Preview
SHANNON B. JONES LAW GROUP, INC. SUPERIOR COURT OFPLAGE
Ke
SHANNON B. JONES (Bar No. 149222)
COUNTY OF ORNIA
sbyasbj-law.com SEP 26 2019
LPO
LINDSEY A. MORGAN (Bar No. 274214)
JAKE
WD
CHATTER
lanva’sbj-law.com EXECUTIVE OFFICER a CLERK
ALAN PALMER JACOBUS (Bar No. 206954) By: N. Fycts, Deputy
fe
apjia'sbj-law.com
208 W. El Pintado Road
WO
Danville, California 94526
DBR
Telephone: (925) 837-2317
Facsimile: (925) 837-4831
NN
Attorneys for Plaintiff
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PACIFIC UNION INTERNATIONAL, INC.
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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
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IN AND FOR THE COUNTY OF PLACER
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PACIFIC UNION INTERNATIONAL, INC., ) No. SCV0042080
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Plaintiff, ) PLAINTIFF PACIFIC UNION
WY
) INTERNATIONAL, INC.’S REPLY BRIEF
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)
F&F
Vv.
IN SUPPORT OF ITS MOTION TO
) TRANSFER ACTION FILED IN LOS
ERIK LUDWICK, an individual and )
WO
beneficiary of The Anything Trust Dated ) ANGELES SUPERIOR COURT TO THIS
October 12, 2007; THE ANYTHING TRUST ) COURT AND TO CONSOLIDATE, OR
HDB
DATED OCTOBER 12, 2007; PAUL D. ) ALTERNATIVELY COORDINATE, THE
BOOTH, in his capacity as trustee of The )
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LOS ANGELES ACTION WITH THE
Anything Trust Dated October 12, 2007; and ) PLACER COUNTY ACTION
www
DOES 1-50, )
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) Date: October 3, 2019
Defendants. )
ODO
) Time: 8:30 a.m. BY FAX
) Dept: 42 ae
OF
DN
)
) Complaint Filed: November 7,2018
KY
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) Trial Date: None Set
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NO
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)
WY
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NO
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REPLY BRIEF IN SUPPORT OF MOTION TO TRANSFER AND CONSOLIDATE ACTIONS
I. ARGUMENT
Plaintiff Pacific Union International, Inc. (“Pacific Union”) addresses the
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arguments presented by Defendant Erik Ludwick (“Ludwick”) in his opposition to Pacific
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Union’s Motion to Transfer in turn below.
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A. Ludwick’s Opposition Inappropriately Attempts To Litigate Factual Issues
M&M
Notably missing from the arguments presented in Ludwick’s opposition isa
DH
comparison of the claims, transaction, witnesses and requested relief in his newly filed Los
NSN
Angeles Action with those already asserted by Pacific Union here in this Court. This is because
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the facts and requested relief are the same. This is the only appropriate factual analysis for the
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10 purpose of this motion.
11 Ludwick, however, goes well beyond this, making a gratuitous pitch on his
12 favorite (and wrong) argument about the Statute of Frauds. This motion to transfer is not the
13 appropriate place for Pacific Union to explain why its acquisition of a brokerage during the
14 pendency of an open escrow gives itthe rights to the earned commission Ludwick wrongfully
15 refuses to release. Pacific Union will cohesively lay out those arguments for the Court in the
16 appropriate place, which is Pacific Union’s forthcoming motion for summary judgment.
17 Pacific Union requests that the Court ignore inappropriately presented factual
18 arguments to this Court which have no bearing on the current motion. The motion asks this
19 Court to pull claims arising from the same exact transaction and involving the same parties,
20 witnesses, and disputed commission back into this Court so that the parties can move forward
21 with trying them. Ludwick has not presented any facts explaining why this should not be done.
22 B. Ludwick Admits Jurisdiction and Venue Are Both Proper in Placer
23 Ludwick admits that thisCourt has jurisdiction over this action, and this Court has
24 already held Placer Superior Court isthe appropriate venue.
