Preview
12 Stacy Monahan Tucker (SBN 218942)
stucker@kantorlaw.net
3 Jaclyn D. Conover (SBN 266749)
jconover@kantorlaw.net
4 KANTOR & KANTOR LLP
19839 Nordhoff Street
5 Northridge, California 91324
Telephone: (818) 886-2525
6 Facsimile: (818) 350-6272
7 Attorneys for Plaintiff
GARY KOOP
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF SONOMA
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12 GARY KOOP, Case No.: SCV-266944
13 Plaintiff, [Assigned for all purposes to the Honorable
Gary Nadler, Dept. 19]
vs.
Northridge, California 91324
14
KANTOR & KANTOR LLP
19839 Nordhoff Street
(818) 886 2525
15 FIRE INSURANCE EXCHANGE, dba STIPULATION TO CONTINUE
FARMERS INSURANCE GROUP; BRIAN HEARING DATE ON DEFENDANT
16 HUNSAKER, BRIAN HUNSAKER’S MOTION FOR
SUMMARY JUDGMENT OR, IN
17 Defendants. THE ALTERNATIVE, SUMMARY
ADJUDICATION AND [PROPOSED]
18 ORDER
19
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Complaint Filed: August 24, 2020
21 Trial Date: October 21, 2022
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WHEREAS, Defendant BRIAN HUNSAKER (“Hunsaker”) filed a Motion for Summary
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Judgment or, in the alternative, Summary Adjudication on December 21, 2021;
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WHEREAS, Hunsaker’s Motion for Summary Judgment is currently set for hearing on May
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11, 2022;
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WHEREAS, this matter is currently set for trial on October 21, 2022.
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WHEREAS, counsel for Plaintiff and Hunsaker have mutually agreed to a continuance of
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the hearing date on Hunsaker’s Motion for Summary Judgment from May 11, 2022 to August 19,
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STIPULATION TO CONTINUE HEARING DATE ON DEFENDANT BRIAN HUNSAKER’S
MOTON FOR SUMMARY JUDGMENT AND [PROPOSED] ORDER
12 2022 to permit time for settlement discussions and to permit Plaintiff time to receive and review
3 documents subpoenaed from the Custodians of Record of third party Verisk, Inc. which are
4 necessary to comprehensively depose Hunsaker.
5 WHEREAS, the parties agree that in light of the foregoing, good cause exists to extend the
6 date for the hearing on HUNSAKER’s Motion for Summary Judgment and all related briefing dates.
7 IT IS HEREBY STIPULATED by and between Plaintiff and Hunsaker, through their
8 respective attorneys of record, that said parties jointly ask the Court to issue an order continuing the
9 hearing date on Defendant HUNSAKER’s Motion for Summary Judgment from May 11, 2022 to
10 August 19, 2022; that Plaintiff’s Opposition to Hunsaker’s Motion for Summary Judgment is due
11 August 5, 2022 and that Defendant HUNSAKER’s reply to Plaintiff’s opposition is due August 12,
12 2022.
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IT IS SO STIPULATED.
Northridge, California 91324
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KANTOR & KANTOR LLP
19839 Nordhoff Street
DATED: April 20, 2022 KANTOR & KANTOR, LLP
(818) 886 2525
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By: /s/ Stacy M. Tucker__
17 Stacy M. Tucker
Attorneys for Plaintiff
18 GARY KOOP
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DATED: April 20, 2022 ERICKSEN ARBUTHNOT
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By: __________________
22 Albert Finch
Jason Deng
23 Attorneys for Defendant
BRIAN HUNSAKER
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STIPULATION TO CONTINUE HEARING DATE ON DEFENDANT BRIAN HUNSAKER’S
MOTON FOR SUMMARY JUDGMENT AND [PROPOSED] ORDER
12 [PROPOSED] ORDER
3 Based on the stipulation of Plaintiff and Brian Hunsaker, and GOOD CAUSE being shown:
4 The hearing date on Hunsaker’s Motion for Summary Judgment is hereby continued to
5 August 19, 2022; Plaintiff’s Opposition to Hunsaker’s Motion for Summary Judgment is due August
6 5, 2022; Hunsaker’s Reply to Plaintiff’s Opposition is due August 12, 2022.
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IT IS SO ORDERED.
