROOF OF SERVICE
I,the undersigned, declare:
Iam 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 is208 W. El Pintado Road, Danville, CA
94526. On September 26, 2019, I served the within document(s):
SUPPLEMENTAL DECLARATION OF SHANNON B. JONES IN SUPPORT
PLAINTIFF PACIFIC UNION INTERNATIONAL, INC.’S MOTION TO TRANSFER
ACTION FILED IN LOS ANGELES SUPERIOR COURT TO THIS COURT AND TO
CONSOLIDATE, OR ALTERNATIVELY COORDINATE, THE LOS ANGELES
ACTION WITH THE PLACER COUNTY ACTION
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. - .
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 Paul Booth as Trustee of — A”vthing Trust and Paul Booth as Trustee of
the Anything Trust the Anything Trust
Lawrence E. Skidmore, Esq.
Michacl A.J. Nangano, Esq. Aronowitz, Skidmore, Lyon
Franklin T. Bigelow, Esq. 200 Auburn Folsom Road, Suite 305
Law Offices of Michael A.J. Nangano Auburn, CA 95603
133 No. Altadena Drive, Suite 403 Tel: (530) 823-9736
Pasadena, CA 91107 Fax: (530) 823-5241
Tel: (626) 796-9998 Iskidmore@asilaw.org
Fax: (626) 796-9992
mnangano@lacounsel.com
Civil Clerk
Los Angeles Superior Court
Stanley Mosk Courthouse
111 North Hill Street
Los Angeles, CA 90012
I declare under penalty of perjury under the laws of the State of California that the
above istrue and correct.
Executed on September 26 2019, at Danville, California.
Qik nner
L. SALAMIDA
DECLARATION OF SHANNON B. JONES ISO MOTION TO TRANSFER AND CONSOLIDATE ACTIONS
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SHANNON B. JONES LAW GROUP, INC. SHANNON B. JONES (Bar No. 149222) sbj‘@sbj-law.com SUPERIOR LED COURT LINDSEY A. MORGAN (Bar No. 274214) COUNTY OF OF CALIF PLACER ORNIA lam@sbj-law.com ALAN,PALMER JACOBUS (Bar No. 206954) SEP 26 2019 apj@sbj-law.com JAKE CHATTERS 208 W. El Pintado Road EXECUTIVE OFFICER & CLERK Danville, California 94526 By: N. Rahs. Deputy DN Telephone: (925) 837-2317 Facsimile: (925) 837-4831 nN Attorneys for Plaintiff ao PACIFIC UNION INTERNATIONAL, INC. \o 10 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 IN AND FOR THE COUNTY OF PLACER 12 PACIFIC UNION INTERNATIONAL, INC., ee No. SCV0042080 13 Plaintiff, SUPPLEMENTAL DECLARATION OF ee 14 V. SHANNON B. JONES IN SUPPORT OF ae PLAINTIFF PACIFIC UNION 15 Ne ERIK LUDWICK, an individual and INTERNATIONAL, INC.’S MOTION TO Ne beneficiary of The Anything Trust Dated TRANSFER ACTION FILED IN T.0S Se 16 October 12, 2007; THE ANYTHING TRUST ANGELES SUPERIOR COURT TO THIS Ne DATED OCTOBER 12, 2007; PAUL D. COURT AND TO CONSOLIDATE, OR ae 17 BOOTH, in his capacity as trustee of The ALTERNATIVELY COORDINATE, THE Ne Anything Trust Dated October 12, 2007; and ee 18 DOES 1-50, LOS ANGELES ACTION WITH THE Ne PLACER COUNTY ACTION Se 19 Defendants. ae Date: October 3, 2019 BY FAX ae 20 Time: 8:30 a.m. ae Dept: 42 ae 21 Ne ee 22 Complaint Filed: November 7, 2018 Trial Date: None Set ee 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 SUPPLEMENTAL DECLARATION OF SHANNON B. JONES ISO MOTION TO TRANSFER AND CONSOLIDATE} ACTIONS declaration and ifcalled upon to testify, I could and would competently testify thereto, except as to those matters stated upon information