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1 MICHAEL AJ. NANGANO(SBN 133999) 10/19/2020
Law Offices of Michael A.J. Nangano
2 133 No. Altadena Drive, Suite 403
Pasadena, CA 91107
3 Phone: (626)796-9998
Fax: (626)796-9992
4
FRANKLIN T. BIGELOW,JR(SBN 81606)
5 Klika,Parrish & Bigelow
133 No. Altadena Drive, Suite 403
6 Pasadena, CA 91107
Phone: (626)796-9998
7
Attorneys for Petitioner(s)(and all Plaintiff(s) in the Los Angeles Superior Court Case
8 below): ERIK LUDWICK,individually AND as Trustee and Beneficiary of
"THE ANYTHING TRUST" dated October 12, 2007
9
10 JUDICIAL COUNCIL OF CALIFORNIA
11 CHAIR OF THE JUDICIAL COUNCIL
12
13 JUDICIAL COUNCIL
Coordmation Proceeding COORDINATION PROCEEDING
14 Special Title (Rule 3.550) NO.5123
15 Petition Filed On: 07/17/2020
TOYOPA HOME CASES Notice Served On: 07/23/2020
16
Included actions:
17
SUPERIOR COURT OF CALIFORNIA
18 Ludwick V. Partners Trust COUNTY OF LOS ANGELES
Real Estate Brokerage & Acquisitions, et al. NO. 19STCV2533I
19
20
SUPERIOR COURT OF CALIFORNIA
21 Pacific Union International, Inc. v. COUNTY OF PLACER
Ludwick, et al. NO. S-CV-00442080
22
23
24
25
26 NOTICE OF ORDER ASSIGNING COORDINATION MOTION JUDGE
AND SETTING DATE FOR HEARING
27
28
Notice of Order Assigning Coordination Motion Judge and Setting Date for Hearing
1 TO THE CHAIRPERSON OF THE JUDICIAL COUNSEL;AND TO ALL
2 PARTIES AND THEIR ATTORNEYS OF RECORD AS WELL AS THE
3 SUPERIOR COURTS OF PLACER COUNTY AND LOS ANGELES COUNTY:
4
5 NOTICE IS HERE BY GIVEN THAT: THE HONORABLE ASSISTANT
6 SUPERVISING JUDGE of the Complex Litigation Courts ofthe Superior Court of California
7 for the County of Los Angeles was assigned this matter("TOYOPA HOME CASES" JCCP
8 5123)for hearing on the "Petition to Coordinate" pursuant to California Code ofCivil.
9 Procedure § 404 and California Rules ofCourt, Rule 3.524 to determine whether these matters
10 are complex, and if so, whether coordination of the actions is appropriate. Please see the
11 attached Order from the "Chair of the Judicial Council of California" and letter from Bemadine
12 M. Adams, Administrative Coordinator for the Judicial Council of California, attached hereto.
13 The Hearing, unless otherwise ordered by the coordination motion judge is schedule to
14 the heard as follows:
15 Date: Nov. 2,2020
16 Time: 2:00 p.m.
17 Place Dept. 14
18 312 N. Spring St.
19 Los Angles, CA 90012
20
21 Respectfully submitted,
22 MICHAEL A.J. NANGANO,A LAW CORPORATION
23
DATED: October 16,2020 xv I-'
24 '
BY:
25 MICHAEL A.J. NANGANO
Attorney for PETITIONER / Plaintiff(s)
27 [See Attachments For Judicial Council of Califomia Order and letter.]
28
2
Notice of Order Assigning Coordination Motion Judge and Setting Date for Hearing
JUDICIAL COUNCIL OF CALIFORNIA
455 Golden Gate Avenue • San Francisco, California 94102-3688
Telephone 415-^65-4200 ♦ Fax 415-8654205 • TDD 415-8654272
TANI G. CANTIL-SAKAUYE MARTIN HOSHINO
Chte/7t«rice of Cfllt/omia Adminutrorive Direccor
CKalr of the Judicial Council
MILLICENT TIDTELL
Chic/ Depuo Di«c»r
LAURA E. SPEED
Director, Leadership Support Services
September 28,2020
Michael AJ. Nangano
LAW OFFICES OF MICHAEL A.J. NANGANO
133 No. Altadena Drive, Suite 403
Pasadena, California 91107
Franklin T. Bigelow, Jr.