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Dated: ______________ By:_________________________
11 The Honorable Gary Nadler
Judge of the Superior Court
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Northridge, California 91324
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KANTOR & KANTOR LLP
19839 Nordhoff Street
(818) 886 2525
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STIPULATION TO CONTINUE HEARING DATE ON DEFENDANT BRIAN HUNSAKER’S
MOTON FOR SUMMARY JUDGMENT AND [PROPOSED] ORDER
12 PROOF OF SERVICE
3 I, Carolyn Spencer, declare as follows:
4 I am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action; my business address is 19839 Nordhoff Street, Northridge,
5 CA 91324.
6 On April 20, 2022, I served the foregoing document described as STIPULATION OF
COUNSEL TO CONTINUE HEARING DATE ON DEFENDANT BRIAN HUNSAKER’S
7 MOTION FOR SUMMARY JUDGMENT AND [PROPOSED] ORDER in this action by
serving a true copy thereof addressed as follows:
8
9 Peter Schwartz, Esq. pschwartz@grsm.com
Christopher R. Wagner, Esq. cwagner@grsm.com
10 Margaret M. Drugan, Esq. mdrugan@grsm.com
11 GORDON REES SCULLY MANSUKHANI, LLP
633 West Fifth Street, 52nd floor
12 Los Angeles, CA 90071
13 Attorneys for Defendant Fire Insurance
Exchange, dba Farmers Insurance Group
Northridge, California 91324
14
KANTOR & KANTOR LLP
19839 Nordhoff Street
Albert M. T. Finch, III, Esq. afinch@ericksenarbuthnot.com
(818) 886 2525
15
Jason Deng, Esq. jdeng@ericksenarbuthnot.com
16 ERICKSEN ARBUTHNOT kokasaki@ericksenarbuthnot.com
210 North Fourth Street, Suite 350
17 San Jose, CA 95112
T: 415-362-7125 x318
18 F: 415-362-6401
19 Attorneys for Defendant Brian Hunsaker
20 [X] BY E-MAIL SERVICE: I caused a copy of the document(s) to be sent from e-mail address
cspencer@kantorlaw.net to the persons at the e-mail addresses listed above. I did not receive,
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within a reasonable time after the transmission, any electronic message or other indication that the
22 transmission was unsuccessful.
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[x] STATE: I declare under penalty of perjury under the Laws of the State of California that the
24 foregoing is true and correct.
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26 I declare under penalty of perjury under the laws of the State of California that the above is
true and correct. Executed on April 20, 2022, Rohnert Park, California.
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/s/Carolyn Spencer
Carolyn Spencer
4
STIPULATION TO CONTINUE HEARING DATE ON DEFENDANT BRIAN HUNSAKER’S
MOTON FOR SUMMARY JUDGMENT AND [PROPOSED] ORDER
Preview
12 Stacy Monahan Tucker (SBN 218942) stucker@kantorlaw.net 3 Jaclyn D. Conover (SBN 266749) jconover@kantorlaw.net 4 KANTOR & KANTOR LLP 19839 Nordhoff Street 5 Northridge, California 91324 Telephone: (818) 886-2525 6 Facsimile: (818) 350-6272 7 Attorneys for Plaintiff GARY KOOP 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SONOMA 10 11 12 GARY KOOP, Case No.: SCV-266944 13 Plaintiff, [Assigned for all purposes to the Honorable Gary Nadler, Dept. 19] vs. Northridge, California 91324 14 KANTOR & KANTOR LLP 19839 Nordhoff Street (818) 886 2525 15 FIRE INSURANCE EXCHANGE, dba STIPULATION TO CONTINUE FARMERS INSURANCE GROUP; BRIAN HEARING DATE ON DEFENDANT 16 HUNSAKER, BRIAN HUNSAKER’S MOTION FOR SUMMARY JUDGMENT OR, IN 17 Defendants. THE ALTERNATIVE, SUMMARY ADJUDICATION AND [PROPOSED] 18 ORDER 19 20 Complaint Filed: August 24, 2020 21 Trial Date: October 21, 2022 22 WHEREAS, Defendant BRIAN HUNSAKER (“Hunsaker”) filed a Motion for Summary 23 Judgment or, in the alternative, Summary Adjudication on December 21, 2021; 24 WHEREAS, Hunsaker’s Motion for Summary Judgment is currently set for hearing on May 25 11, 2022; 26 WHEREAS, this matter is currently set for trial on October 21, 2022. 