Preview
ELECTRONICALLY FILED
superior Court of California,
County of Placer
SHANNON B. JONES LAW GROUP, INC. 10/16/2020
SHANNON B. JONES (Bar No. 149222) By: LaurelSanders, Deputy Clerk
sbi/@isbj-law.com
LINDSEY A. MORGAN (Bar No. 274214)
lam@sbj-law.com
208 W. El Pintado Road
Danville, California 94526
Telephone: (925) 837-2317
Facsimile: (925) 837-4831
Attorneys for Plaintiff
PACIFIC UNION INTERNATIONAL, INC.
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF PLACER
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11 PACIFIC UNION INTERNATIONAL, INC., ) Case No. SCV0042080
12 )
Plaintiff, ) DECLARATION OF LINDSEY A.
13 ) MORGAN IN SUPPORT OF PACIFIC
Ve UNION INTERNATIONAL, INC.’S
14 OPPOSITION TO DEFENDANTS’
ERIK LUDWICK, an individual and ) MOTION FOR ReCG eae ON
beneficiary of The Anything Trust Dated ) AND/OR RELIEF UNDER SECTION 472
15 October 12, 2007; THE ANYTHING TRUST ) OF THE CODE OF CIVIL PROCEDURE
DATED OCTOBER 12, 2007; PAUL D. )
16 BOOTH, in his capacity as trustee of The )
Anything Trust Dated October 12,2007; and ) — Date: October 29, 2020
17 DOES 1-50, ) Time: 8:30 a.m.
) Dept: 42
18 Defendants. )
19 ) Complaint Filed: November 7, 2018
Trial Date: March 29, 2021
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22 I,Lindsey A. Morgan, declare:
23 1. I am an attorney licensed to practice in the State of California, and Iam a
24 lawyer with the Shannon B. Jones Law Group, Inc., counsel of record for Plaintiff PACIFIC
25 UNION INTERNATIONAL, INC. (“Pacific Union”). By virtue of that representation, I have
26 personal knowledge of the facts set forth in this declaration and if called upon to testify, Icould
27 and would competently testify thereto, except as to those matters stated upon information and
28 belief and as to those matters, Iam informed and believe them to be true.
DECLARATION OF LINDSEY A. MORGAN IN SUPPORT OF PACIFIC UNION INTERNATIONAL, INC.’S
REPLY BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY,
SUMMARY ADJUDICATION OF ISSUES
2. On August 7, 2020, my office sent a letterand a proposed stipulation to
continue the trialdate in this matter from September 21, 2020 to March 29, 2021 to counsel for
Defendants. The documents were attached as two separate pdf files to a single email. A true and
correct copy of the correspondence and stipulation my office sent to Mr. Nangano’s office is
attached hereto as Exhibit 1.
3. I prepared the cover letter enclosing the stipulation to continue trial by
copying over the cover letter from my office’s earlier stipulation to continue trialand all]
related
dates. The letter as sent contained a typographical error where I inadvertently neglected to delete
the phrase “and allrelated dates” from the description of the stipulation.
10 4, I did not have any knowledge that counsel for Defendants desired to take
11 any further depositions or engage in any additional discovery when my office prepared and
12 circulated the stipulation to continue trial. Mr. Nangano’s office stated that Defendants did not
13 intend to depose Sarah Kosasky as of June 2, 2020 (see Exhibit G to Mr. Nangano’s declaration),
14 and there has not been no communication between the parties regarding depositions since Pacific
15 Union deposed Erik Ludwick on June 16, 2020. As both parties have filed and fully briefed their
16 respective Motions for Summary Judgment, and discovery was closing based on the September
17 2020 trialdate, itwas my understanding that we had finished discovery in this matter.
18 5. The stipulation itself,including the language in Paragraph 15, immediately
19 above Defendants’ counsel’s signature block, was very clear that the stipulation was for the
20 purpose of continuing the trialdate, but not all related deadlines.
21 6. Mr. Nangano executed the stipulation on behalf of Defendants and returned
22 itto my office by email on August 10, 2012, without comment.
23 7. After receiving Mr. Nangano’s signature page, I called the Court on August
24 12, 2020 to schedule a hearing date on a stipulated motion to continue trial. The clerk asked me if
25 the request to continue trial was stipulated, and Ianswered affirmatively. The clerk then instructed
26 me to simply submit the stipulation and a proposed order instead of filing a motion. She stated the
27 Court did not usually do itthat way, but was attempting to make it easier for litigants in light of the
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DECLARATION OF LINDSEY A. MORGAN IN SUPPORT OF PACIFIC UNION INTERNATIONAL, INC.’S
REPLY BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY,
SUMMARY ADJUDICATION OF ISSUES
scheduling difficulties presented by the COVID-19 pandemic and related trial availability
problems. I immediately sent an email to counsel for Defendants, indicating that the clerk had
instructed Pacific Union to file the stipulation and a proposed order. A true and correct copy of my
August 12, 2020 email to Mr. Nangano and his assistant, Patti Poole, advising them of this
development is attached hereto as Exhibit 2.
8. My office filed the stipulation and a proposed order copied from the
stipulation on August 12, 2020 — a date that isreflected on the time stamp on the sidebar of the
Court’s order. A true and correct copy of the filing receipt is attached hereto as Exhibit 3.
9. My office served Mr. Nangano’s office on August 12, 2020 with the
10 stipulation and proposed order continuing trial. A true and correct copy of the email serving the
11 documents on Mr. Nangano’s office on August 12, 2020 is attached hereto as Exhibit 4.
12 10. I did not hear from Mr. Nangano again until five days later,on August 17,
13 2020, when his office sent me an email at 3:54 p.m. attaching a letter. The letter demanded that
14 the stipulation be withdrawn. A true and correct copy of that email and the attached letter is
15 attached hereto as Exhibit 5.
16 11. Upon receipt of Mr. Nangano’s letter on August 17, 2020, Ipromptly called
17 the Court to request that the stipulation be withdrawn. I was not able to get through to the Court,
18 which had closed at 3:00 p.m. that day. On information and belief, this was due to eithera fire
19 concern or a heat wave on that particular day. I also accessed our firm’s electronic filing account
20 and attempted to withdraw the stipulation, but there was not method by which Icould do so.
