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1 JOHN D. HOURIHAN, ESQ. – State Bar No. 099799
STRATMAN & WILLIAMS-ABREGO
2 P.O. Box 258829
Oklahoma City, OK 73125-8829
3 Phone: (510) 457-3440
Email: norcal.legal@farmersinsurance.com
4
Attorney for Defendant,
5 QUINN MCLAUGHLIN INDIVIDUALLY AND AS TRUSTEE OF THE QUINN M. MCLAUGHLIN
LIVING TRUST
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF SANTA CRUZ
10
11 DAPHNE BELETSIS, individually, and as Case No.: 19CV03287
Administrator of the Estate of ALEXANDER UNLIMITED JURISDICTION
12 BELETSIS, and YVONNE RAINEY, a surviving
parent of ALEXANDER BELETSIS, deceased, ASSIGNED TO FOR ALL PURPOSES:
13 DEPT: Not Assigned
Plaintiffs,
14 NOTICE OF SETTLEMENT (C.C.P. Section
vs. 877.6(a)(2))
15
THETA CHI FRATERNITY, INC., a New York
16 corporation, individually, as a member of the t/a the
Theta Iota Chapter, University of California, Santa
17 Cruz, as a member of the fraternal order known as
Theta Chi Fraternity, and as an alter-ego and
18 successor entity of the Theta Iota Chapter of the
Theta Chi Fraternity; THETA IOTA CHAPTER OF
19 THETA CHI FRATERNITY, individually, and as
an and agent and alter-ego of the Theta Chi
20 Fraternity, Inc.; CHRISTOPHER GUEVARA,
individually, and as an agent/member of the Theta
21 Chi Fraternity, Inc. and Theta Iota Chapter of the
Theta Chi Fraternity; BRAD VISACKI, individual,
22 and/or as an agent/member of Theta Chi Fraternity,
Inc., and Theta Iota Chapter of Theta Chi
23 Fraternity; QUINN MCLAUGHLIN, individually
and as Trustee of the QUINN M. MCLAUGHLIN
24 LIVING TRUST, 117 Pasture Road., Santa Cruz,
CA, 95060, and JOHN DOES 1 through 25,
25 inclusive, individually, and as agents/members of
Theta Chi Fraternity, Inc. and Theta Iota Chapter of
26 Theta Chi Fraternity,
27 Defendants.
28
Public NOTICE OF SETTLEMENT - 1
1
2 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
3 NOTICE IS HEREBY GIVEN that a settlement has been entered into by and between
4 Plaintiffs, Daphne Beletsis, individually, and as Administrator of the Estate of Alexander Beletsis, and
5 Yvonne Rainey, a surviving parent of Alexander Beletsis, deceased, (“Plaintiffs”) and Defendants,
6 Quinn McLaughlin individually and as Trustee of the Quinn M. McLaughlin Living Trust
7 (“Defendants”). Said settlement is contingent upon a determination of good faith settlement, and
8 Defendants do hereby apply for an Order of this court determining that said settlement meets the
9 standards of good faith within the meaning of California Code of Civil Procedure, § 877.6(a)(2).
10 This Notice, Application and Proposed Order are made pursuant to California Code of Civil
11 Procedure § 877.6(a)(2). Within twenty-five (25) days of the mailing of this Notice, Application and the
12 Proposed Order, a non-settling party may file a Notice of Motion to Contest the Good Faith Settlement.
13 Said Motion by a non-settling party shall be given in a manner provided in subdivision (b) of Section
14 1005 of the California Code of Civil Procedure. If none of the non-settling parties files a Motion within
15 twenty-five (25) days of the mailing of this Notice, Application and Proposed Order, the court may
16 approve the settlement. If the court does approve the settlement and makes a determination that it has
17 been made in good faith, such determination by the court shall bar any other joint tortfeasor or co-
18 obligor from existing or future claims against the settling party for equitable contribution, comparative
19 indemnity, implied indemnity and declaratory relief.
20
This Application is based on this Notice, and the Application and Declaration of John D.
21
Hourihan filed concurrently herewith.
22
23 DATED: April __28___, 2022 STRATMAN & WILLIAMS-ABREGO
24
25 BY:
JOHN D. HOURIHAN, ESQ.
26 Attorney for Defendant,
QUINN MCLAUGHLIN INDIVIDUALLY AND AS
27 TRUSTEE OF THE QUINN M. MCLAUGHLIN
LIVING TRUST
28
Public NOTICE OF SETTLEMENT - 2
1 Re: Beletsis v. Theta Chi Fraternity, et al.
Case Number: 19CV03287
2
3 PROOF OF SERVICE
Code of Civil Procedure §§ 1013a, 2015.5
4
I am a resident of the State of California and over the age of eighteen years, and not a party to the
5 within action. My business address is P.O. Box 258829, Oklahoma City, OK 73125-8829. On May 12,
2022, I served the following document(s):
6
7 NOTICE OF SETTLEMENT (C.C.P. Section 877.6(a)(2))
by placing the document(s) listed above in a sealed envelope, with prepaid postage
8 √ affixed for CERTIFIED MAIL/RETURN RECEIPT REQUESTED, addressed as
9 set forth below, and placing the envelope for collection and mailing in the place
designated for such in our offices, following ordinary business practices.
10
11 I am readily familiar with the firm’s practice of collection and processing correspondence for
mailing with the United States Postal Service. Under that practice, it would be deposited with U.S.
12
Postal Service on that same day with postage thereon fully prepaid (Certified Mail/Return Receipt
13 Requested) in the ordinary 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 is more than one day after date of
14 deposit for mailing in affidavit.
15 I declare under penalty of perjury under the laws of the State of California that the above is true
and correct.
16
17 Executed on May 12, 2022, at San Jose, California.
18
19
20 TIMOTHY C. FEENEY
21
22
23
24
25
26
27
28
Public NOTICE OF SETTLEMENT - 3
1 Re: Beletsis v. Theta Chi Fraternity, et al.
Case Number: 19CV03287
2
SERVICE LIST
3
Douglas E. Fierberg, Esq.
4
Fierberg National Law Group
161 East Front Street, Ste. 200
5
Traverse City, MI 49684
Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey
6
Phone: (202) 351-0510
Fax: (231) 252-8100
7
dfierberg@tfnlgroup.com
8
Ivo Labar, Esq.
Sawyer & Labar LLP
9
1700 Montgomery Street, Suite 108
San Francisco, CA 941111
10
Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey
Phone: (415) 262-3820
11
labar@sawyerlabar.com
12
Michael C. Osborne, Esq.
Cokinos/Young
13
900 S. Capitol of Texas Highway
Las Cimas IV, Ste. 425
14
Austin, TX 78746
Attorney for Defendant, Theta Chi Fraternity, Inc.