25 The Opposition suggests that Ludwick’s substitution of himself as trustee for the
26 Anything Trust somehow makes the former trustee, Paul Booth (“Booth”), an irrelevant witness.
a7 The theory underlying Ludwick’s separate Los Angeles Action, however, is that Booth was
28 misled by Pacific Union’s predecessor and agents into signing an extension of time addendum to
|
REPLY BRIEF IN SUPPORT OF MOTION TO TRANSFER AND CONSOLIDATE ACTIONS
the listing agreement for the sale of the property, and that he signed itwithout Ludwick’s
permission. Accordingly, Booth’s actions during the time he was trustee of the trustee gave rise
NV
to this litigation. As this Court has already held, Booth conducted those day-to-day activities of
Ww
trustee for Ludwick’s trust in Placer County. The dispute should remain here, where this Court
>
has already spent significant time and resources overseeing it,and where a trialdate isalready
DN
set to dispose of the claims one way or another.
C. Pacific Union’s Counsel Represents All Defendants Named In Ludwick’s
NN
Los Angeles Action
OO
Ludwick observes that Pacific Union only met and conferred with counsel for
So
Ludwick, Booth, and the Anything Trust regarding Pacific Union’s motion to transfer. That is
10
accurate. The defendants named in Ludwick’s complaint filed on July 19, 2019 in the Superior
11
Court of California, County of Los Angeles, under case number 19 STCV 25331, titledErik
12
Ludwick vs.Partners’ Trust Real Estate Brokerage & Acquisitions, etal. (the “Los Angeles
13
Action’), are Partners Trust Real Estate Brokerage & Acquisitions, Pacific Union International,
14
Inc., Madison Hildebrand, individually and dba The Malibu Life Team, Malibu Life, Inc.,Nick
15
R. Segal. Samuel H. Kraemer, Gina Kirkpatrick and Jennifer Chrisman. These defendants are all
16
represented by counsel for Pacific Union. (See Supplemental Declaration of Shannon B. Jones
17
(“Supplemental Jones Decl.”), J2.) Many of those defendants are not appropriately named and
18
their presence in Ludwick’s lawsuit will be subject to future motion practice. Regardless of
19
whether they were appropriately included or not, however, each named defendant in the Los
20 Angeles Action agrees to this request for transfer. (Supplemental Jones Decl., {J 3-4.) Pacific
21
Union apologizes for any confusion that itmay have caused the Court by not previously
23
highlighting this fact.
23 D. Neither Action Is Complex
24 Ludwick leans heavily on his alleged intention to seek a complex case designation
25 from the Los Angeles Superior Court. The Civil Case Cover Sheet that Ludwick prepared and
26 filed with his complaint in Los Angeles suggests otherwise. (See Supplemental Request for
27 Judicial Notice, Exh. 7 — Ludwick’s Civil Case Cover Sheet filed on July 19, 2019.) That cover
28 sheet does not have boxes checked for a complex case designation. Instead, Ludwick checked
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REPLY BRIEF IN SUPPORT OF MOTION TO TRANSFER AND CONSOLIDATE ACTIONS
the box which states the case “IS NOT” complex. (/d.) Accordingly, Ludwick’s claim that the
e&
matter is complex and cannot be transferred arose only after Pacific Union requested that the
YY
matter be transferred.
WY
BR
Moreover, the matter is not complex. Neither complaint includes an antitrust or
trade regulation claim, or any construction defect issue involving many parties or structures.
OD
DBD
Cal. R. Ct. 3-400(c). There are no issues with securities or investment losses involving many
parties. (/d.) The dispute does not involve an environmental or toxic tort claim with many
NI
ee
parties, nor is ita mass tort, a class action, or insurance coverage claim. (Jd.) There is simply no
basis to pretend that this is a complex case deserving of the resources courts dedicate to the
So
oversight and management of those legitimately complex cases.
OC
The opposition also describes Ludwick’s intention to filea petition for
KF
meet
coordination with the Judicial Council to designate the dispute complex and move the matter to
PO
Los Angeles. Neither counsel for Pacific Union nor any of the defendants named in Ludwick’s
WY
Los Angeles action have received any notice of such a petition. The threat of an as-yet unfiled
F&F
petition to have the cases deemed complex (which, ifsubmitted, Pacific Union and all of the
Hn
Ludwick Defendants will oppose) is not an appropriate basis for denial of this motion.
DB
Ludwick’s promised course of action ignores the order of this Court and misuses the Judicial
wm
IN
Council’s process, wasting judicial resources that should be dedicated to coordinating disputes
BH
that are actually complex. Public policy implications aside, as no actual petition has been filed,
ODO
RO
this point is a non-argument.