21 12. The next morning, the order entering the stipulation had been entered on the
22 docket. My office responded to Mr. Nangano’s letter on August 18, 2020, explaining that we had
23 attempted to call the Court and had also attempted to withdraw the stipulation electronically, but
24 were unable to do so. We attached the order, which the Court had entered. A true and correct
25 copy of that correspondence is attached hereto as Exhibit 6. My office then filed a notice of entry
26 of order.
27
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DECLARATION OF LINDSEY A. MORGAN IN SUPPORT OF PACIFIC UNION INTERNATIONAL, INC.’S
REPLY BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY,
SUMMARY ADJUDICATION OF ISSUES
13. I heard nothing else about the matter until September 8, 2020, when I
received a hard copy of an August 28, 2020 letter full of accusations of improper conduct from Mr.
Nangano’s office, threatening to file this motion and attaching a stipulation to extend the discovery
deadlines in conjunction with the new trialdate. Idid not receive a copy of the letter by email.
14. On September 8, 2020, upon receipt of the proposed stipulation from Mr.
Nangano’s office, Isigned and returned the stipulation. A true and correct copy of my
correspondence with Mr. Nangano’s office on that date isattached hereto as Exhibit 7.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
10
11 Executed on October {§ 2020, at Danville, California.
‘aM
12
13
EY Ax,MORGAN
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DECLARATION OF LINDSEY A. MORGAN IN SUPPORT OF PACIFIC UNION INTERNATIONAL, INC.’S
REPLY BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY,
SUMMARY ADJUDICATION OF ISSUES
Exhibit 1
Lindsey Morgan
From: Shannon B.Jones Law Group Inc.
Sent: Friday, August 7,2020 8:00 AM
To: mnangano@lacounsel.com
Cc: Shannon B.Jones; Lindsey Morgan; Iskidmore@asilaw.org; PattiPoole
Subject: PacificUnion International, Inc.v.Ludwick, et al./ Case No. SCV0042080
Attachments: SBJ-Nangano re stipulationto continue trial8-7-20.pdf
Attached please find correspondence from Shannon Jones. Please feel free to contact Ms. Jones at shjicshj-
/aw.com or (925) 837-2315 if you have any questions.
Shannon B. Jones Law Group, Inc.
208 W. El Pintado Road
Danville, CA 94526
Main: (925) 837-2317
Fax: (925) 837-4831
www.calrealestatelaw.com
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The foregoing name, telephone, telecopy and email information isprovided to the recipientforinformational purposes only and is
not intended to be the signatureof the sender forpurposes ofbinding the sender or Shannon B.Jones Law Group, orany clientof
the sender or the firm,toany contract or agreement under the Uniform ElectronicTransactions Actor any similarlaw.
PRIVILEGE & CONFIDENTIALITY NOTICE
This email and allattachments are CONFIDENTIAL and intended SOLELY forthe recipientsas identifiedinthe “to,”“cc” and “bcc”
linesof thisemail. Ifyou are notan intended recipient,
your receiptofthisemail and its
attachments isthe resultof aninadvertent
disclosureor unauthorized transmittal.Ifyou have receivedthiselectronicmail in error,pleasenotifythe sender immediately by
replyingto thiselectronicmail or by calling
(925) 837-2317 Sender reserves and asserts all
rightsto confidentiality,
includingall
privilegesthat may apply. Pursuant to those rightsand privileges,immediately DELETE and DESTROY all
copies of theemail and its
attachments, inwhatever form, and immediately NOTIFY the sender of your receiptof thisemail. DO NOT review, copy,forward, or
relyon the email and itsattachments inany way. NOTICE: NO DUTIES ARE ASSUMED, INTENDED, OR CREATED BY THIS
COMMUNICATION. If youhave not executed afee contract oran engagement letter,
thisfirm does NOT represent you as your
attorney.
7oe Sa cree a a ee ca ee “eee marl
SHANNON B. JONES LAW GROUP, INC.
Writer'sDirectNo.: (925) 837-2317
Writer’sDirect Email: sha shj-law.com
August 7, 2020
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: Pacific Union International, Inc. v. Ludwick, et al.
Case No: SCV0042080
Dear Mr. Nangano:
Enclosed is a proposed stipulation to continue the trialdate and allrelated pre-
trialmotion and discovery deadlines from the current September 21, 2020 date. Please let us
know if you have comments or proposed revisions to the stipulation, and whether a proposed
new trialdate of March 29, 2021 is acceptable for your office and your client.
That isour firstavailable trial date next year, and the date we believe is realistic,
in light of your petition to coordinate with the California Judicial Council and the practicalities
of the COVID-19 trial delays.
We will prepare and file the motion after finalizing the stipulation.
Very truly yours,
&
Ke
SHANNON B. JONES
SBJ:lam
Enclosure: As noted
Danville | 208W. El PintadoRoad, Danville,CA 94526 -Tel: (925)837-2317 -Fax: (925) 837-4831
Sacramento | 770L Street,Suite950, Sacramento,CA 95814 : Tel:(916) 368-1000
San Jose |111North Market Street,
Suite300, San Jose,CA 95113 -Tel: (408) 363-3635
(Pleaserespond to DanvilleOffice) |www.calrealestatelaw.com
Michael A.J. Nangano, Esq.
August 7, 2020
Page 2
ce (via email): Lawrence E. Skidmore, Esq.
Patti Poole
Lindsey A. Morgan, Esq.
SHANNON B. JONES LAW GROUP, INC.
SHANNON B. JONES (Bar No. 149222)
sbjesbj-law.com
LINDSEY A. MORGAN (Bar No. 274214)
lanka shj-law.com
208 W. El Pintado Road
Danville, California 94526
Telephone: (925) 837-2317
Facsimile: (925) 837-4831
Attorneys for Plaintiff
PACIFIC UNION INTERNATIONAL, INC.
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF PLACER
10
11 PACIFIC UNION INTERNATIONAL, INC., ) Case No. SCV0042080
12 i )
Plaintiff, STIPULATION TO CONTINUE THE
13 vy. ) TRIAL DATE AND [PROPOSED] ORDER
14 )
ERIK LUDWICK, an individual and )
beneficiary of The Anything Trust Dated ) Complaint Filed: November 7, 2018
15 October 12, 2007; THE ANYTHING TRUST ) Trial Date: September 21, 2020
DATED OCTOBER 12, 2007; PAUL D. )
16 BOOTH, inhis capacity as trustee of The ) .
17
Anything Trust Dated October 12, 2007; and} Proposed Trial Date: March 29, 2021
DOES 1-50, )
18 )
Defendants. )
)
19
20
21 Plaintiff PACIFIC UNION INTERNATIONAL, INC. (“Plaintiff”) and
22 Defendants ERIK LUDWICK, an individual and beneficiary of The Anything Trust Dated
23 October 12, 2007, THE ANYTHING TRUST DATED OCTOBER 12, 2007 and PAUL D.
24 BOOTH, inhis capacity as trustee of The Anything Trust Dated October 12, 2007 (collectively,
25 “Defendants”) stipulate, through their counsel of record, as follows:
26 ile This action arises from a dispute between Plaintiff and Defendants
27 regarding a commission from the sale of real property.