27 WHEREAS, counsel for Plaintiff and Hunsaker have mutually agreed to a continuance of 28 the hearing date on Hunsaker’s Motion for Summary Judgment from May 11, 2022 to August 19, 1 STIPULATION TO CONTINUE HEARING DATE ON DEFENDANT BRIAN HUNSAKER’S MOTON FOR SUMMARY JUDGMENT AND [PROPOSED] ORDER 12 2022 to permit time for settlement discussions and to permit Plaintiff time to receive and review 3 documents subpoenaed from the Custodians of Record of third party Verisk, Inc. which are 4 necessary to comprehensively depose Hunsaker. 5 WHEREAS, the parties agree that in light of the foregoing, good cause exists to extend the 6 date for the hearing on HUNSAKER’s Motion for Summary Judgment and all related briefing dates. 7 IT IS HEREBY STIPULATED by and between Plaintiff and Hunsaker, through their 8 respective attorneys of record, that said parties jointly ask the Court to issue an order continuing the 9 hearing date on Defendant HUNSAKER’s Motion for Summary Judgment from May 11, 2022 to 10 August 19, 2022; that Plaintiff’s Opposition to Hunsaker’s Motion for Summary Judgment is due 11 August 5, 2022 and that Defendant HUNSAKER’s reply to Plaintiff’s opposition is due August 12, 12 2022. 13 IT IS SO STIPULATED. Northridge, California 91324 14 KANTOR & KANTOR LLP 19839 Nordhoff Street DATED: April 20, 2022 KANTOR & KANTOR, LLP (818) 886 2525 15 16 By: /s/ Stacy M. Tucker__ 17 Stacy M. Tucker Attorneys for Plaintiff 18 GARY KOOP 19 DATED: April 20, 2022 ERICKSEN ARBUTHNOT 20 21 By: __________________ 22 Albert Finch Jason Deng 23 Attorneys for Defendant BRIAN HUNSAKER 24 25 26 27 28 2 STIPULATION TO CONTINUE HEARING DATE ON DEFENDANT BRIAN HUNSAKER’S MOTON FOR SUMMARY JUDGMENT AND [PROPOSED] ORDER 12 [PROPOSED] ORDER 3 Based on the stipulation of Plaintiff and Brian Hunsaker, and GOOD CAUSE being shown: 4 The hearing date on Hunsaker’s Motion for Summary Judgment is hereby continued to 5 August 19, 2022; Plaintiff’s Opposition to Hunsaker’s Motion for Summary Judgment is due August 6 5, 2022; Hunsaker’s Reply to Plaintiff’s Opposition is due August 12, 2022. 7 IT IS SO ORDERED. 8 9 10 Dated: ______________ By:_________________________ 11 The Honorable Gary Nadler Judge of the Superior Court 12 13 Northridge, California 91324 14 KANTOR & KANTOR LLP 19839 Nordhoff Street (818) 886 2525 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 STIPULATION TO CONTINUE HEARING DATE ON DEFENDANT BRIAN HUNSAKER’S MOTON FOR SUMMARY JUDGMENT AND [PROPOSED] ORDER 12 PROOF OF SERVICE 3 I, Carolyn Spencer, declare as follows: 4 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is 19839 Nordhoff Street, Northridge, 5 CA 91324. 6 On April 20, 2022, I served the foregoing document described as STIPULATION OF COUNSEL TO CONTINUE HEARING DATE ON DEFENDANT BRIAN HUNSAKER’S 7 MOTION FOR SUMMARY JUDGMENT AND [PROPOSED] ORDER in this action by serving a true copy thereof addressed as follows: 8 9 Peter Schwartz, Esq. pschwartz@grsm.com Christopher R. Wagner, Esq. cwagner@grsm.com 10 Margaret M. Drugan, Esq. mdrugan@grsm.com 11 GORDON REES SCULLY MANSUKHANI, LLP 633 West Fifth Street, 52nd floor 12 Los Angeles, CA 90071 13 Attorneys for Defendant Fire Insurance Exchange, dba Farmers Insurance Group Northridge, California 91324 14 KANTOR & KANTOR LLP 19839 Nordhoff Street Albert M. T. Finch, III, Esq. afinch@ericksenarbuthnot.com (818) 886 2525 15 Jason Deng, Esq. jdeng@ericksenarbuthnot.com 16 ERICKSEN ARBUTHNOT kokasaki@ericksenarbuthnot.com 210 North Fourth Street, Suite 350 17 San Jose, CA 95112 T: 415-362-7125 x318 18 F: 415-362-6401 19 Attorneys for Defendant Brian Hunsaker 20 [X] BY E-MAIL SERVICE: I caused a copy of the document(s) to be sent from e-mail address cspencer@kantorlaw.net to the persons at the e-mail addresses listed above. I did not receive, 21 within a reasonable time after the transmission, any electronic message or other indication that the 22 transmission was unsuccessful. 23 [x] STATE: I declare under penalty of perjury under the Laws of the State of California that the 24 foregoing is true and correct. 25 26 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on April 20, 2022, Rohnert Park, California. 27 28 /s/Carolyn Spencer Carolyn Spencer 4 STIPULATION TO CONTINUE HEARING DATE ON DEFENDANT BRIAN HUNSAKER’S MOTON FOR SUMMARY JUDGMENT AND [PROPOSED] ORDER