15
Phone: (512) 476-1080
16
Mary Childs, Esq.
Yoka & Smith, LLP
17
445 South Figueroa Street, 38th Floor
Los Angeles, CA 90071
18
Attorney for Defendants, Emmanuel Thomas; Bobby Karki; John Dylan Lietch
Phone: (213) 427-2300
19
Fax: (213) 427-2330
mchilds@yokasmith.com
20
Derek H. Lim, Esq.
21
Demler, Armstrong & Rowland LLP
1350 Treat Boulevard, Suite 400
22
Walnut Creek, CA 94597
Attorney for Defendants, Chris Guevara; Bradley Visacki
23
Phone: (415) 949-1900
lim@darlaw.com
24
Chris A. Tarkington, Esq.
25
Tarkington, O'Neill, Barrack & Chong - SF
201 Mission Street, Suite 710
26
San Francisco, CA 94105
Attorney for Defendant, Najpreet Kahlon
27
Phone: (415) 777-5501
Fax: (415) 546-4962
28
Public NOTICE OF SETTLEMENT - 4
1 ctark@to2law.com
2 Robert Mackey, Esq.
Veatch Carlson, LLP
3 1055 Wilshire Blvd., 11th Floor
Los Angeles, CA 90017
4 Attorney for Defendant, Stefan Leon
Phone: (213) 381-2861
5 Fax: (213) 383-6370
rmackey@veatchfirm.com
6
Matthew C. Jaime, Esq.
7 Metheny Sears Linkert & Jaime LLP
3638 American River Drive
8 Sacramento, CA 95864
Attorney for Defendant, Chris Guevara
9 Phone: (916) 978-3434
Fax: (916) 978-3430
10 mjaime@mathenysears.com
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Public NOTICE OF SETTLEMENT - 5
1 JOHN D. HOURIHAN, ESQ. – State Bar No. 099799
STRATMAN & WILLIAMS-ABREGO
2 P.O. Box 258829
Oklahoma City, OK 73125-8829
3 Phone: (510) 457-3440
Email: norcal.legal@farmersinsurance.com
4
Attorney for Defendant,
5 QUINN MCLAUGHLIN INDIVIDUALLY AND AS TRUSTEE OF THE QUINN M. MCLAUGHLIN
LIVING TRUST
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF SANTA CRUZ
10
11 DAPHNE BELETSIS, individually, and as Case No.: 19CV03287
Administrator of the Estate of ALEXANDER UNLIMITED JURISDICTION
12 BELETSIS, and YVONNE RAINEY, a surviving
parent of ALEXANDER BELETSIS, deceased, ASSIGNED TO FOR ALL PURPOSES:
13 DEPT: Not Assigned
Plaintiffs,
14 NOTICE OF SETTLEMENT (C.C.P. Section
vs. 877.6(a)(2))
15
THETA CHI FRATERNITY, INC., a New York
16 corporation, individually, as a member of the t/a the
Theta Iota Chapter, University of California, Santa
17 Cruz, as a member of the fraternal order known as
Theta Chi Fraternity, and as an alter-ego and
18 successor entity of the Theta Iota Chapter of the
Theta Chi Fraternity; THETA IOTA CHAPTER OF
19 THETA CHI FRATERNITY, individually, and as
an and agent and alter-ego of the Theta Chi
20 Fraternity, Inc.; CHRISTOPHER GUEVARA,
individually, and as an agent/member of the Theta
21 Chi Fraternity, Inc. and Theta Iota Chapter of the
Theta Chi Fraternity; BRAD VISACKI, individual,
22 and/or as an agent/member of Theta Chi Fraternity,
Inc., and Theta Iota Chapter of Theta Chi
23 Fraternity; QUINN MCLAUGHLIN, individually
and as Trustee of the QUINN M. MCLAUGHLIN
24 LIVING TRUST, 117 Pasture Road., Santa Cruz,
CA, 95060, and JOHN DOES 1 through 25,
25 inclusive, individually, and as agents/members of
Theta Chi Fraternity, Inc. and Theta Iota Chapter of
26 Theta Chi Fraternity,
27 Defendants.
28
Public NOTICE OF SETTLEMENT - 1
1
2 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
3 NOTICE IS HEREBY GIVEN that a settlement has been entered into by and between
4 Plaintiffs, Daphne Beletsis, individually, and as Administrator of the Estate of Alexander Beletsis, and
5 Yvonne Rainey, a surviving parent of Alexander Beletsis, deceased, (“Plaintiffs”) and Defendants,
6 Quinn McLaughlin individually and as Trustee of the Quinn M. McLaughlin Living Trust
7 (“Defendants”). Said settlement is contingent upon a determination of good faith settlement, and
8 Defendants do hereby apply for an Order of this court determining that said settlement meets the
9 standards of good faith within the meaning of California Code of Civil Procedure, § 877.6(a)(2).
10 This Notice, Application and Proposed Order are made pursuant to California Code of Civil
11 Procedure § 877.6(a)(2). Within twenty-five (25) days of the mailing of this Notice, Application and the
12 Proposed Order, a non-settling party may file a Notice of Motion to Contest the Good Faith Settlement.
13 Said Motion by a non-settling party shall be given in a manner provided in subdivision (b) of Section
14 1005 of the California Code of Civil Procedure. If none of the non-settling parties files a Motion within
15 twenty-five (25) days of the mailing of this Notice, Application and Proposed Order, the court may
16 approve the settlement. If the court does approve the settlement and makes a determination that it has
17 been made in good faith, such determination by the court shall bar any other joint tortfeasor or co-
18 obligor from existing or future claims against the settling party for equitable contribution, comparative
19 indemnity, implied indemnity and declaratory relief.
20
This Application is based on this Notice, and the Application and Declaration of John D.
21
Hourihan filed concurrently herewith.
22
23 DATED: April __28___, 2022 STRATMAN & WILLIAMS-ABREGO
24
25 BY:
JOHN D. HOURIHAN, ESQ.
26 Attorney for Defendant,
QUINN MCLAUGHLIN INDIVIDUALLY AND AS
27 TRUSTEE OF THE QUINN M. MCLAUGHLIN
LIVING TRUST
28
Public NOTICE OF SETTLEMENT - 2
1 Re: Beletsis v. Theta Chi Fraternity, et al.
Case Number: 19CV03287
2
3 PROOF OF SERVICE
Code of Civil Procedure §§ 1013a, 2015.5
4
I am a resident of the State of California and over the age of eighteen years, and not a party to the
5 within action. My business address is P.O. Box 258829, Oklahoma City, OK 73125-8829. On May 12,
2022, I served the following document(s):
6
7 NOTICE OF SETTLEMENT (C.C.P. Section 877.6(a)(2))
by placing the document(s) listed above in a sealed envelope, with prepaid postage
8 √ affixed for CERTIFIED MAIL/RETURN RECEIPT REQUESTED, addressed as
9 set forth below, and placing the envelope for collection and mailing in the place
designated for such in our offices, following ordinary business practices.