28 ///
STIPULATION TO CONTINUE THE TRIAL DATE AND [PROPOSED] ORDER
2. This action ispresently scheduled for trialto commence on September 21,
2020.
3. There has been one previous request for trialcontinuance in this matter,
when trialwas set in June 2020 during the peak of the COVID-19 related court closures.
4, The parties have completed written discovery and party depositions.
Accordingly, the parties do not seek the continuance of non-expert discovery deadlines.
5. The parties have each submitted a dispositive motion. Defendants’ motion
for summary judgment is fully briefed and set for hearing on August 13, 2020. Plaintiff's motion
for summary judgment is set for hearing on August 20, 2020.
10 6. On July 17, 2020, Defendants submitted a petition for coordination to the
1 California Judicial Council, seeking to coordinate this matter and a related matter Defendants
12 filed in Los Angeles Superior Court, and requesting a stay. No hearing date has been set on that
13 petition, which Plaintiff intends to oppose. Plaintiff, however, would like to continue the trial
14 until ithas guidance from the Judicial Council on whether the matters will be coordinated in
15 another county or not.
16 7. Preparing for the quickly approaching trialdate has been hampered and
17 complicated by the realities of the COVID-19 shelter in place orders, social distancing
18 requirements, and travel by some of the parties from Los Angeles to Placer County.
19 8. Plaintiff's counsel’s trialschedule has been severely impacted by COVID-
20 19 related trialcontinuances, many of which were unilaterally set by courts with no involvement
21 by counsel, and as a result, counsel for Plaintiffs has adouble or triple set trialschedule nearly
22 every week until March 2021.
23 9, The parties need additional time to work toward settlement and attend
24 mediation or a settlement conference.
25 10. Expert discovery has not yet started in this matter.
26 11. Accordingly, the parties respectfully request a continuance of the trialdate
27 to March 29, 2021, in order to obtain a ruling from the Judicial Council on Defendants’ petition
28 to coordinate, conduct expert discovery, wait for the recent COVID-19 surge of cases to abate,
ak pe
STIPULATION TO CONTINUE THE TRIAL DATE AND [PROPOSED] ORDER
and to either mediate this matter or attend a settlement conference.
12. The parties do not seek this continuance for purposes of delay or for any
other improper purpose. The parties agree that a continuance of the trialdate isin the best
interests of the parties, and will serve the interests of judicial economy and efficiency. The
f
parties stipulate that a continuance of the trial and pre-trial expert related discovery dates and
ws
deadlines isnecessary for effective preparation for trial.
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13. The parties stipulate and agree good cause exists for a continuance
a
pursuant to California Rule of Court 3.1332(d) for the following reasons: (1) the Parties in the
action agree that there isa need to continue the trial date in order to obtain clarification from the
10 Judicial Council on whether this matter will be coordinated with the Los Angeles matter, finalize
11 their investigations, and potentially mediate the matter to resolve the dispute and avoid trial;(2)
12 there has been one previous continuance of the trial date which would have occurred anyhow, as
13 trialwas in the middle of the COVID-19 related shelter in place orders, and there has been no
14 delay in the preparation of the case for trial; (3) the length of the requested continuance is
15 relatively short given the realities of the petition and the international pandemic, and the parties
16 to the instant action will not suffer prejudice by a continuance; (4) all parties and counsel agree
17 to the continuance, and affirmatively request the continuance pursuant to this stipulation; (5) the
18 efforts of the parties to prepare fortrial have been severely impacted by the COVID-19 related
19 shelter in place orders; and (6) the interests ofjustice will be served by a continuance.
20 14.‘ The parties stipulate and jointly request that the September 21, 2020 trial
21 date be continued to March 29, 2021, or a date thereafter convenient for the Court.
22 ///
23 {if
24 ///
25 //1
26 //I
27 ///
28 ///
- - 3 ——
STIPULATION TO CONTINUE THE TRIAL DATE AND [PROPOSED] ORDER
15. The parties further stipulate and jointly request that discovery be
considered closed and that only pre-trial expert discovery related deadlines dates and deadlines
shall be calculated based on the new trialdate.
IT IS SO STIPULATED.
Dated: August _, 2020 SHANNON B. JONES LAW GROUP, INC.
By
SHANNON B. JONES, ESQ.
Attorneys for Plaintiff,
PACIFIC UNION INTERNATIONAL, INC.
10
MICHAEL A.J. NANGANO, A LAW
11 CORPORATION
12
By:
13 MICHAEL A.J. NANGANO, ESQ.
Attorneys for Defendants
14 ERIK LUDWICK, an individual and beneficiary
of The Anything Trust Dated October 12, 2007;
15
THE ANYTHING TRUST DATED OCTOBER
16 12, 2007; and PAUL D. BOOTH, in his capacity
as trustee of The Anything Trust
17 Dated October 12, 2007
18 ORDER
19
IT IS SO ORDERED.
20
21 Dated:
JUDGE OF THE SUPERIOR COURT
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4
STIPULATION TO CONTINUE THE TRIAL DATE AND [PROPOSED] ORDER
Exhibit 2
Lindsey Morgan
From: Lindsey Morgan
Sent: Wednesday, August 12,2020 12:21 PM
To: mnangano@lacounsel.com
Cc: ‘Shannon B.Jones’; PattiPoole
Subject: PacificUnion International, Inc.v.Ludwick, et al.-stipulation to continue trial
Mike —
We previously indicted that we would file amotion to continue trial. When we called to obtain a hearing date on the
motion to continue trial,however, the clerk instructed us to filethe stipulation and aproposed order alone, without a
noticed motion. The clerk indicated that this was not the Court’s usual procedure, but said the Court istrying to simplify
and expedite the trialcontinuance process in thisunusual time.
Accordingly, we are submitting the stipulation you have already executed and a proposed order to continue the trial,
instead offilinga noticed motion. You willreceive service copies later today. Please feel free to letus know ifyou have
any questions.