KXIKA,PARRISH & BIGELOW
133 No. Altadena Drive, Suite 403
Pasadena, California 91107
Dear Counsel:
Enclosed is a copy ofthe order assigning a coordination motion judge and setting a hearing date
of November 2,2020 at 2:00 p.m. in a coordination proceeding given the special title of
"TOYOPA HOME CASES" and numbered JCCP 5123.
Petitioner is directed to serve a copy ofthis order on all parties to the included actions and on the
clerk of each court in which an included action is pending for filing in the included action.
assist you in any way, please call me at 415-865-7629.
lemadine M. Adams
Administrative Coordinator
/bma
Enclosure
CHAIR,JUDICIAL COUNCIL OF CALIFORNIA
455 Golden Gate Avenue,San Francisco,CA 94102-3688
Coordination Proceeding
Special Title(Rule 3.550)
TOYOPA HOME CASES JUDICIAL COUNCIL
COORDINATION PROCEEDING
NO. 5123
Included actions:
Ludwick V. Partners Trust Real Estate SUPERIOR COURT OF CALIFORNIA
Brokerage & Acquisitions, et al. COUNTY OF LOS ANGELES
NO. 19STCV25331
Pacific Union International, Inc. v. SUPERIOR COURT OF CALIFORNIA
Ludwick,et al. COUNTY OF PLACER
NO. S-CV-0042080
ORDER ASSIGNING COORDINATION MOTION JUDGE
AND SETTING DATE FOR HEARING
THE ASSISTANT SUPERVISING JUDGE of Complex Litigation Courts of
the Superior Court of California, County ofLos Angeles,is hereby assigned pursuant to Code
of Civil Procedure section 404 and rule 3.524 ofthe California Rules of Court to sit as
coordination motion judge to determine whether the included actions set forth in the caption
are complex(rule 3.502), and if so, whether coordination ofthose actions is appropriate. Ifthe
coordination motion judge grants the petition for coordination, thejudge must(1)recommend
a particular superior court for the site ofthe coordination proceedings, pursuant to rule 3.530,
and(2)select the reviewing court having appellate jurisdiction ifthe actions to be coordinated
are within the jurisdiction of more than one reviewing court, pursuant to rule 3.505(a).
Pursuant to Code of Civil Procedure section 404.5 and rule 3.515, pending
the determination of whether coordination is appropriate, the coordination motion judge
may stay any action being considered for, or affecting an action being considered for,
coordination.
Pursuant to rule 3.524,the clerk ofeach court in which an included action
is pending is directed to file this order in the included action. Also pursuant to rule 3.524,
all documents required to be submitted to the coordination motion Judge must be
transmitted to the court address designated below:
Assistant Supervising Judge of Complex Litigation Courts
Superior Court of California,
County ofLos Angeles
312 North Spring Street, Dept. 14
Los Angeles, CA 90012
Pursuant to rule 3.511, a copy ofevery notice ofopposition, application
for stay order, stay order, notice of hearing on the petition, and order granting or denying
coordination must be transmitted to the Chair ofthe Judicial Council at the following
address:
Chair, Judicial Council of California
Attn: Appellate Court Services
(Civil Case Coordination)
455 Golden Gate Avenue,5th Floor
San Francisco, CA 94102-3688
Unless otherwise ordered by the coordination motion judge, it is ordered
that a hearing on the petition for coordination be set before the coordination motionjudge
at the time and place as follows:
November 2,2020; 2:00 p.m.
312 North Spring Street, Dept. 14
Los Angeles,CA 90012
Petitioner is directed to serve a copy ofthis order on(1)all parties to the
included actions, and(2)the clerk ofeach court for filing in each included action.