DD
Ludwick may be entitled to bring a successive action, but this isnot a successive
KY§&
DD
action as described by section 1047 of the Code of Civil Procedure. (“Successive actions may be
NO
DO
maintained upon the same contract or transaction, whenever, after the former action, a new cause
WN
RO
of action arises therefrom.”) There isnot a former action, but an existing action in Placer
F&F
DN
Superior Court, and there is not a new cause of action here. Nor isLudwick entitled to litigate
Wn
NO
compulsory cross-claims in a separate action.
DBD
NO
The parties appear to agree that the cases should be litigated together.
YN
NO
Accordingly, the only issue for the Court to decide at this time iswhether, with a trialdate set
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NO
3
REPLY BRIEF IN SUPPORT OF MOTION TO TRANSFER AND CONSOLIDATE ACTIONS
and significant discovery conducted, this action should remain in Placer County, with Ludwick’s
separate but completely related complaint to move to Placer County with it for the duration of
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litigation and trial.
WH
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Il. CONCLUSION
Ten of the twelve potential parties in these two lawsuits either reside in Placer
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County or desire for the claims to be litigated here. This Court has spent significant resources
shepherding this litigation to this point, and Pacific Union’s lawsuit should remain here, joined
JN
by Ludwick’s related claims under the same contract and transaction. There is no basis for the
eH
allegation that this is a dispute entitled to a complex case designation — an argument drummed
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10 up, it appears, solely for the purposes of the opposition.
11 For these reasons, Pacific Union asks that the Court grant the request in its
i2 moving papers to transfer the Los Angeles Action to this Court and to coordinate it with this
Le, pending action in Placer County Superior Court, or alternatively to transfer and consolidate the
14 actions, and for allother relief to which Pacific Union is entitled at law, atequity, or otherwise.
io Dated: September 26, 2019
SHANNON B. JONES LAW GROUP, INC.
16
17
18 SHANNON B. JONES
Attorneys for Plaintiff
19 PACIFIC UNION INTERNATIONAL, INC
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22
23
24
25
26
27
28
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REPLY BRIEF IN SUPPORT OF MOTION TO TRANSFER AND CONSOLIDATE ACTIONS
PROOF OF SERVICE
&
YO
I,the undersigned, declare:
WY
Iam a resident of the State of California and over the age of eighteen years, and
not aparty to the within action; my business address is 208 W. El Pintado Road, Danville, CA
F&F
94526. On September 2b, 2019, I served the within document(s):
NO
PLAINTIFF PACIFIC UNION INTERNATIONAL, INC.’S REPLY BRIEF IN SUPPORT
DH
OF ITS MOTION TO TRANSFER ACTION FILED IN LOS ANGELES SUPERIOR
COURT TO THIS COURT AND TO CONSOLIDATE, OR ALTERNATIVELY
NIN
COORDINATE, THE LOS ANGELES ACTION WITH THE PLACER COUNTY
ACTION
FH
oS
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.
OC
X____ by placing the document(s) listedabove in a sealed envelope with postage thereon fully
met
KF
prepaid, in the United States mail atDanville, California addressed as set forth below.
NYO
Attorneys for Defendants Erik Ludwick, The Co-Counsel for Defendants Erik Ludwick, The
WYO
Anything Trust and Paul Booth as Trustee of Anything Trust and Paul Booth as Trustee of
the Anvthing Trust the Anything Trust
F&F
Lawrence E. Skidmore, Esq.
Michael A.J. Nangano, Esq. Aronowitz, Skidmore, Lyon
Wn
Franklin T. Bigelow, Esq. 200 Auburn Folsom Road, Suite 305
Law Offices of Michael A.J. Nangano Auburn, CA 95603
DBD
133 No. Altadena Drive, Suite 403 Tel: (530) 823-9736
JN
Pasadena, CA 91107 F sai (530) 823-5241
Tel: (626) 796-9998 Iskidmore(@asilaw.ory
ww
Be
Fax: (626) 796-9992
mnangano@ lacounsel.com
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Civil Clerk
OO
RO
Los Angeles Superior Court
—|&
Stanley Mosk Courthouse
DD
111 North Hill Street
RO
YY
Los Angeles, CA 90012
WY
KR
I declare under penalty of perjury under the laws of the State of California that the
above istrue and correct.
SF
PO
UN
Executed on September 26, 2019, at Danville, California.