Thank you,
Lindsey A.Morgan
Shannon B.Jones Law Group, Inc.
208 W. El Pintado Road
Danville, CA 94526
Direct: (925) 837-5577 ext. 317
Main: (925) 837-2317
Fax: (925) 837-4831
sbj-law.com
www.calrealestatelaw.com
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The foregoing name, telephone, telecopy and email information isprovided to the recipientforinformational purposes only and is
not intended to be the signatureof the sender forpurposes ofbinding the sender or Shannon B.Jones Law Group, orany clientof
the sender or thefirm, toany contract or agreement under the Uniform ElectronicTransactions Actor any similarlaw.
PRIVILEGE & CONFIDENTIALITY NOTICE
This emailand all
attachments are CONFIDENTIAL and intended SOLELY forthe recipientsas identifiedinthe “to,”“ce” and “bcc”
linesof thisemail. if youare notan intended recipient,
your receipt ofthisemail and itsattachments isthe resultofan inadvertent
disclosureor unauthorized transmittal.If youhave received thiselectronicmail inerror, pleasenotifythe sender immediately by
replyingto thiselectronicmail or bycalling(925) 837-2317. Sender reserves and asserts all
rightsto confidentiality,
includingall
privilegesthatmay apply. Pursuant to those rightsand privileges,immediately DELETE and DESTROY all
copies ofthe email and its
attachments, in whatever form, and immediately NOTIFY the sender ofyour receiptofthisemail. DO NOT review,copy, forward, or
relyon the email and itsattachments inany way. NOTICE: NO DUTIES ARE ASSUMED, INTENDED, OR CREATED BYTHIS
COMMUNICATION. Ifyou have not executed afee contractor an engagement letter,
thisfirm does NOT represent you asyour
attorney.
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Exhibit 3
ere
Placer County Superior Court
Receipt
Your case is being sent to CMS
Filing Sent
Filing Title
Stipulation to Continue the Trial Date and [Proposed] Order
Status
Submitted
Filing Date
08/12/2020 02:42:10 pm
Filed By
Paula Case
JTI Ref. No.
3493d05a1f37
Received By
Journal Tech EFSP
Payments
$ 24.50
“- Start Another Filing QView My Filings Print This Page
Copyright © Journal Technologies, USA. All rights reserved.
Exhibit 4
Lindsey Morgan
From: Shannon B.Jones Law Group Inc.
Sent: Wednesday, August 12,2020 2:45 PM
To: mnangano @lacounsel.com; patti@lacounsel.com; Iskidmore@asilaw.org
Cc: Shannon B.Jones; Lindsey Morgan
Subject: PacificUnion International, Inc.v.Ludwick, et al.-ELECTRONIC SERVICE
Attachments: Stip and Proposed Order 8-12-20.pdf; Proposed Order Granting MTC 8-12-20.pdf; Stip-
POS 8-12-20.pdf
The attached is sent at the request of Shannon B. Jones. Please feel free to contact Ms. Jones at shjiashi-
fae.com or (925) 837-2315 if you have questions.
Shannon B. Jones Law Group, Inc.
208 W. El Pintado Road
Danville, CA 94526
Main: (925) 837-2317
Fax: (925) 837-483 |
www.calrealestatelaw.com
Cee eeedShe RES Eade ERE HESSep cekee ee a ke ee
The foregoing name, telephone, telecopy and email information isprovided to the recipientforinformationa! purposes only and is
not intended to be the signatureof the sender forpurposes ofbinding the sender or Shannon B.Jones Law Group, orany clientof
the sender or thefirm, toany contract or agreement under the Uniform ElectronicTransactions Actor any similarlaw.
PRIVILEGE & CONFIDENTIALITY NOTICE
This emailand all
attachments are CONFIDENTIAL and intended SOLELY forthe recipientsas identifiedinthe “to,”“cc” and “bcc”
jinesof thisemail. Ifyou are notan intended recipient,
your receipt ofthisemail and itsattachments isthe resultofan inadvertent
disclosureor unauthorized transmittal.If youhave received thiselectronic mailinerror, pleasenotifythe sender immediately by
replyingto thiselectronicmail or by calling
(925) 837-2317. Sender reserves and asserts all
rightsto confidentiality,
includingall
privilegesthatmay apply. Pursuant to those rightsand privileges,immediately DELETE and DESTROY all
copies of theemail and its
attachments, inwhatever fori, and immediately NOTIFY the sender ofyour receiptofthis email. DO NOT review, copy,forward, or
relyon the email and itsattachments inany way. NOTICE: NO DUTIES ARE ASSUMED, INTENDED, OR CREATED BYTHIS
COMMUNICATION. Ifyou have not executed afee contract oran engagement letter,
thisfirm does NOT represent you as your
attorney
SE ee eee nce “ae tReeT mal)
SHANNON B. JONES LAW GROUP, INC.
SHANNON B. JONES (Bar No. 149222)
shh sif-law cont
LINDSEY A. MORGAN (Bar No. 274214)
Iie shy-biy cant
208 W. El Pintado Road
Danville, California 94526
Telephone: (925) 837-2317
Facsimile: (925) 837-4831
Attorneys forPlaintiff
PACIFIC UNION INTERNATIONAL, INC,
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF PLACER
10
11 PACIFIC UNION INTERNATIONAL, INC., Case No. SCV0042080
12 ae
Plaintiff, STIPULATION TO CONTINUE THE
Ne
13
ee
Em TRIAL DATE AND [PROPOSED] ORDER
Ne
14
Ne
ERIK LUDWICK, an individual and
ee
beneficiary of The Anything Trust Dated Complaint Filed: November 7, 2018
15
ee
October 12, 2007; THE ANYTHING TRUST Trial Date: September 21, 2020
DATED OCTOBER 12, 2007; PAUL D.
16
ee
BOOTH, in his capacity as trustee of The
Proposed Trial Date: March 29, 2021
ee
Anything Trust Dated October 12, 2007; and
17 DOES 1-50,
ee
18
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Defendants.