23
Dated: September ,2020
ChiefJustice of California and
Chair ofthe Judicial Council
CHAIR, JUDICIAL COUNCIL OF CALIFORNIA
PROOF OF SERVICE BY AAAIL
JUDICIAL COUNCIL COORDINATION NUMBER; CASE NUMBER:
5123
1. I am over the age of 18 and not a party to this legal action.
2. I am employed In the City and County of San Francisco and my business address is
455 Golden Gate Avenue
San Francisco, OA 94102-3888
3. On September 28,2020, 1 served a copy of the following documents:
ORDER ASSIGNING COORDINATION MOTION JUDGE
ORDER ASSIGNING COORDINATION TRIAL JUDGE
ORDER ASSIGNING COORDINATION MOTION JUDGE
AND SETTING DATE FOR HEARING
AMENDED ORDER ASSIGNING COORDINATION MOTION JUDGE
AMENDED ORDER ASSIGNING COORDINATION TRIAL JUDGE
OTHER
on the Interested parties listed on the attached mailing list by placing a true copy enclosed in a
sealed envelope with postage fully prepaid In the outgoing mailbox in my office, in accordance with
ordinary business practices for deposit with the United States Postal Service in San Francisco,
Callfbmia. I am readily familiar with my office's business practice for collection of and processing of
correspondence for mailing, and under that practice the above document is being deposited with
the United States Postal Service this date in San Francisco, California, In the ordinary course of
business.
4. I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct
Date: Monday, September 28,2020
Bemadine M.A
MAILING UST
JUDICIAL COUNCIL COORDINATION PROCEEDING NO. 5123
Michael A.J. Nangano
LAW OFFICES OF MICHAEL A.J. NANGANO
133 North Altadena Drive, Suite 403
Pasadena, CA 91107
Franklin T. Bigelow, Jr.
KLDCA,PARRISH & BIGELOW
133 North Altadena Drive, Suite 403
Pasadena, CA 91107
1 PROOF OF SERVICE
2
I am employed in the County of Los Angeles, State of California. I am over the age of 18
3 and not a party to the within action. My business address is 133 N. Altadena Drive, Suite 403,
Pasadena, CA 91107.
4
On October 19, 2020,1 served the following document(s) described as:
5 â– â–
6
on all interested parties in this action by placing [X] a true copy [ ]the original thereof enclosed
7 in sealed envelopes addressed as follows:
SEE ATTACHED MAILING LIST
9
[] (BYMAIL, 1013a, 2015.5 C.C.P.) I am readily familiar with the firm's practice for
10 collection and processing correspondence for mailing. Under that practice, this document
will be deposited with the U.S. Postal Service on this date with postage thereon fully prepaid
11 at Los Angeles, California in the ordinai-y course of business. I am aware that on motion of
the party served, service is presumed invalid if postal cancellation date or postage meter date
12 is more than one day after date of deposit for mailing in affidavit.
13 [] (BY OVERNIGHT DELIVERY/COURIER)I served the above referenced document(s)
enclosed in a sealed package, for collection and for delivery marked for next day delivery in
14 the ordinary course of business, addressed to the office of the addressee(s) listed above or on
attached sheet.
15
[X] (BY E-MAIL) I transmitted a copy of the foregoing document(s) via e-mail to the
16 addressee(s).
17 [X] (STATE) I declare under penalty of perjury under the laws ofthe State of California that the
above is true and correct.
18 â– â–
Executed on October 19, 2020, at Pasadena, California.
19
20
Patufiia^ Poole
21
22
23
24
25
26
27
28
PROOF OF SERVICE
1 MAILING LIST
Pacific Union International. Inc. v. Ludwick. et al.
2
Case No. SCV0042080
3
^ Ludwick V. Partners Trust, et al.
5 Case No. 19STCV25331
^ Shannon B. Jones, Esq.
Lindsey Morgan, Esq.
7 SHANNON B. JONES LAW GROUP,INC.
208 W.El Pintado Road
8 Danville, CA 94526
8 sbilg@sbi-law.com
lam@sbi-law.com
Lawrence E. Skidmore, Esq.