10
11 I am readily familiar with the firm’s practice of collection and processing correspondence for
mailing with the United States Postal Service. Under that practice, it would be deposited with U.S.
12
Postal Service on that same day with postage thereon fully prepaid (Certified Mail/Return Receipt
13 Requested) in the ordinary 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 is more than one day after date of
14 deposit for mailing in affidavit.
15 I declare under penalty of perjury under the laws of the State of California that the above is true
and correct.
16
17 Executed on May 12, 2022, at San Jose, California.
18
19
20 TIMOTHY C. FEENEY
21
22
23
24
25
26
27
28
Public NOTICE OF SETTLEMENT - 3
1 Re: Beletsis v. Theta Chi Fraternity, et al.
Case Number: 19CV03287
2
SERVICE LIST
3
Douglas E. Fierberg, Esq.
4
Fierberg National Law Group
161 East Front Street, Ste. 200
5
Traverse City, MI 49684
Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey
6
Phone: (202) 351-0510
Fax: (231) 252-8100
7
dfierberg@tfnlgroup.com
8
Ivo Labar, Esq.
Sawyer & Labar LLP
9
1700 Montgomery Street, Suite 108
San Francisco, CA 941111
10
Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey
Phone: (415) 262-3820
11
labar@sawyerlabar.com
12
Michael C. Osborne, Esq.
Cokinos/Young
13
900 S. Capitol of Texas Highway
Las Cimas IV, Ste. 425
14
Austin, TX 78746
Attorney for Defendant, Theta Chi Fraternity, Inc.
15
Phone: (512) 476-1080
16
Mary Childs, Esq.
Yoka & Smith, LLP
17
445 South Figueroa Street, 38th Floor
Los Angeles, CA 90071
18
Attorney for Defendants, Emmanuel Thomas; Bobby Karki; John Dylan Lietch
Phone: (213) 427-2300
19
Fax: (213) 427-2330
mchilds@yokasmith.com
20
Derek H. Lim, Esq.
21
Demler, Armstrong & Rowland LLP
1350 Treat Boulevard, Suite 400
22
Walnut Creek, CA 94597
Attorney for Defendants, Chris Guevara; Bradley Visacki
23
Phone: (415) 949-1900
lim@darlaw.com
24
Chris A. Tarkington, Esq.
25
Tarkington, O'Neill, Barrack & Chong - SF
201 Mission Street, Suite 710
26
San Francisco, CA 94105
Attorney for Defendant, Najpreet Kahlon
27
Phone: (415) 777-5501
Fax: (415) 546-4962
28
Public NOTICE OF SETTLEMENT - 4
1 ctark@to2law.com
2 Robert Mackey, Esq.
Veatch Carlson, LLP
3 1055 Wilshire Blvd., 11th Floor
Los Angeles, CA 90017
4 Attorney for Defendant, Stefan Leon
Phone: (213) 381-2861
5 Fax: (213) 383-6370
rmackey@veatchfirm.com
6
Matthew C. Jaime, Esq.
7 Metheny Sears Linkert & Jaime LLP
3638 American River Drive
8 Sacramento, CA 95864
Attorney for Defendant, Chris Guevara
9 Phone: (916) 978-3434
Fax: (916) 978-3430
10 mjaime@mathenysears.com
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Public NOTICE OF SETTLEMENT - 5
1 JOHN D. HOURIHAN, ESQ. – State Bar No. 099799
STRATMAN & WILLIAMS-ABREGO
2 P.O. Box 258829
Oklahoma City, OK 73125-8829
3 Phone: (510) 457-3440
Email: norcal.legal@farmersinsurance.com
4
Attorney for Defendant,
5 QUINN MCLAUGHLIN INDIVIDUALLY AND AS TRUSTEE OF THE QUINN M. MCLAUGHLIN
LIVING TRUST
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF SANTA CRUZ
10
11 DAPHNE BELETSIS, individually, and as Case No.: 19CV03287
Administrator of the Estate of ALEXANDER UNLIMITED JURISDICTION
12 BELETSIS, and YVONNE RAINEY, a surviving
parent of ALEXANDER BELETSIS, deceased, ASSIGNED TO FOR ALL PURPOSES:
13 DEPT: Not Assigned
Plaintiffs,
14 NOTICE OF SETTLEMENT (C.C.P. Section
vs. 877.6(a)(2))
15
THETA CHI FRATERNITY, INC., a New York
16 corporation, individually, as a member of the t/a the
Theta Iota Chapter, University of California, Santa
17 Cruz, as a member of the fraternal order known as
Theta Chi Fraternity, and as an alter-ego and
18 successor entity of the Theta Iota Chapter of the
Theta Chi Fraternity; THETA IOTA CHAPTER OF
19 THETA CHI FRATERNITY, individually, and as
an and agent and alter-ego of the Theta Chi
20 Fraternity, Inc.; CHRISTOPHER GUEVARA,
individually, and as an agent/member of the Theta
21 Chi Fraternity, Inc. and Theta Iota Chapter of the
Theta Chi Fraternity; BRAD VISACKI, individual,
22 and/or as an agent/member of Theta Chi Fraternity,
Inc., and Theta Iota Chapter of Theta Chi
23 Fraternity; QUINN MCLAUGHLIN, individually
and as Trustee of the QUINN M. MCLAUGHLIN
24 LIVING TRUST, 117 Pasture Road., Santa Cruz,
CA, 95060, and JOHN DOES 1 through 25,
25 inclusive, individually, and as agents/members of
Theta Chi Fraternity, Inc. and Theta Iota Chapter of
26 Theta Chi Fraternity,
27 Defendants.
28
Public NOTICE OF SETTLEMENT - 1
1
2 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
3 NOTICE IS HEREBY GIVEN that a settlement has been entered into by and between
4 Plaintiffs, Daphne Beletsis, individually, and as Administrator of the Estate of Alexander Beletsis, and
5 Yvonne Rainey, a surviving parent of Alexander Beletsis, deceased, (“Plaintiffs”) and Defendants,
6 Quinn McLaughlin individually and as Trustee of the Quinn M. McLaughlin Living Trust
7 (“Defendants”). Said settlement is contingent upon a determination of good faith settlement, and
8 Defendants do hereby apply for an Order of this court determining that said settlement meets the
9 standards of good faith within the meaning of California Code of Civil Procedure, § 877.6(a)(2).