19
me
20
21 Plaintiff PACIFIC UNION INTERNATIONAL, INC. (“Plaintiff”) and
22 Defendants ERIK LUDWICK, an individual and beneficiary ofThe Anything Trust Dated
23 October 12, 2007, THE ANYTHING TRUST DATED OCTOBER 12, 2007 and PAUL D.
24 BOOTH, in his capacity astrustee ofThe Anything Trust Dated October 12, 2007 (collectively,
25 “Defendants’) stipulate,through their counsel of record, as follows:
26 1, This action arises from a dispute
Preview
ELECTRONICALLY FILED superior Court of California, County of Placer SHANNON B. JONES LAW GROUP, INC. 10/16/2020 SHANNON B. JONES (Bar No. 149222) By: LaurelSanders, Deputy Clerk sbi/@isbj-law.com LINDSEY A. MORGAN (Bar No. 274214) lam@sbj-law.com 208 W. El Pintado Road Danville, California 94526 Telephone: (925) 837-2317 Facsimile: (925) 837-4831 Attorneys for Plaintiff PACIFIC UNION INTERNATIONAL, INC. IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF PLACER 10 11 PACIFIC UNION INTERNATIONAL, INC., ) Case No. SCV0042080 12 ) Plaintiff, ) DECLARATION OF LINDSEY A. 13 ) MORGAN IN SUPPORT OF PACIFIC Ve UNION INTERNATIONAL, INC.’S 14 OPPOSITION TO DEFENDANTS’ ERIK LUDWICK, an individual and ) MOTION FOR ReCG eae ON beneficiary of The Anything Trust Dated ) AND/OR RELIEF UNDER SECTION 472 15 October 12, 2007; THE ANYTHING TRUST ) OF THE CODE OF CIVIL PROCEDURE DATED OCTOBER 12, 2007; PAUL D. ) 16 BOOTH, in his capacity as trustee of The ) Anything Trust Dated October 12,2007; and ) — Date: October 29, 2020 17 DOES 1-50, ) Time: 8:30 a.m. ) Dept: 42 18 Defendants. ) 19 ) Complaint Filed: November 7, 2018 Trial Date: March 29, 2021 20 21 22 I,Lindsey A. Morgan, declare: 23 1. I am an attorney licensed to practice in the State of California, and Iam a 24 lawyer with the Shannon B. Jones Law Group, Inc., counsel of record for Plaintiff PACIFIC 25 UNION INTERNATIONAL, INC. (“Pacific Union”). By virtue of that representation, I have 26 personal knowledge of the facts set forth in this declaration and if called upon to testify, Icould 27 and would competently testify thereto, except as to those matters stated upon information and 28 belief and as to those matters, Iam informed and believe them to be true. DECLARATION OF LINDSEY A. MORGAN IN SUPPORT OF PACIFIC UNION INTERNATIONAL, INC.’S REPLY BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES 2. On August 7, 2020, my office sent a letterand a proposed stipulation to continue the trialdate in this matter from September 21, 2020 to March 29, 2021 to counsel for Defendants. The documents were attached as two separate pdf files to a single email. A true and correct copy of the correspondence and stipulation my office sent to Mr. Nangano’s office is attached hereto as Exhibit 1. 3. I prepared the cover letter enclosing the stipulation to continue trial by copying over the cover letter from my office’s earlier stipulation to continue trialand all] related dates. The letter as sent contained a typographical error where I inadvertently neglected to delete the phrase “and allrelated dates” from the description of the stipulation. 10 4, I did not have any knowledge that counsel for Defendants desired to take 11 any further depositions or engage in any additional discovery when my office prepared and 12 circulated the stipulation to continue trial. Mr. Nangano’s office stated that Defendants did not 13 intend to depose Sarah Kosasky as of June 2, 2020 (see Exhibit G to Mr. Nangano’s declaration), 14 and there has not been no communication between the parties regarding depositions since Pacific 15 Union deposed Erik Ludwick on June 16, 2020. As both parties have filed and fully briefed their 16 respective Motions for Summary Judgment, and discovery was closing based on the September 17 2020 trialdate, itwas my understanding that we had finished discovery in this matter. 18 5. The stipulation itself,including the language in Paragraph 15, immediately 19 above Defendants’ counsel’s signature block, was very clear that the stipulation was for the 20 purpose of continuing the trialdate, but not all related deadlines. 21 6. Mr. Nangano executed the stipulation on behalf of Defendants and returned 22 itto my office by email on August 10, 2012, without comment. 23 7. After receiving Mr. Nangano’s signature page, I called the Court on August 24 12, 2020 to schedule a hearing date on a stipulated motion to continue trial. The clerk asked me if 25 the request to continue trial was stipulated, and Ianswered affirmatively. The clerk then instructed 26 me to simply submit the stipulation and a proposed order instead of filing a motion. She stated the 27 Court did not usually do itthat way, but was attempting to make it easier for litigants in light of the 2 28 DECLARATION OF LINDSEY A. MORGAN IN SUPPORT OF PACIFIC UNION INTERNATIONAL, INC.’S REPLY BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES scheduling difficulties presented by the COVID-19 pandemic and related trial availability problems. I immediately sent an email to counsel for Defendants, indicating that the clerk had instructed Pacific Union to file the stipulation and a proposed order. A true and correct copy of my August 12, 2020 email to Mr. Nangano and his assistant, Patti Poole, advising them of this development is attached hereto as Exhibit 2. 8. My office filed the stipulation and a proposed order copied from the stipulation on August 12, 2020 — a date that isreflected on the time stamp on the sidebar of the Court’s order. A true and correct copy of the filing receipt is attached hereto as Exhibit 3. 9. My office served Mr. Nangano’s office on August 12, 2020 with the 10 stipulation and proposed order continuing trial. A true and correct copy of the email serving the 11 documents on Mr. Nangano’s office on August 12, 2020 is attached hereto as Exhibit 4. 12 10. I did not hear from Mr. Nangano again until five days later,on August 17, 13 2020, when his office sent me an email at 3:54 p.m. attaching a letter. The letter demanded that 14 the stipulation be withdrawn. A true and correct copy of that email and the attached letter is 15 attached hereto as Exhibit 5. 