1 O
Aronowitz Skidmore Lyon
A Professional Law Corporation
200 Auburn Folsom Road, Suite 305
Auburn, CA 95603
lskidmore@.asilaw.org
15 „
Los Angeles Superior Court
111 North Hill Street
Department 54
1^ Los Angeles, CA 90012
16 (Via e-filing)
1^ Placer County Superior Court
10820 Justice Center Drive
20 Roseville, CA 95678
21 (Via e-filing)
22 Judicial Council of California
455 Golden Gate Avenue
23 San Francisco, CA 94102
2^ Adams,Bemadine
25
26
27
28
PROOF OF SERVICE
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1 MICHAEL AJ. NANGANO(SBN 133999) 10/19/2020 Law Offices of Michael A.J. Nangano 2 133 No. Altadena Drive, Suite 403 Pasadena, CA 91107 3 Phone: (626)796-9998 Fax: (626)796-9992 4 FRANKLIN T. BIGELOW,JR(SBN 81606) 5 Klika,Parrish & Bigelow 133 No. Altadena Drive, Suite 403 6 Pasadena, CA 91107 Phone: (626)796-9998 7 Attorneys for Petitioner(s)(and all Plaintiff(s) in the Los Angeles Superior Court Case 8 below): ERIK LUDWICK,individually AND as Trustee and Beneficiary of "THE ANYTHING TRUST" dated October 12, 2007 9 10 JUDICIAL COUNCIL OF CALIFORNIA 11 CHAIR OF THE JUDICIAL COUNCIL 12 13 JUDICIAL COUNCIL Coordmation Proceeding COORDINATION PROCEEDING 14 Special Title (Rule 3.550) NO.5123 15 Petition Filed On: 07/17/2020 TOYOPA HOME CASES Notice Served On: 07/23/2020 16 Included actions: 17 SUPERIOR COURT OF CALIFORNIA 18 Ludwick V. Partners Trust COUNTY OF LOS ANGELES Real Estate Brokerage & Acquisitions, et al. NO. 19STCV2533I 19 20 SUPERIOR COURT OF CALIFORNIA 21 Pacific Union International, Inc. v. COUNTY OF PLACER Ludwick, et al. NO. S-CV-00442080 22 23 24 25 26 NOTICE OF ORDER ASSIGNING COORDINATION MOTION JUDGE AND SETTING DATE FOR HEARING 27 28 Notice of Order Assigning Coordination Motion Judge and Setting Date for Hearing 1 TO THE CHAIRPERSON OF THE JUDICIAL COUNSEL;AND TO ALL 2 PARTIES AND THEIR ATTORNEYS OF RECORD AS WELL AS THE 3 SUPERIOR COURTS OF PLACER COUNTY AND LOS ANGELES COUNTY: 4 5 NOTICE IS HERE BY GIVEN THAT: THE HONORABLE ASSISTANT 6 SUPERVISING JUDGE of the Complex Litigation Courts ofthe Superior Court of California 7 for the County of Los Angeles was assigned this matter("TOYOPA HOME CASES" JCCP 8 5123)for hearing on the "Petition to Coordinate" pursuant to California Code ofCivil. 9 Procedure § 404 and California Rules ofCourt, Rule 3.524 to determine whether these matters 10 are complex, and if so, whether coordination of the actions is appropriate. Please see the 11 attached Order from the "Chair of the Judicial Council of California" and letter from Bemadine 12 M. Adams, Administrative Coordinator for the Judicial Council of California, attached hereto. 13 The Hearing, unless otherwise ordered by the coordination motion judge is schedule to 14 the heard as follows: 15 Date: Nov. 2,2020 16 Time: 2:00 p.m. 17 Place Dept. 14 18 312 N. Spring St. 19 Los Angles, CA 90012 20 21 Respectfully submitted, 22 MICHAEL A.J. NANGANO,A LAW CORPORATION 23 DATED: October 16,2020 xv I-' 24 ' BY: 25 MICHAEL A.J. NANGANO Attorney for PETITIONER / Plaintiff(s) 27 [See Attachments For Judicial Council of Califomia Order and letter.] 28 2 Notice of Order Assigning Coordination Motion Judge and Setting Date for Hearing JUDICIAL COUNCIL OF CALIFORNIA 455 Golden Gate Avenue • San Francisco, California 94102-3688 Telephone 415-^65-4200 ♦ Fax 415-8654205 • TDD 415-8654272 TANI G. CANTIL-SAKAUYE MARTIN HOSHINO Chte/7t«rice of Cfllt/omia Adminutrorive Direccor CKalr of the Judicial Council MILLICENT TIDTELL Chic/ Depuo Di«c»r LAURA E. SPEED Director, Leadership Support Services September 28,2020 Michael AJ. Nangano LAW OFFICES OF MICHAEL A.J. NANGANO 133 No. Altadena Drive, Suite 403 Pasadena, California 91107 Franklin T. Bigelow, Jr. KXIKA,PARRISH & BIGELOW 133 No. Altadena Drive, Suite 403 Pasadena, California 