10 This Notice, Application and Proposed Order are made pursuant to California Code of Civil
11 Procedure § 877.6(a)(2). Within twenty-five (25) days of the mailing of this Notice, Application and the
12 Proposed Order, a non-settling party may file a Notice of Motion to Contest the Good Faith Settlement.
13 Said Motion by a non-settling party shall be given in a manner provided in subdivision (b) of Section
14 1005 of the California Code of Civil Procedure. If none of the non-settling parties files a Motion within
15 twenty-five (25) days of the mailing of this Notice, Application and Proposed Order, the court may
16 approve the settlement. If the court does approve the settlement and makes a determination that it has
17 been made in good faith, such determination by the court shall bar any other joint tortfeasor or co-
18 obligor from existing or future claims against the settling party for equitable contribution, comparative
19 indemnity, implied indemnity and declaratory relief.
20
This Application is based on this Notice, and the Application and Declaration of John D.
21
Hourihan filed concurrently herewith.
22
23 DATED: April __28___, 2022 STRATMAN & WILLIAMS-ABREGO
24
25 BY:
JOHN D. HOURIHAN, ESQ.
26 Attorney for Defendant,
QUINN MCLAUGHLIN INDIVIDUALLY AND AS
27 TRUSTEE OF THE QUINN M. MCLAUGHLIN
LIVING TRUST
28
Public NOTICE OF SETTLEMENT - 2
1 Re: Beletsis v. Theta Chi Fraternity, et al.
Case Number: 19CV03287
2
3 PROOF OF SERVICE
Code of Civil Procedure §§ 1013a, 2015.5
4
I am a resident of the State of California and over the age of eighteen years, and not a party to the
5 within action. My business address is P.O. Box 258829, Oklahoma City, OK 73125-8829. On May 12,
2022, I served the following document(s):
6
7 NOTICE OF SETTLEMENT (C.C.P. Section 877.6(a)(2))
by placing the document(s) listed above in a sealed envelope, with prepaid postage
8 √ affixed for CERTIFIED MAIL/RETURN RECEIPT REQUESTED, addressed as
9 set forth below, and placing the envelope for collection and mailing in the place
designated for such in our offices, following ordinary business practices.
10
11 I am readily familiar with the firm’s practice of collection and processing correspondence for
mailing with the United States Postal Service. Under that practice, it would be deposited with U.S.
12
Postal Service on that same day with postage thereon fully prepaid (Certified Mail/Return Receipt
13 Requested) in the ordinary 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 is more than one day after date of
14 deposit for mailing in affidavit.
15 I declare under penalty of perjury under the laws of the State of California that the above is true
and correct.
16
17 Executed on May 12, 2022, at San Jose, California.
18
19
20 TIMOTHY C. FEENEY
21
22
23
24
25
26
27
28
Public NOTICE OF SETTLEMENT - 3
1 Re: Beletsis v. Theta Chi Fraternity, et al.
Case Number: 19CV03287
2
SERVICE LIST
3
Douglas E. Fierberg, Esq.
4
Fierberg National Law Group
161 East Front Street, Ste. 200
5
Traverse City, MI 49684
Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey
6
Phone: (202) 351-0510
Fax: (231) 252-8100
7
dfierberg@tfnlgroup.com
8
Ivo Labar, Esq.
Sawyer & Labar LLP
9
1700 Montgomery Street, Suite 108
San Francisco, CA 941111
10
Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey
Phone: (415) 262-3820
11
labar@sawyerlabar.com
12
Michael C. Osborne, Esq.
Cokinos/Young
13
900 S. Capitol of Texas Highway
Las Cimas IV, Ste. 425
14
Austin, TX 78746
Attorney for Defendant, Theta Chi Fraternity, Inc.
15
Phone: (512) 476-1080
16
Mary Childs, Esq.
Yoka & Smith, LLP
17
445 South Figueroa Street, 38th Floor
Los Angeles, CA 90071
18
Attorney for Defendants, Emmanuel Thomas; Bobby Karki; John Dylan Lietch
Phone: (213) 427-2300
19
Fax: (213) 427-2330
mchilds@yokasmith.com
20
Derek H. Lim, Esq.
21
Demler, Armstrong & Rowland LLP
1350 Treat Boulevard, Suite 400
22
Walnut Creek, CA 94597
Attorney for Defendants, Chris Guevara; Bradley Visacki
23
Phone: (415) 949-1900
lim@darlaw.com
24
Chris A. Tarkington, Esq.
25
Tarkington, O'Neill, Barrack & Chong - SF
201 Mission Street, Suite 710
26
San Francisco, CA 94105
Attorney for Defendant, Najpreet Kahlon
27
Phone: (415) 777-5501
Fax: (415) 546-4962
28
Public NOTICE OF SETTLEMENT - 4
1 ctark@to2law.com
2 Robert Mackey, Esq.
Veatch Carlson, LLP
3 1055 Wilshire Blvd., 11th Floor
Los Angeles, CA 90017
4 Attorney for Defendant, Stefan Leon
Phone: (213) 381-2861
5 Fax: (213) 383-6370
rmackey@veatchfirm.com
6
Matthew C. Jaime, Esq.
7 Metheny Sears Linkert & Jaime LLP
3638 American River Drive
8 Sacramento, CA 95864
Attorney for Defendant, Chris Guevara
9 Phone: (916) 978-3434
Fax: (916) 978-3430
10 mjaime@mathenysears.com
11
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Public NOTICE OF SETTLEMENT - 5
1 JOHN D. HOURIHAN, ESQ. – State Bar No. 099799
STRATMAN & WILLIAMS-ABREGO
2 P.O. Box 258829
Oklahoma City, OK 73125-8829
3 Phone: (510) 457-3440
Email: norcal.legal@farmersinsurance.com
4
Attorney for Defendant,
5 QUINN MCLAUGHLIN INDIVIDUALLY AND AS TRUSTEE OF THE QUINN M. MCLAUGHLIN
LIVING TRUST
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF SANTA CRUZ
10
11 DAPHNE BELETSIS, individually, and as Case No.: 19CV03287
Administrator of the Estate of ALEXANDER UNLIMITED JURISDICTION
12 BELETSIS, and YVONNE RAINEY, a surviving
parent of ALEXANDER BELETSIS, deceased, ASSIGNED TO FOR ALL PURPOSES:
13 DEPT: Not Assigned
Plaintiffs,
14 NOTICE OF SETTLEMENT (C.C.P. Section
vs. 877.6(a)(2))