16 11. Upon receipt of Mr. Nangano’s letter on August 17, 2020, Ipromptly called 17 the Court to request that the stipulation be withdrawn. I was not able to get through to the Court, 18 which had closed at 3:00 p.m. that day. On information and belief, this was due to eithera fire 19 concern or a heat wave on that particular day. I also accessed our firm’s electronic filing account 20 and attempted to withdraw the stipulation, but there was not method by which Icould do so. 21 12. The next morning, the order entering the stipulation had been entered on the 22 docket. My office responded to Mr. Nangano’s letter on August 18, 2020, explaining that we had 23 attempted to call the Court and had also attempted to withdraw the stipulation electronically, but 24 were unable to do so. We attached the order, which the Court had entered. A true and correct 25 copy of that correspondence is attached hereto as Exhibit 6. My office then filed a notice of entry 26 of order. 27 3 28 DECLARATION OF LINDSEY A. MORGAN IN SUPPORT OF PACIFIC UNION INTERNATIONAL, INC.’S REPLY BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES 13. I heard nothing else about the matter until September 8, 2020, when I received a hard copy of an August 28, 2020 letter full of accusations of improper conduct from Mr. Nangano’s office, threatening to file this motion and attaching a stipulation to extend the discovery deadlines in conjunction with the new trialdate. Idid not receive a copy of the letter by email. 14. On September 8, 2020, upon receipt of the proposed stipulation from Mr. Nangano’s office, Isigned and returned the stipulation. A true and correct copy of my correspondence with Mr. Nangano’s office on that date isattached hereto as Exhibit 7. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 10 11 Executed on October {§ 2020, at Danville, California. ‘aM 12 13 EY Ax,MORGAN 14 15 16 17 18 19 20 21 22 23 24 25 26 27 4 28 DECLARATION OF LINDSEY A. MORGAN IN SUPPORT OF PACIFIC UNION INTERNATIONAL, INC.’S REPLY BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES Exhibit 1 Lindsey Morgan From: Shannon B.Jones Law Group Inc. Sent: Friday, August 7,2020 8:00 AM To: mnangano@lacounsel.com Cc: Shannon B.Jones; Lindsey Morgan; Iskidmore@asilaw.org; PattiPoole Subject: PacificUnion International, Inc.v.Ludwick, et al./ Case No. SCV0042080 Attachments: SBJ-Nangano re stipulationto continue trial8-7-20.pdf Attached please find correspondence from Shannon Jones. Please feel free to contact Ms. Jones at shjicshj- /aw.com or (925) 837-2315 if you have any questions. Shannon B. Jones Law Group, Inc. 208 W. El Pintado Road Danville, CA 94526 Main: (925) 837-2317 Fax: (925) 837-4831 www.calrealestatelaw.com 3 oe oe fe ER RO KCK 2 Cooo oe oe eS ee2 i i ae fe eooRaE Ck ok The foregoing name, telephone, telecopy and email information isprovided to the recipientforinformational purposes only and is not intended to be the signatureof the sender forpurposes ofbinding the sender or Shannon B.Jones Law Group, orany clientof the sender or the firm,toany contract or agreement under the Uniform ElectronicTransactions Actor any similarlaw. PRIVILEGE & CONFIDENTIALITY NOTICE This email and allattachments are CONFIDENTIAL and intended SOLELY forthe recipientsas identifiedinthe “to,”“cc” and “bcc” linesof thisemail. Ifyou are notan intended recipient, your receiptofthisemail and its attachments isthe resultof aninadvertent disclosureor unauthorized transmittal.Ifyou have receivedthiselectronicmail in error,pleasenotifythe sender immediately by replyingto thiselectronicmail or by calling (925) 837-2317 Sender reserves and asserts all rightsto confidentiality, includingall privilegesthat may apply. Pursuant to those rightsand privileges,immediately DELETE and DESTROY all copies of theemail and its attachments, inwhatever form, and immediately NOTIFY the sender of your receiptof thisemail. DO NOT review, copy,forward, or relyon the email and itsattachments inany way. NOTICE: NO DUTIES ARE ASSUMED, INTENDED, OR CREATED BY THIS COMMUNICATION. If youhave not executed afee contract oran engagement letter, thisfirm does NOT represent you as your attorney. 7oe Sa cree a a ee ca ee “eee marl SHANNON B. JONES LAW GROUP, INC. Writer'sDirectNo.: (925) 837-2317 Writer’sDirect Email: sha shj-law.com August 7, 2020 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: Pacific Union International, Inc. v. Ludwick, et al. Case No: SCV0042080 Dear Mr. Nangano: Enclosed is a proposed stipulation to continue the trialdate and allrelated pre- trialmotion and discovery deadlines from the current September 21, 2020 date. Please let us know if you have comments or proposed revisions to the stipulation, and whether a proposed new trialdate of March 29, 2021 is acceptable for your office and your client. That isour firstavailable trial date next year, and the date we believe is realistic, in light of your petition to coordinate with the California Judicial Council and the practicalities of the COVID-19 trial delays. We will prepare and file the motion after finalizing the stipulation. Very truly yours, & Ke SHANNON B. JONES SBJ:lam Enclosure: As noted Danville | 208W. El PintadoRoad, Danville,CA 94526 -Tel: (925)837-2317 -Fax: (925) 837-4831 Sacramento | 770L Street,Suite950, Sacramento,CA 95814 : Tel:(916) 368-1000 San Jose |111North Market Street, Suite300, San Jose,CA 95113 -Tel: (408) 363-3635 (Pleaserespond to DanvilleOffice) |www.calrealestatelaw.com Michael A.J. Nangano, Esq. August 7, 2020 Page 2 ce (via email): Lawrence E. Skidmore, Esq. Patti Poole Lindsey A. Morgan, Esq. SHANNON B. JONES LAW GROUP, INC. SHANNON B. JONES (Bar No. 149222) sbjesbj-law.com LINDSEY A. MORGAN (Bar No. 274214) lanka shj-law.com 208 W. El Pintado Road Danville, California 94526 Telephone: (925) 837-2317 Facsimile: (925) 837-4831 Attorneys for Plaintiff PACIFIC UNION INTERNATIONAL, INC. IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF PLACER 10 11 PACIFIC UNION INTERNATIONAL, INC., ) Case No. SCV0042080 12 i ) Plaintiff, STIPULATION TO CONTINUE THE 13 vy. ) TRIAL DATE AND [PROPOSED] ORDER 14 ) ERIK LUDWICK, an individual and ) beneficiary of The Anything Trust Dated ) Complaint Filed: November 7, 2018 15 October 12, 2007; THE ANYTHING TRUST ) Trial Date: September 21, 2020 DATED OCTOBER 12, 2007; PAUL D. ) 16 BOOTH, inhis capacity as trustee of The ) . 