and belief and as to those matters, I am informed and believe them to be true. BS 2. My office represents the defendants in the action Erik Ludwick filed in Wn Los Angeles Superior Court (Erik Ludwick vs. Partners’ Trust Real Estate Brokerage & ON DR Acquisitions, et al., Los Angeles County Superior Court number 19 STCV 25331 (the “Los Angeles Lawsuit”)), including Partners Trust Real Estate Brokerage & Acquisitions, Pacific Union International, Inc., Madison Hildebrand, individually and dba The Malibu Life Team, So Malibu Life, Inc., Nick R. Segal, Samuel H. Kraemer, Gina Kirkpatrick, and Jennifer Chrisman. 10 3. Partners Trust Real Estate Brokerage & Acquisitions, Madison 11 Hildebrand, individually and dba The Malibu Life Team, Malibu Life, Inc., Nick R. Segal, YW, Samuel H. Kraemer, Gina Kirkpatrick, and Jennifer Chrisman each agree with Pacific Union’s 13 request to transfer and coordinate, or alternatively, consolidate both actions to Placer Superior 14 Court. 4. Neither Partners Trust Real Estate Brokerage & Acquisitions, Pacific 16 Union International, Inc., Madison Hildebrand, individually and dba The Malibu Life Team, 17 Malibu Life, Inc., Nick R. Segal, Samuel H. Kraemer, Gina Kirkpatrick, or Jennifer Chrisman 18 objects to Pacific Union’s motion to transfer the Los Angeles Action to Placer Superior Court for 19 coordination, or alternatively, consolidation. 20 21 I declare under the penalty of perjury under the laws of the State of California that 22 the foregoing is true and correct. Ae — 23 Executed this2V day of Atay", 2019, at Danville, California. 24 25 26 SHANNON B. JONES 27 28 2 DECLARATION OF SHANNON B. JONES ISO MOTION TO TRANSFER AND CONSOLIDATE ACTIONS PROOF OF SERVICE I,the undersigned, declare: Iam 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 is208 W. El Pintado Road, Danville, CA 94526. On September 26, 2019, I served the within document(s): SUPPLEMENTAL DECLARATION OF SHANNON B. JONES IN SUPPORT PLAINTIFF PACIFIC UNION INTERNATIONAL, INC.’S MOTION TO TRANSFER ACTION FILED IN LOS ANGELES SUPERIOR COURT TO THIS COURT AND TO CONSOLIDATE, OR ALTERNATIVELY COORDINATE, THE LOS ANGELES ACTION WITH THE PLACER COUNTY ACTION 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. - . 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 Paul Booth as Trustee of — A”vthing Trust and Paul Booth as Trustee of the Anything Trust the Anything Trust Lawrence E. Skidmore, Esq. Michacl A.J. Nangano, Esq. Aronowitz, Skidmore, Lyon Franklin T. Bigelow, Esq. 200 Auburn Folsom Road, Suite 305 Law Offices of Michael A.J. Nangano Auburn, CA 95603 133 No. Altadena Drive, Suite 403 Tel: (530) 823-9736 Pasadena, CA 91107 Fax: (530) 823-5241 Tel: (626) 796-9998 Iskidmore@asilaw.org Fax: (626) 796-9992 mnangano@lacounsel.com Civil Clerk Los Angeles Superior Court Stanley Mosk Courthouse 111 North Hill Street Los Angeles, CA 90012 I declare under penalty of perjury under the laws of the State of California that the above istrue and correct. Executed on September 26 2019, at Danville, California. Qik nner L. SALAMIDA DECLARATION OF SHANNON B. JONES ISO MOTION TO TRANSFER AND CONSOLIDATE ACTIONS