91107 Dear Counsel: Enclosed is a copy ofthe order assigning a coordination motion judge and setting a hearing date of November 2,2020 at 2:00 p.m. in a coordination proceeding given the special title of "TOYOPA HOME CASES" and numbered JCCP 5123. Petitioner is directed to serve a copy ofthis order on all parties to the included actions and on the clerk of each court in which an included action is pending for filing in the included action. assist you in any way, please call me at 415-865-7629. lemadine M. Adams Administrative Coordinator /bma Enclosure CHAIR,JUDICIAL COUNCIL OF CALIFORNIA 455 Golden Gate Avenue,San Francisco,CA 94102-3688 Coordination Proceeding Special Title(Rule 3.550) TOYOPA HOME CASES JUDICIAL COUNCIL COORDINATION PROCEEDING NO. 5123 Included actions: Ludwick V. Partners Trust Real Estate SUPERIOR COURT OF CALIFORNIA Brokerage & Acquisitions, et al. COUNTY OF LOS ANGELES NO. 19STCV25331 Pacific Union International, Inc. v. SUPERIOR COURT OF CALIFORNIA Ludwick,et al. COUNTY OF PLACER NO. S-CV-0042080 ORDER ASSIGNING COORDINATION MOTION JUDGE AND SETTING DATE FOR HEARING THE ASSISTANT SUPERVISING JUDGE of Complex Litigation Courts of the Superior Court of California, County ofLos Angeles,is hereby assigned pursuant to Code of Civil Procedure section 404 and rule 3.524 ofthe California Rules of Court to sit as coordination motion judge to determine whether the included actions set forth in the caption are complex(rule 3.502), and if so, whether coordination ofthose actions is appropriate. Ifthe coordination motion judge grants the petition for coordination, thejudge must(1)recommend a particular superior court for the site ofthe coordination proceedings, pursuant to rule 3.530, and(2)select the reviewing court having appellate jurisdiction ifthe actions to be coordinated are within the jurisdiction of more than one reviewing court, pursuant to rule 3.505(a). Pursuant to Code of Civil Procedure section 404.5 and rule 3.515, pending the determination of whether coordination is appropriate, the coordination motion judge may stay any action being considered for, or affecting an action being considered for, coordination. Pursuant to rule 3.524,the clerk ofeach court in which an included action is pending is directed to file this order in the included action. Also pursuant to rule 3.524, all documents required to be submitted to the coordination motion Judge must be transmitted to the court address designated below: Assistant Supervising Judge of Complex Litigation Courts Superior Court of California, County ofLos Angeles 312 North Spring Street, Dept. 14 Los Angeles, CA 90012 Pursuant to rule 3.511, a copy ofevery notice ofopposition, application for stay order, stay order, notice of hearing on the petition, and order granting or denying coordination must be transmitted to the Chair ofthe Judicial Council at the following address: Chair, Judicial Council of California Attn: Appellate Court Services (Civil Case Coordination) 455 Golden Gate Avenue,5th Floor San Francisco, CA 94102-3688 Unless otherwise ordered by the coordination motion judge, it is ordered that a hearing on the petition for coordination be set before the coordination motionjudge at the time and place as follows: November 2,2020; 2:00 p.m. 312 North Spring Street, Dept. 14 Los Angeles,CA 90012 Petitioner is directed to serve a copy ofthis order on(1)all parties to the included actions, and(2)the clerk ofeach court for filing in each included action. 23 Dated: September ,2020 ChiefJustice of California and Chair ofthe Judicial Council CHAIR, JUDICIAL COUNCIL OF CALIFORNIA PROOF OF SERVICE BY AAAIL JUDICIAL COUNCIL COORDINATION NUMBER; CASE NUMBER: 5123 1. I am over the age of 18 and not a party to this legal action. 