17 Anything Trust Dated October 12, 2007; and} Proposed Trial Date: March 29, 2021 DOES 1-50, ) 18 ) Defendants. ) ) 19 20 21 Plaintiff PACIFIC UNION INTERNATIONAL, INC. (“Plaintiff”) and 22 Defendants ERIK LUDWICK, an individual and beneficiary of The Anything Trust Dated 23 October 12, 2007, THE ANYTHING TRUST DATED OCTOBER 12, 2007 and PAUL D. 24 BOOTH, inhis capacity as trustee of The Anything Trust Dated October 12, 2007 (collectively, 25 “Defendants”) stipulate, through their counsel of record, as follows: 26 ile This action arises from a dispute between Plaintiff and Defendants 27 regarding a commission from the sale of real property. 28 /// STIPULATION TO CONTINUE THE TRIAL DATE AND [PROPOSED] ORDER 2. This action ispresently scheduled for trialto commence on September 21, 2020. 3. There has been one previous request for trialcontinuance in this matter, when trialwas set in June 2020 during the peak of the COVID-19 related court closures. 4, The parties have completed written discovery and party depositions. Accordingly, the parties do not seek the continuance of non-expert discovery deadlines. 5. The parties have each submitted a dispositive motion. Defendants’ motion for summary judgment is fully briefed and set for hearing on August 13, 2020. Plaintiff's motion for summary judgment is set for hearing on August 20, 2020. 10 6. On July 17, 2020, Defendants submitted a petition for coordination to the 1 California Judicial Council, seeking to coordinate this matter and a related matter Defendants 12 filed in Los Angeles Superior Court, and requesting a stay. No hearing date has been set on that 13 petition, which Plaintiff intends to oppose. Plaintiff, however, would like to continue the trial 14 until ithas guidance from the Judicial Council on whether the matters will be coordinated in 15 another county or not. 16 7. Preparing for the quickly approaching trialdate has been hampered and 17 complicated by the realities of the COVID-19 shelter in place orders, social distancing 18 requirements, and travel by some of the parties from Los Angeles to Placer County. 19 8. Plaintiff's counsel’s trialschedule has been severely impacted by COVID- 20 19 related trialcontinuances, many of which were unilaterally set by courts with no involvement 21 by counsel, and as a result, counsel for Plaintiffs has adouble or triple set trialschedule nearly 22 every week until March 2021. 23 9, The parties need additional time to work toward settlement and attend 24 mediation or a settlement conference. 25 10. Expert discovery has not yet started in this matter. 26 11. Accordingly, the parties respectfully request a continuance of the trialdate 27 to March 29, 2021, in order to obtain a ruling from the Judicial Council on Defendants’ petition 28 to coordinate, conduct expert discovery, wait for the recent COVID-19 surge of cases to abate, ak pe STIPULATION TO CONTINUE THE TRIAL DATE AND [PROPOSED] ORDER and to either mediate this matter or attend a settlement conference. 12. The parties do not seek this continuance for purposes of delay or for any other improper purpose. The parties agree that a continuance of the trialdate isin the best interests of the parties, and will serve the interests of judicial economy and efficiency. The f parties stipulate that a continuance of the trial and pre-trial expert related discovery dates and ws deadlines isnecessary for effective preparation for trial. HD 13. The parties stipulate and agree good cause exists for a continuance a pursuant to California Rule of Court 3.1332(d) for the following reasons: (1) the Parties in the action agree that there isa need to continue the trial date in order to obtain clarification from the 10 Judicial Council on whether this matter will be coordinated with the Los Angeles matter, finalize 11 their investigations, and potentially mediate the matter to resolve the dispute and avoid trial;(2) 12 there has been one previous continuance of the trial date which would have occurred anyhow, as 13 trialwas in the middle of the COVID-19 related shelter in place orders, and there has been no 14 delay in the preparation of the case for trial; (3) the length of the requested continuance is 15 relatively short given the realities of the petition and the international pandemic, and the parties 16 to the instant action will not suffer prejudice by a continuance; (4) all parties and counsel agree 17 to the continuance, and affirmatively request the continuance pursuant to this stipulation; (5) the 18 efforts of the parties to prepare fortrial have been severely impacted by the COVID-19 related 19 shelter in place orders; and (6) the interests ofjustice will be served by a continuance. 20 14.‘ The parties stipulate and jointly request that the September 21, 2020 trial 21 date be continued to March 29, 2021, or a date thereafter convenient for the Court. 22 /// 23 {if 24 /// 25 //1 26 //I 27 /// 28 /// - - 3 —— STIPULATION TO CONTINUE THE TRIAL DATE AND [PROPOSED] ORDER 15. The parties further stipulate and jointly request that discovery be considered closed and that only pre-trial expert discovery related deadlines dates and deadlines shall be calculated based on the new trialdate. IT IS SO STIPULATED. Dated: August _, 2020 SHANNON B. JONES LAW GROUP, INC. By SHANNON B. JONES, ESQ. Attorneys for Plaintiff, PACIFIC UNION INTERNATIONAL, INC. 10 MICHAEL A.J. NANGANO, A LAW 11 CORPORATION 12 By: 13 MICHAEL A.J. NANGANO, ESQ. Attorneys for Defendants 14 ERIK LUDWICK, an individual and beneficiary of The Anything Trust Dated October 12, 2007; 15 THE ANYTHING TRUST DATED OCTOBER 16 12, 2007; and PAUL D. BOOTH, in his capacity as trustee of The Anything Trust 17 Dated October 12, 2007 18 ORDER 19 IT IS SO ORDERED. 20 21 Dated: JUDGE OF THE SUPERIOR COURT 22 23 24 25 26 27 28 4 STIPULATION TO CONTINUE THE TRIAL DATE AND [PROPOSED] ORDER Exhibit 2 Lindsey Morgan From: Lindsey Morgan Sent: Wednesday, August 12,2020 12:21 PM To: mnangano@lacounsel.com Cc: ‘Shannon B.Jones’; PattiPoole Subject: PacificUnion International, Inc.v.Ludwick, et al.