15
THETA CHI FRATERNITY, INC., a New York
16 corporation, individually, as a member of the t/a the
Theta Iota Chapter, University of California, Santa
17 Cruz, as a member of the fraternal order known as
Theta Chi Fraternity, and as an alter-ego and
18 successor entity of the Theta Iota Chapter of the
Theta Chi Fraternity; THETA IOTA CHAPTER OF
19 THETA CHI FRATERNITY, individually, and as
an and agent and alter-ego of the Theta Chi
20 Fraternity, Inc.; CHRISTOPHER GUEVARA,
individually, and as an agent/member of the Theta
21 Chi Fraternity, Inc. and Theta Iota Chapter of the
Theta Chi Fraternity; BRAD VISACKI, individual,
22 and/or as an agent/member of Theta Chi Fraternity,
Inc., and Theta Iota Chapter of Theta Chi
23 Fraternity; QUINN MCLAUGHLIN, individually
and as Trustee of the QUINN M. MCLAUGHLIN
24 LIVING TRUST, 117 Pasture Road., Santa Cruz,
CA, 95060, and JOHN DOES 1 through 25,
25 inclusive, individually, and as agents/members of
Theta Chi Fraternity, Inc. and Theta Iota Chapter of
26 Theta Chi Fraternity,
27 Defendants.
28
Public NOTICE OF SETTLEMENT - 1
1
2 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
3 NOTICE IS HEREBY GIVEN that a settlement has been entered into by and between
4 Plaintiffs, Daphne Beletsis, individually, and as Administrator of the Estate of Alexander Beletsis, and
5 Yvonne Rainey, a surviving parent of Alexander Beletsis, deceased, (“Plaintiffs”) and Defendants,
6 Quinn McLaughlin individually and as Trustee of the Quinn M. McLaughlin Living Trust
7 (“Defendants”). Said settlement is contingent upon a determination of good faith settlement, and
8 Defendants do hereby apply for an Order of this court determining that said settlement meets the
9 standards of good faith within the meaning of California Code of Civil Procedure, § 877.6(a)(2).
10 This Notice, Application and Proposed Order are made pursuant to California Code of Civil
11 Procedure § 877.6(a)(2). Within twenty-five (25) days of the mailing of this Notice, Application and the
12 Proposed Order, a non-settling party may file a Notice of Motion to Contest the Good Faith Settlement.
13 Said Motion by a non-settling party shall be given in a manner provided in subdivision (b) of Section
14 1005 of the California Code of Civil Procedure. If none of the non-settling parties files a Motion within
15 twenty-five (25) days of the mailing of this Notice, Application and Proposed Order, the court may
16 approve the settlement. If the court does approve the settlement and makes a determination that it has
17 been made in good faith, such determination by the court shall bar any other joint tortfeasor or co-
18 obligor from existing or future claims against the settling party for equitable contribution, comparative
19 indemnity, implied indemnity and declaratory relief.
20
This Application is based on this Notice, and the Application and Declaration of John D.
21
Hourihan filed concurrently herewith.
22
23 DATED: April __28___, 2022 STRATMAN & WILLIAMS-ABREGO
24
25 BY:
JOHN D. HOURIHAN, ESQ.
26 Attorney for Defendant,
QUINN MCLAUGHLIN INDIVIDUALLY AND AS
27 TRUSTEE OF THE QUINN M. MCLAUGHLIN
LIVING TRUST
28
Public NOTICE OF SETTLEMENT - 2
1 Re: Beletsis v. Theta Chi Fraternity, et al.
Case Number: 19CV03287
2
3 PROOF OF SERVICE
Code of Civil Procedure §§ 1013a, 2015.5
4
I am a resident of the State of California and over the age of eighteen years, and not a party to the
5 within action. My business address is P.O. Box 258829, Oklahoma City, OK 73125-8829. On May 12,
2022, I served the following document(s):
6
7 NOTICE OF SETTLEMENT (C.C.P. Section 877.6(a)(2))
by placing the document(s) listed above in a sealed envelope, with prepaid postage
8 √ affixed for CERTIFIED MAIL/RETURN RECEIPT REQUESTED, addressed as
9 set forth below, and placing the envelope for collection and mailing in the place
designated for such in our offices, following ordinary business practices.
10
11 I am readily familiar with the firm’s practice of collection and processing correspondence for
mailing with the United States Postal Service. Under that practice, it would be deposited with U.S.
12
Postal Service on that same day with postage thereon fully prepaid (Certified Mail/Return Receipt
13 Requested) in the ordinary 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 is more than one day after date of
14 deposit for mailing in affidavit.
15 I declare under penalty of perjury under the laws of the State of California that the above is true
and correct.
16
17 Executed on May 12, 2022, at San Jose, California.
18
19
20 TIMOTHY C. FEENEY
21
22
23
24
25
26
27
28
Public NOTICE OF SETTLEMENT - 3
1 Re: Beletsis v. Theta Chi Fraternity, et al.
Case Number: 19CV03287
2
SERVICE LIST
3
Douglas E. Fierberg, Esq.
4
Fierberg National Law Group
161 East Front Street, Ste. 200
5
Traverse City, MI 49684
Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey
6
Phone: (202) 351-0510
Fax: (231) 252-8100
7
dfierberg@tfnlgroup.com
8
Ivo Labar, Esq.
Sawyer & Labar LLP
9
1700 Montgomery Street, Suite 108
San Francisco, CA 941111
10
Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey
Phone: (415) 262-3820
11
labar@sawyerlabar.com
12
Michael C. Osborne, Esq.
Cokinos/Young
13
900 S. Capitol of Texas Highway
Las Cimas IV, Ste. 425
14
Austin, TX 78746
Attorney for Defendant, Theta Chi Fraternity, Inc.
15
Phone: (512) 476-1080
16
Mary Childs, Esq.
Yoka & Smith, LLP
17
445 South Figueroa Street, 38th Floor
Los Angeles, CA 90071
18
Attorney for Defendants, Emmanuel Thomas; Bobby Karki; John Dylan Lietch
Phone: (213) 427-2300
19
Fax: (213) 427-2330
mchilds@yokasmith.com
20
Derek H. Lim, Esq.
21
Demler, Armstrong & Rowland LLP
1350 Treat Boulevard, Suite 400
22
Walnut Creek, CA 94597
Attorney for Defendants, Chris Guevara; Bradley Visacki
23
Phone: (415) 949-1900
lim@darlaw.com
24
Chris A. Tarkington, Esq.
25
Tarkington, O'Neill, Barrack & Chong - SF
201 Mission Street, Suite 710
26
San Francisco, CA 94105
Attorney for Defendant, Najpreet Kahlon
27
Phone: (415) 777-5501
Fax: (415) 546-4962
28
Public NOTICE OF SETTLEMENT - 4
1 ctark@to2law.com
2 Robert Mackey, Esq.
Veatch Carlson, LLP
3 1055 Wilshire Blvd., 11th Floor
Los Angeles, CA 90017
4 Attorney for Defendant, Stefan Leon
Phone: (213) 381-2861
5 Fax: (213) 383-6370
rmackey@veatchfirm.com
6
Matthew C. Jaime, Esq.