KN
(YH full nde
NO
NO
wPpO
L. SAL AMIDA
oN
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5
REPLY BRIEF IN SUPPORT OF MOTION TO TRANSFER AND CONSOLIDATE ACTIONS
Preview
SHANNON B. JONES LAW GROUP, INC. SUPERIOR COURT OFPLAGE Ke SHANNON B. JONES (Bar No. 149222) COUNTY OF ORNIA sbyasbj-law.com SEP 26 2019 LPO LINDSEY A. MORGAN (Bar No. 274214) JAKE WD CHATTER lanva’sbj-law.com EXECUTIVE OFFICER a CLERK ALAN PALMER JACOBUS (Bar No. 206954) By: N. Fycts, Deputy fe apjia'sbj-law.com 208 W. El Pintado Road WO Danville, California 94526 DBR Telephone: (925) 837-2317 Facsimile: (925) 837-4831 NN Attorneys for Plaintiff Co PACIFIC UNION INTERNATIONAL, INC. Oo IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA |S le IN AND FOR THE COUNTY OF PLACER KF PACIFIC UNION INTERNATIONAL, INC., ) No. SCV0042080 NO ) Plaintiff, ) PLAINTIFF PACIFIC UNION WY ) INTERNATIONAL, INC.’S REPLY BRIEF mm ) F&F Vv. IN SUPPORT OF ITS MOTION TO ) TRANSFER ACTION FILED IN LOS ERIK LUDWICK, an individual and ) WO beneficiary of The Anything Trust Dated ) ANGELES SUPERIOR COURT TO THIS October 12, 2007; THE ANYTHING TRUST ) COURT AND TO CONSOLIDATE, OR HDB DATED OCTOBER 12, 2007; PAUL D. ) ALTERNATIVELY COORDINATE, THE BOOTH, in his capacity as trustee of The ) HN LOS ANGELES ACTION WITH THE Anything Trust Dated October 12, 2007; and ) PLACER COUNTY ACTION www DOES 1-50, ) Oo ) Date: October 3, 2019 Defendants. ) ODO ) Time: 8:30 a.m. BY FAX ) Dept: 42 ae OF DN ) ) Complaint Filed: November 7,2018 KY KN ) Trial Date: None Set ) NO KN ) WY KN //1 FF NO /T/ NY A /TI Bn NO /TT/ pO NN /TI oa Oo REPLY BRIEF IN SUPPORT OF MOTION TO TRANSFER AND CONSOLIDATE ACTIONS I. ARGUMENT Plaintiff Pacific Union International, Inc. (“Pacific Union”) addresses the bd arguments presented by Defendant Erik Ludwick (“Ludwick”) in his opposition to Pacific Ww Union’s Motion to Transfer in turn below. - A. Ludwick’s Opposition Inappropriately Attempts To Litigate Factual Issues M&M Notably missing from the arguments presented in Ludwick’s opposition isa DH comparison of the claims, transaction, witnesses and requested relief in his newly filed Los NSN Angeles Action with those already asserted by Pacific Union here in this Court. This is because Oo the facts and requested relief are the same. This is the only appropriate factual analysis for the o 10 purpose of this motion. 11 Ludwick, however, goes well beyond this, making a gratuitous pitch on his 12 favorite (and wrong) argument about the Statute of Frauds. This motion to transfer is not the 13 appropriate place for Pacific Union to explain why its acquisition of a brokerage during the 14 pendency of an open escrow gives itthe rights to the earned commission Ludwick wrongfully 15 refuses to release. Pacific Union will cohesively lay out those arguments for the Court in the 16 appropriate place, which is Pacific Union’s forthcoming motion for summary judgment. 17 Pacific Union requests that the Court ignore inappropriately presented factual 18 arguments to this Court which have no bearing on the current motion. The motion asks this 19 Court to pull claims arising from the same exact transaction and involving the same parties, 20 witnesses, and disputed commission back into this Court so that the parties can move forward 21 with trying them. Ludwick has not presented any facts explaining why this should not be done. 22 B. Ludwick Admits Jurisdiction and Venue Are Both Proper in Placer 23 Ludwick admits that thisCourt has jurisdiction over this action, and this Court has 24 already held Placer Superior Court isthe appropriate venue. 