2. I am employed In the City and County of San Francisco and my business address is 455 Golden Gate Avenue San Francisco, OA 94102-3888 3. On September 28,2020, 1 served a copy of the following documents: ORDER ASSIGNING COORDINATION MOTION JUDGE ORDER ASSIGNING COORDINATION TRIAL JUDGE ORDER ASSIGNING COORDINATION MOTION JUDGE AND SETTING DATE FOR HEARING AMENDED ORDER ASSIGNING COORDINATION MOTION JUDGE AMENDED ORDER ASSIGNING COORDINATION TRIAL JUDGE OTHER on the Interested parties listed on the attached mailing list by placing a true copy enclosed in a sealed envelope with postage fully prepaid In the outgoing mailbox in my office, in accordance with ordinary business practices for deposit with the United States Postal Service in San Francisco, Callfbmia. I am readily familiar with my office's business practice for collection of and processing of correspondence for mailing, and under that practice the above document is being deposited with the United States Postal Service this date in San Francisco, California, In the ordinary course of business. 4. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct Date: Monday, September 28,2020 Bemadine M.A MAILING UST JUDICIAL COUNCIL COORDINATION PROCEEDING NO. 5123 Michael A.J. Nangano LAW OFFICES OF MICHAEL A.J. NANGANO 133 North Altadena Drive, Suite 403 Pasadena, CA 91107 Franklin T. Bigelow, Jr. KLDCA,PARRISH & BIGELOW 133 North Altadena Drive, Suite 403 Pasadena, CA 91107 1 PROOF OF SERVICE 2 I am employed in the County of Los Angeles, State of California. I am over the age of 18 3 and not a party to the within action. My business address is 133 N. Altadena Drive, Suite 403, Pasadena, CA 91107. 4 On October 19, 2020,1 served the following document(s) described as: 5 ■■6 on all interested parties in this action by placing [X] a true copy [ ]the original thereof enclosed 7 in sealed envelopes addressed as follows: SEE ATTACHED MAILING LIST 9 [] (BYMAIL, 1013a, 2015.5 C.C.P.) I am readily familiar with the firm's practice for 10 collection and processing correspondence for mailing. Under that practice, this document will be deposited with the U.S. Postal Service on this date with postage thereon fully prepaid 11 at Los Angeles, California in the ordinai-y course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date 12 is more than one day after date of deposit for mailing in affidavit. 13 [] (BY OVERNIGHT DELIVERY/COURIER)I served the above referenced document(s) enclosed in a sealed package, for collection and for delivery marked for next day delivery in 14 the ordinary course of business, addressed to the office of the addressee(s) listed above or on attached sheet. 15 [X] (BY E-MAIL) I transmitted a copy of the foregoing document(s) via e-mail to the 16 addressee(s). 17 [X] (STATE) I declare under penalty of perjury under the laws ofthe State of California that the above is true and correct. 18 ■■Executed on October 19, 2020, at Pasadena, California. 19 20 Patufiia^ Poole 21 22 23 24 25 26 27 28 PROOF OF SERVICE 1 MAILING LIST Pacific Union International. Inc. v. Ludwick. et al. 2 Case No. SCV0042080 3 ^ Ludwick V. Partners Trust, et al. 5 Case No. 19STCV25331 ^ Shannon B. Jones, Esq. Lindsey Morgan, Esq. 7 SHANNON B. JONES LAW GROUP,INC. 208 W.El Pintado Road 8 Danville, CA 94526 8 sbilg@sbi-law.com lam@sbi-law.com Lawrence E. Skidmore, Esq. 1 O Aronowitz Skidmore Lyon A Professional Law Corporation 200 Auburn Folsom Road, Suite 305 Auburn, CA 95603 lskidmore@.asilaw.org 15 „ Los Angeles Superior Court 111 North Hill Street Department 54 1^ Los Angeles, CA 90012 16 (Via e-filing) 1^ Placer County Superior Court 10820 Justice Center Drive 20 Roseville, CA 95678 21 (Via e-filing) 22 Judicial Council of California 455 Golden Gate Avenue 23 San Francisco, CA 94102 2^ Adams,Bemadine 25 26 27 28 PROOF OF SERVICE