7 Metheny Sears Linkert & Jaime LLP
3638 American River Drive
8 Sacramento, CA 95864
Attorney for Defendant, Chris Guevara
9 Phone: (916) 978-3434
Fax: (916) 978-3430
10 mjaime@mathenysears.com
11
12
13
14
15
16
17
18
19
20
21
22
Preview
1 JOHN D. HOURIHAN, ESQ. – State Bar No. 099799 STRATMAN & WILLIAMS-ABREGO 2 P.O. Box 258829 Oklahoma City, OK 73125-8829 3 Phone: (510) 457-3440 Email: norcal.legal@farmersinsurance.com 4 Attorney for Defendant, 5 QUINN MCLAUGHLIN INDIVIDUALLY AND AS TRUSTEE OF THE QUINN M. MCLAUGHLIN LIVING TRUST 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SANTA CRUZ 10 11 DAPHNE BELETSIS, individually, and as Case No.: 19CV03287 Administrator of the Estate of ALEXANDER UNLIMITED JURISDICTION 12 BELETSIS, and YVONNE RAINEY, a surviving parent of ALEXANDER BELETSIS, deceased, ASSIGNED TO FOR ALL PURPOSES: 13 DEPT: Not Assigned Plaintiffs, 14 NOTICE OF SETTLEMENT (C.C.P. Section vs. 877.6(a)(2)) 15 THETA CHI FRATERNITY, INC., a New York 16 corporation, individually, as a member of the t/a the Theta Iota Chapter, University of California, Santa 17 Cruz, as a member of the fraternal order known as Theta Chi Fraternity, and as an alter-ego and 18 successor entity of the Theta Iota Chapter of the Theta Chi Fraternity; THETA IOTA CHAPTER OF 19 THETA CHI FRATERNITY, individually, and as an and agent and alter-ego of the Theta Chi 20 Fraternity, Inc.; CHRISTOPHER GUEVARA, individually, and as an agent/member of the Theta 21 Chi Fraternity, Inc. and Theta Iota Chapter of the Theta Chi Fraternity; BRAD VISACKI, individual, 22 and/or as an agent/member of Theta Chi Fraternity, Inc., and Theta Iota Chapter of Theta Chi 23 Fraternity; QUINN MCLAUGHLIN, individually and as Trustee of the QUINN M. MCLAUGHLIN 24 LIVING TRUST, 117 Pasture Road., Santa Cruz, CA, 95060, and JOHN DOES 1 through 25, 25 inclusive, individually, and as agents/members of Theta Chi Fraternity, Inc. and Theta Iota Chapter of 26 Theta Chi Fraternity, 27 Defendants. 28 Public NOTICE OF SETTLEMENT - 1 1 2 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: 3 NOTICE IS HEREBY GIVEN that a settlement has been entered into by and between 4 Plaintiffs, Daphne Beletsis, individually, and as Administrator of the Estate of Alexander Beletsis, and 5 Yvonne Rainey, a surviving parent of Alexander Beletsis, deceased, (“Plaintiffs”) and Defendants, 6 Quinn McLaughlin individually and as Trustee of the Quinn M. McLaughlin Living Trust 7 (“Defendants”). Said settlement is contingent upon a determination of good faith settlement, and 8 Defendants do hereby apply for an Order of this court determining that said settlement meets the 9 standards of good faith within the meaning of California Code of Civil Procedure, § 877.6(a)(2). 10 This Notice, Application and Proposed Order are made pursuant to California Code of Civil 11 Procedure § 877.6(a)(2). Within twenty-five (25) days of the mailing of this Notice, Application and the 12 Proposed Order, a non-settling party may file a Notice of Motion to Contest the Good Faith Settlement. 13 Said Motion by a non-settling party shall be given in a manner provided in subdivision (b) of Section 14 1005 of the California Code of Civil Procedure. If none of the non-settling parties files a Motion within 15 twenty-five (25) days of the mailing of this Notice, Application and Proposed Order, the court may 16 approve the settlement. If the court does approve the settlement and makes a determination that it has 17 been made in good faith, such determination by the court shall bar any other joint tortfeasor or co- 18 obligor from existing or future claims against the settling party for equitable contribution, comparative 19 indemnity, implied indemnity and declaratory relief. 20 This Application is based on this Notice, and the Application and Declaration of John D. 21 Hourihan filed concurrently herewith. 22 23 DATED: April __28___, 2022 STRATMAN & WILLIAMS-ABREGO 24 25 BY: JOHN D. HOURIHAN, ESQ. 26 Attorney for Defendant, QUINN MCLAUGHLIN INDIVIDUALLY AND AS 27 TRUSTEE OF THE QUINN M. MCLAUGHLIN LIVING TRUST 28 Public NOTICE OF SETTLEMENT - 2 1 Re: Beletsis v. Theta Chi Fraternity, et al. Case Number: 19CV03287 2 3 PROOF OF SERVICE Code of Civil Procedure §§ 1013a, 2015.5 4 I am a resident of the State of California and over the age of eighteen years, and not a party to the 5 within action. My business address is P.O. Box 258829, Oklahoma City, OK 73125-8829. On May 12, 2022, I served the following document(s): 6 7 NOTICE OF SETTLEMENT (C.C.P. Section 877.6(a)(2)) by placing the document(s) listed above in a sealed envelope, with prepaid postage 8 √ affixed for CERTIFIED MAIL/RETURN RECEIPT REQUESTED, addressed as 9 set forth below, and placing the envelope for collection and mailing in the place designated for such in our offices, following ordinary business practices. 10 11 I am readily familiar with the firm’s practice of collection and processing correspondence for mailing with the United States Postal Service. Under that practice, it would be deposited with U.S. 12 Postal Service on that same day with postage thereon fully prepaid (Certified Mail/Return Receipt 13 Requested) in the ordinary 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 is more than one day after date of 14 deposit for mailing in affidavit. 15 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 16 17 Executed on May 12, 2022, at San Jose, California. 