25 The Opposition suggests that Ludwick’s substitution of himself as trustee for the 26 Anything Trust somehow makes the former trustee, Paul Booth (“Booth”), an irrelevant witness. a7 The theory underlying Ludwick’s separate Los Angeles Action, however, is that Booth was 28 misled by Pacific Union’s predecessor and agents into signing an extension of time addendum to | REPLY BRIEF IN SUPPORT OF MOTION TO TRANSFER AND CONSOLIDATE ACTIONS the listing agreement for the sale of the property, and that he signed itwithout Ludwick’s permission. Accordingly, Booth’s actions during the time he was trustee of the trustee gave rise NV to this litigation. As this Court has already held, Booth conducted those day-to-day activities of Ww trustee for Ludwick’s trust in Placer County. The dispute should remain here, where this Court > has already spent significant time and resources overseeing it,and where a trialdate isalready DN set to dispose of the claims one way or another. C. Pacific Union’s Counsel Represents All Defendants Named In Ludwick’s NN Los Angeles Action OO Ludwick observes that Pacific Union only met and conferred with counsel for So Ludwick, Booth, and the Anything Trust regarding Pacific Union’s motion to transfer. That is 10 accurate. The defendants named in Ludwick’s complaint filed on July 19, 2019 in the Superior 11 Court of California, County of Los Angeles, under case number 19 STCV 25331, titledErik 12 Ludwick vs.Partners’ Trust Real Estate Brokerage & Acquisitions, etal. (the “Los Angeles 13 Action’), are Partners Trust Real Estate Brokerage & Acquisitions, Pacific Union International, 14 Inc., Madison Hildebrand, individually and dba The Malibu Life Team, Malibu Life, Inc.,Nick 15 R. Segal. Samuel H. Kraemer, Gina Kirkpatrick and Jennifer Chrisman. These defendants are all 16 represented by counsel for Pacific Union. (See Supplemental Declaration of Shannon B. Jones 17 (“Supplemental Jones Decl.”), J2.) Many of those defendants are not appropriately named and 18 their presence in Ludwick’s lawsuit will be subject to future motion practice. Regardless of 19 whether they were appropriately included or not, however, each named defendant in the Los 20 Angeles Action agrees to this request for transfer. (Supplemental Jones Decl., {J 3-4.) Pacific 21 Union apologizes for any confusion that itmay have caused the Court by not previously 23 highlighting this fact. 23 D. Neither Action Is Complex 24 Ludwick leans heavily on his alleged intention to seek a complex case designation 25 from the Los Angeles Superior Court. The Civil Case Cover Sheet that Ludwick prepared and 26 filed with his complaint in Los Angeles suggests otherwise. (See Supplemental Request for 27 Judicial Notice, Exh. 7 — Ludwick’s Civil Case Cover Sheet filed on July 19, 2019.) That cover 28 sheet does not have boxes checked for a complex case designation. Instead, Ludwick checked 2 REPLY BRIEF IN SUPPORT OF MOTION TO TRANSFER AND CONSOLIDATE ACTIONS the box which states the case “IS NOT” complex. (/d.) Accordingly, Ludwick’s claim that the e& matter is complex and cannot be transferred arose only after Pacific Union requested that the YY matter be transferred. WY BR Moreover, the matter is not complex. Neither complaint includes an antitrust or trade regulation claim, or any construction defect issue involving many parties or structures. OD DBD Cal. R. Ct. 3-400(c). There are no issues with securities or investment losses involving many parties. (/d.) The dispute does not involve an environmental or toxic tort claim with many NI ee parties, nor is ita mass tort, a class action, or insurance coverage claim. (Jd.) There is simply no basis to pretend that this is a complex case deserving of the resources courts dedicate to the So oversight and management of those legitimately complex cases. OC The opposition also describes Ludwick’s intention to filea petition for KF meet coordination with the Judicial Council to designate the dispute complex and move the matter to PO Los Angeles. Neither counsel for Pacific Union nor any of the defendants named in Ludwick’s WY Los Angeles action have received any notice of such a petition. The threat of an as-yet unfiled F&F petition to have the cases deemed complex (which, ifsubmitted, Pacific Union and all of the Hn Ludwick Defendants will oppose) is not an appropriate basis for denial of this motion. DB Ludwick’s promised course of action ignores the order of this Court and misuses the Judicial wm IN Council’s process, wasting judicial resources that should be dedicated to coordinating disputes BH that are actually complex. Public policy implications aside, as no actual