-stipulation to continue trial Mike — We previously indicted that we would file amotion to continue trial. When we called to obtain a hearing date on the motion to continue trial,however, the clerk instructed us to filethe stipulation and aproposed order alone, without a noticed motion. The clerk indicated that this was not the Court’s usual procedure, but said the Court istrying to simplify and expedite the trialcontinuance process in thisunusual time. Accordingly, we are submitting the stipulation you have already executed and a proposed order to continue the trial, instead offilinga noticed motion. You willreceive service copies later today. Please feel free to letus know ifyou have any questions. Thank you, Lindsey A.Morgan Shannon B.Jones Law Group, Inc. 208 W. El Pintado Road Danville, CA 94526 Direct: (925) 837-5577 ext. 317 Main: (925) 837-2317 Fax: (925) 837-4831 sbj-law.com www.calrealestatelaw.com iekeke a eea a afe ofc ico akc ok a oa ae oe ce oe keie oe ee 2 oe i oe eoae ae ok a The foregoing name, telephone, telecopy and email information isprovided to the recipientforinformational purposes only and is not intended to be the signatureof the sender forpurposes ofbinding the sender or Shannon B.Jones Law Group, orany clientof the sender or thefirm, toany contract or agreement under the Uniform ElectronicTransactions Actor any similarlaw. PRIVILEGE & CONFIDENTIALITY NOTICE This emailand all attachments are CONFIDENTIAL and intended SOLELY forthe recipientsas identifiedinthe “to,”“ce” and “bcc” linesof thisemail. if youare notan intended recipient, your receipt ofthisemail and itsattachments isthe resultofan inadvertent disclosureor unauthorized transmittal.If youhave received thiselectronicmail inerror, pleasenotifythe sender immediately by replyingto thiselectronicmail or bycalling(925) 837-2317. Sender reserves and asserts all rightsto confidentiality, includingall privilegesthatmay apply. Pursuant to those rightsand privileges,immediately DELETE and DESTROY all copies ofthe email and its attachments, in whatever form, and immediately NOTIFY the sender ofyour receiptofthisemail. DO NOT review,copy, forward, or relyon the email and itsattachments inany way. NOTICE: NO DUTIES ARE ASSUMED, INTENDED, OR CREATED BYTHIS COMMUNICATION. Ifyou have not executed afee contractor an engagement letter, thisfirm does NOT represent you asyour attorney. eia i fe ESESe ak oe eea a oe ok ok oie ke oe ok ae oi oe oe kc kc eo oe a ae oe kcoe a oi ai a oe Exhibit 3 ere Placer County Superior Court Receipt Your case is being sent to CMS Filing Sent Filing Title Stipulation to Continue the Trial Date and [Proposed] Order Status Submitted Filing Date 08/12/2020 02:42:10 pm Filed By Paula Case JTI Ref. No. 3493d05a1f37 Received By Journal Tech EFSP Payments $ 24.50 “- Start Another Filing QView My Filings Print This Page Copyright © Journal Technologies, USA. All rights reserved. Exhibit 4 Lindsey Morgan From: Shannon B.Jones Law Group Inc. Sent: Wednesday, August 12,2020 2:45 PM To: mnangano @lacounsel.com; patti@lacounsel.com; Iskidmore@asilaw.org Cc: Shannon B.Jones; Lindsey Morgan Subject: PacificUnion International, Inc.v.Ludwick, et al.-ELECTRONIC SERVICE Attachments: Stip and Proposed Order 8-12-20.pdf; Proposed Order Granting MTC 8-12-20.pdf; Stip- POS 8-12-20.pdf The attached is sent at the request of Shannon B. Jones. Please feel free to contact Ms. Jones at shjiashi- fae.com or (925) 837-2315 if you have questions. Shannon B. Jones Law Group, Inc. 208 W. El Pintado Road Danville, CA 94526 Main: (925) 837-2317 Fax: (925) 837-483 | www.calrealestatelaw.com Cee eeedShe RES Eade ERE HESSep cekee ee a ke ee The foregoing name, telephone, telecopy and email information isprovided to the recipientforinformationa! purposes only and is not intended to be the signatureof the sender forpurposes ofbinding the sender or Shannon B.Jones Law Group, orany clientof the sender or thefirm, toany contract or agreement under the Uniform ElectronicTransactions Actor any similarlaw. PRIVILEGE & CONFIDENTIALITY NOTICE This emailand all attachments are CONFIDENTIAL and intended SOLELY forthe recipientsas identifiedinthe “to,”“cc” and “bcc” jinesof thisemail. Ifyou are notan intended recipient, your receipt ofthisemail and itsattachments isthe resultofan inadvertent disclosureor unauthorized transmittal.If youhave received thiselectronic mailinerror, pleasenotifythe sender immediately by replyingto thiselectronicmail or by calling (925) 837-2317. Sender reserves and asserts all rightsto confidentiality, includingall privilegesthatmay apply. Pursuant to those rightsand privileges,immediately DELETE and DESTROY all copies of theemail and its attachments, inwhatever fori, and immediately NOTIFY the sender ofyour receiptofthis email. DO NOT review, copy,forward, or relyon the email and itsattachments inany way. NOTICE: NO DUTIES ARE ASSUMED, INTENDED, OR CREATED BYTHIS COMMUNICATION. Ifyou have not executed afee contract oran engagement letter, thisfirm does NOT represent you as your attorney SE ee eee nce “ae tReeT mal) SHANNON B. JONES LAW GROUP, INC. SHANNON B. JONES (Bar No. 149222) shh sif-law cont LINDSEY A. MORGAN (Bar No. 274214) Iie shy-biy cant 208 W. El Pintado Road Danville, California 94526 Telephone: (925) 837-2317 Facsimile: (925) 837-4831 Attorneys forPlaintiff PACIFIC UNION INTERNATIONAL, INC, IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF PLACER 10 11 PACIFIC UNION INTERNATIONAL, INC., Case No. SCV0042080 12 ae Plaintiff, STIPULATION TO CONTINUE THE Ne 13 ee Em TRIAL DATE AND [PROPOSED] ORDER Ne 14 Ne ERIK LUDWICK, an individual and ee beneficiary of The Anything Trust Dated Complaint Filed: November 7, 2018 15 ee October 12, 2007; THE ANYTHING TRUST Trial Date: September 21, 2020 DATED OCTOBER 12, 2007; PAUL D. 16 ee BOOTH, in his capacity as trustee of The Proposed Trial Date: March 29, 2021 ee Anything Trust Dated October 12, 2007; and 17 DOES 1-50, ee 18 ee Defendants. 19 me 20 21 Plaintiff PACIFIC UNION INTERNATIONAL, INC. (“Plaintiff”) and 22 Defendants ERIK LUDWICK, an individual and beneficiary ofThe Anything Trust Dated 23 October 12, 2007, THE ANYTHING TRUST DATED OCTOBER 12, 2007 and PAUL D. 24 BOOTH, in his capacity astrustee ofThe Anything Trust Dated October 12, 2007 (collectively, 25 “Defendants’) stipulate,through their counsel of record, as follows: 26 1, This action arises from a dispute