18 19 20 TIMOTHY C. FEENEY 21 22 23 24 25 26 27 28 Public NOTICE OF SETTLEMENT - 3 1 Re: Beletsis v. Theta Chi Fraternity, et al. Case Number: 19CV03287 2 SERVICE LIST 3 Douglas E. Fierberg, Esq. 4 Fierberg National Law Group 161 East Front Street, Ste. 200 5 Traverse City, MI 49684 Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey 6 Phone: (202) 351-0510 Fax: (231) 252-8100 7 dfierberg@tfnlgroup.com 8 Ivo Labar, Esq. Sawyer & Labar LLP 9 1700 Montgomery Street, Suite 108 San Francisco, CA 941111 10 Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey Phone: (415) 262-3820 11 labar@sawyerlabar.com 12 Michael C. Osborne, Esq. Cokinos/Young 13 900 S. Capitol of Texas Highway Las Cimas IV, Ste. 425 14 Austin, TX 78746 Attorney for Defendant, Theta Chi Fraternity, Inc. 15 Phone: (512) 476-1080 16 Mary Childs, Esq. Yoka & Smith, LLP 17 445 South Figueroa Street, 38th Floor Los Angeles, CA 90071 18 Attorney for Defendants, Emmanuel Thomas; Bobby Karki; John Dylan Lietch Phone: (213) 427-2300 19 Fax: (213) 427-2330 mchilds@yokasmith.com 20 Derek H. Lim, Esq. 21 Demler, Armstrong & Rowland LLP 1350 Treat Boulevard, Suite 400 22 Walnut Creek, CA 94597 Attorney for Defendants, Chris Guevara; Bradley Visacki 23 Phone: (415) 949-1900 lim@darlaw.com 24 Chris A. Tarkington, Esq. 25 Tarkington, O'Neill, Barrack & Chong - SF 201 Mission Street, Suite 710 26 San Francisco, CA 94105 Attorney for Defendant, Najpreet Kahlon 27 Phone: (415) 777-5501 Fax: (415) 546-4962 28 Public NOTICE OF SETTLEMENT - 4 1 ctark@to2law.com 2 Robert Mackey, Esq. Veatch Carlson, LLP 3 1055 Wilshire Blvd., 11th Floor Los Angeles, CA 90017 4 Attorney for Defendant, Stefan Leon Phone: (213) 381-2861 5 Fax: (213) 383-6370 rmackey@veatchfirm.com 6 Matthew C. Jaime, Esq. 7 Metheny Sears Linkert & Jaime LLP 3638 American River Drive 8 Sacramento, CA 95864 Attorney for Defendant, Chris Guevara 9 Phone: (916) 978-3434 Fax: (916) 978-3430 10 mjaime@mathenysears.com 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Public NOTICE OF SETTLEMENT - 5 1 JOHN D. HOURIHAN, ESQ. – State Bar No. 099799 STRATMAN & WILLIAMS-ABREGO 2 P.O. Box 258829 Oklahoma City, OK 73125-8829 3 Phone: (510) 457-3440 Email: norcal.legal@farmersinsurance.com 4 Attorney for Defendant, 5 QUINN MCLAUGHLIN INDIVIDUALLY AND AS TRUSTEE OF THE QUINN M. MCLAUGHLIN LIVING TRUST 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SANTA CRUZ 10 11 DAPHNE BELETSIS, individually, and as Case No.: 19CV03287 Administrator of the Estate of ALEXANDER UNLIMITED JURISDICTION 12 BELETSIS, and YVONNE RAINEY, a surviving parent of ALEXANDER BELETSIS, deceased, ASSIGNED TO FOR ALL PURPOSES: 13 DEPT: Not Assigned Plaintiffs, 14 NOTICE OF SETTLEMENT (C.C.P. Section vs. 877.6(a)(2)) 15 THETA CHI FRATERNITY, INC., a New York 16 corporation, individually, as a member of the t/a the Theta Iota Chapter, University of California, Santa 17 Cruz, as a member of the fraternal order known as Theta Chi Fraternity, and as an alter-ego and 18 successor entity of the Theta Iota Chapter of the Theta Chi Fraternity; THETA IOTA CHAPTER OF 19 THETA CHI FRATERNITY, individually, and as an and agent and alter-ego of the Theta Chi 20 Fraternity, Inc.; CHRISTOPHER GUEVARA, individually, and as an agent/member of the Theta 21 Chi Fraternity, Inc. and Theta Iota Chapter of the Theta Chi Fraternity; BRAD VISACKI, individual, 22 and/or as an agent/member of Theta Chi Fraternity, Inc., and Theta Iota Chapter of Theta Chi 23 Fraternity; QUINN MCLAUGHLIN, individually and as Trustee of the QUINN M. MCLAUGHLIN 24 LIVING TRUST, 117 Pasture Road., Santa Cruz, CA, 95060, and JOHN DOES 1 through 25, 25 inclusive, individually, and as agents/members of Theta Chi Fraternity, Inc. and Theta Iota Chapter of 26 Theta Chi Fraternity, 27 Defendants. 28 Public NOTICE OF SETTLEMENT - 1 1 2 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: 3 NOTICE IS HEREBY GIVEN that a settlement has been entered into by and between 4 Plaintiffs, Daphne Beletsis, individually, and as Administrator of the Estate of Alexander Beletsis, and 5 Yvonne Rainey, a surviving parent of Alexander Beletsis, deceased, (“Plaintiffs”) and Defendants, 6 Quinn McLaughlin individually and as Trustee of the Quinn M. McLaughlin Living Trust 7 (“Defendants”). Said settlement is contingent upon a determination of good faith settlement, and 8 Defendants do hereby apply for an Order of this court determining that said settlement meets the 9 standards of good faith within the meaning of California Code of Civil Procedure, § 877.6(a)(2). 10 This Notice, Application and Proposed Order are made pursuant to California Code of Civil 11 Procedure § 877.6(a)(2). Within twenty-five (25) days of the mailing of this Notice, Application and the 12 Proposed Order, a non-settling party may file a Notice of Motion to Contest the Good Faith Settlement. 13 Said Motion by a non-settling party shall be given in a manner provided in subdivision (b) of Section 14 1005 of the California Code of Civil Procedure. If none of the non-settling parties files a Motion within 15 twenty-five (25) days of the mailing of this Notice, Application and Proposed Order, the court may 16 approve the settlement. If the court does approve the settlement and makes a determination that it has 17 been made in good faith, such determination by the court shall bar any other joint tortfeasor or co- 18 obligor from existing or future claims against the settling party for equitable contribution, comparative 19 indemnity, implied indemnity and declaratory relief. 20 This Application is based on this Notice, and the Application and Declaration of John D. 21 Hourihan filed concurrently herewith. 