petition has been filed, ODO RO this point is a non-argument. DD Ludwick may be entitled to bring a successive action, but this isnot a successive KY§& DD action as described by section 1047 of the Code of Civil Procedure. (“Successive actions may be NO DO maintained upon the same contract or transaction, whenever, after the former action, a new cause WN RO of action arises therefrom.”) There isnot a former action, but an existing action in Placer F&F DN Superior Court, and there is not a new cause of action here. Nor isLudwick entitled to litigate Wn NO compulsory cross-claims in a separate action. DBD NO The parties appear to agree that the cases should be litigated together. YN NO Accordingly, the only issue for the Court to decide at this time iswhether, with a trialdate set oo NO 3 REPLY BRIEF IN SUPPORT OF MOTION TO TRANSFER AND CONSOLIDATE ACTIONS and significant discovery conducted, this action should remain in Placer County, with Ludwick’s separate but completely related complaint to move to Placer County with it for the duration of N litigation and trial. WH Fe Il. CONCLUSION Ten of the twelve potential parties in these two lawsuits either reside in Placer no Dn County or desire for the claims to be litigated here. This Court has spent significant resources shepherding this litigation to this point, and Pacific Union’s lawsuit should remain here, joined JN by Ludwick’s related claims under the same contract and transaction. There is no basis for the eH allegation that this is a dispute entitled to a complex case designation — an argument drummed Oo 10 up, it appears, solely for the purposes of the opposition. 11 For these reasons, Pacific Union asks that the Court grant the request in its i2 moving papers to transfer the Los Angeles Action to this Court and to coordinate it with this Le, pending action in Placer County Superior Court, or alternatively to transfer and consolidate the 14 actions, and for allother relief to which Pacific Union is entitled at law, atequity, or otherwise. io Dated: September 26, 2019 SHANNON B. JONES LAW GROUP, INC. 16 17 18 SHANNON B. JONES Attorneys for Plaintiff 19 PACIFIC UNION INTERNATIONAL, INC 20 21 22 23 24 25 26 27 28 4 REPLY BRIEF IN SUPPORT OF MOTION TO TRANSFER AND CONSOLIDATE ACTIONS PROOF OF SERVICE & YO I,the undersigned, declare: WY Iam a resident of the State of California and over the age of eighteen years, and not aparty to the within action; my business address is 208 W. El Pintado Road, Danville, CA F&F 94526. On September 2b, 2019, I served the within document(s): NO PLAINTIFF PACIFIC UNION INTERNATIONAL, INC.’S REPLY BRIEF IN SUPPORT DH OF ITS MOTION TO TRANSFER ACTION FILED IN LOS ANGELES SUPERIOR COURT TO THIS COURT AND TO CONSOLIDATE, OR ALTERNATIVELY NIN COORDINATE, THE LOS ANGELES ACTION WITH THE PLACER COUNTY ACTION FH oS 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. OC X____ by placing the document(s) listedabove in a sealed envelope with postage thereon fully met KF prepaid, in the United States mail atDanville, California addressed as set forth below. NYO Attorneys for Defendants Erik Ludwick, The Co-Counsel for Defendants Erik Ludwick, The WYO Anything Trust and Paul Booth as Trustee of Anything Trust and Paul Booth as Trustee of the Anvthing Trust the Anything Trust F&F Lawrence E. Skidmore, Esq. Michael A.J. Nangano, Esq. Aronowitz, Skidmore, Lyon Wn Franklin T. Bigelow, Esq. 200 Auburn Folsom Road, Suite 305 Law Offices of Michael A.J. Nangano Auburn, CA 95603 DBD 133 No. Altadena Drive, Suite 403 Tel: (530) 823-9736 JN Pasadena, CA 91107 F sai (530) 823-5241 Tel: (626) 796-9998 Iskidmore(@asilaw.ory ww Be Fax: (626) 796-9992 mnangano@ lacounsel.com Oo Civil Clerk OO RO Los Angeles Superior Court —|& Stanley Mosk Courthouse DD 111 North Hill Street RO YY Los Angeles, CA 90012 WY KR I declare under penalty of perjury under the laws of the State of California that the above istrue and correct. SF PO UN Executed on September 26, 2019, at Danville, California. KN (YH full nde NO NO wPpO L. SAL AMIDA oN oO 5 REPLY BRIEF IN SUPPORT OF MOTION TO TRANSFER AND CONSOLIDATE ACTIONS