22 23 DATED: April __28___, 2022 STRATMAN & WILLIAMS-ABREGO 24 25 BY: JOHN D. HOURIHAN, ESQ. 26 Attorney for Defendant, QUINN MCLAUGHLIN INDIVIDUALLY AND AS 27 TRUSTEE OF THE QUINN M. MCLAUGHLIN LIVING TRUST 28 Public NOTICE OF SETTLEMENT - 2 1 Re: Beletsis v. Theta Chi Fraternity, et al. Case Number: 19CV03287 2 3 PROOF OF SERVICE Code of Civil Procedure §§ 1013a, 2015.5 4 I am a resident of the State of California and over the age of eighteen years, and not a party to the 5 within action. My business address is P.O. Box 258829, Oklahoma City, OK 73125-8829. On May 12, 2022, I served the following document(s): 6 7 NOTICE OF SETTLEMENT (C.C.P. Section 877.6(a)(2)) by placing the document(s) listed above in a sealed envelope, with prepaid postage 8 √ affixed for CERTIFIED MAIL/RETURN RECEIPT REQUESTED, addressed as 9 set forth below, and placing the envelope for collection and mailing in the place designated for such in our offices, following ordinary business practices. 10 11 I am readily familiar with the firm’s practice of collection and processing correspondence for mailing with the United States Postal Service. Under that practice, it would be deposited with U.S. 12 Postal Service on that same day with postage thereon fully prepaid (Certified Mail/Return Receipt 13 Requested) in the ordinary 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 is more than one day after date of 14 deposit for mailing in affidavit. 15 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 16 17 Executed on May 12, 2022, at San Jose, California. 18 19 20 TIMOTHY C. FEENEY 21 22 23 24 25 26 27 28 Public NOTICE OF SETTLEMENT - 3 1 Re: Beletsis v. Theta Chi Fraternity, et al. Case Number: 19CV03287 2 SERVICE LIST 3 Douglas E. Fierberg, Esq. 4 Fierberg National Law Group 161 East Front Street, Ste. 200 5 Traverse City, MI 49684 Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey 6 Phone: (202) 351-0510 Fax: (231) 252-8100 7 dfierberg@tfnlgroup.com 8 Ivo Labar, Esq. Sawyer & Labar LLP 9 1700 Montgomery Street, Suite 108 San Francisco, CA 941111 10 Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey Phone: (415) 262-3820 11 labar@sawyerlabar.com 12 Michael C. Osborne, Esq. Cokinos/Young 13 900 S. Capitol of Texas Highway Las Cimas IV, Ste. 425 14 Austin, TX 78746 Attorney for Defendant, Theta Chi Fraternity, Inc. 15 Phone: (512) 476-1080 16 Mary Childs, Esq. Yoka & Smith, LLP 17 445 South Figueroa Street, 38th Floor Los Angeles, CA 90071 18 Attorney for Defendants, Emmanuel Thomas; Bobby Karki; John Dylan Lietch Phone: (213) 427-2300 19 Fax: (213) 427-2330 mchilds@yokasmith.com 20 Derek H. Lim, Esq. 21 Demler, Armstrong & Rowland LLP 1350 Treat Boulevard, Suite 400 22 Walnut Creek, CA 94597 Attorney for Defendants, Chris Guevara; Bradley Visacki 23 Phone: (415) 949-1900 lim@darlaw.com 24 Chris A. Tarkington, Esq. 25 Tarkington, O'Neill, Barrack & Chong - SF 201 Mission Street, Suite 710 26 San Francisco, CA 94105 Attorney for Defendant, Najpreet Kahlon 27 Phone: (415) 777-5501 Fax: (415) 546-4962 28 Public NOTICE OF SETTLEMENT - 4 1 ctark@to2law.com 2 Robert Mackey, Esq. Veatch Carlson, LLP 3 1055 Wilshire Blvd., 11th Floor Los Angeles, CA 90017 4 Attorney for Defendant, Stefan Leon Phone: (213) 381-2861 5 Fax: (213) 383-6370 rmackey@veatchfirm.com 6 Matthew C. Jaime, Esq. 7 Metheny Sears Linkert & Jaime LLP 3638 American River Drive 8 Sacramento, CA 95864 Attorney for Defendant, Chris Guevara 9 Phone: (916) 978-3434 Fax: (916) 978-3430 10 mjaime@mathenysears.com 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Public NOTICE OF SETTLEMENT - 5 1 JOHN D. HOURIHAN, ESQ. – State Bar No. 099799 STRATMAN & WILLIAMS-ABREGO 2 P.O. Box 258829 Oklahoma City, OK 73125-8829 3 Phone: (510) 457-3440 Email: norcal.legal@farmersinsurance.com 4 Attorney for Defendant, 5 QUINN MCLAUGHLIN INDIVIDUALLY AND AS TRUSTEE OF THE QUINN M. MCLAUGHLIN LIVING TRUST 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SANTA CRUZ 10 11 DAPHNE BELETSIS, individually, and as Case No.: 19CV03287 Administrator of the Estate of ALEXANDER UNLIMITED JURISDICTION 12 BELETSIS, and YVONNE RAINEY, a surviving parent of ALEXANDER BELETSIS, deceased, ASSIGNED TO FOR ALL PURPOSES: 13 DEPT: Not Assigned Plaintiffs, 14 NOTICE OF SETTLEMENT (C.C.P. Section vs. 877.6(a)(2)) 15 THETA CHI FRATERNITY, INC., a New York 16 corporation, individually, as a member of the t/a the Theta Iota Chapter, University of California, Santa 17 Cruz, as a member of the fraternal order known as Theta Chi Fraternity, and as an alter-ego and 18 successor entity of the Theta Iota Chapter of the Theta Chi Fraternity; THETA IOTA CHAPTER OF 19 THETA CHI FRATERNITY, individually, and as an and agent and alter-ego of the Theta Chi 20 Fraternity, Inc.; CHRISTOPHER GUEVARA, individually, and as an agent/member of the Theta 21 Chi Fraternity, Inc. and Theta Iota Chapter of the Theta Chi Fraternity; BRAD VISACKI, individual, 22 and/or as an agent/member of Theta Chi Fraternity, Inc., and Theta Iota Chapter of Theta Chi 23 Fraternity; QUINN MCLAUGHLIN, individually and as Trustee of the QUINN M. MCLAUGHLIN 24 LIVING TRUST, 117 Pasture Road., Santa Cruz, CA, 95060, and JOHN DOES 1 through 25, 25 inclusive, individually, and as agents/members of Theta Chi Fraternity, Inc. and Theta Iota Chapter of 26 Theta Chi Fraternity, 27 Defendants. 28 Public NOTICE OF SETTLEMENT - 1 1 2 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: 3 NOTICE IS HEREBY GIVEN that a settlement has been entered into by and between 4 Plaintiffs, Daphne Beletsis, individually, and as Administrator of the Estate of Alexander Beletsis, and 5 Yvonne Rainey, a surviving parent of Alexander Beletsis, deceased, (“Plaintiffs”) and Defendants, 6 Quinn McLaughlin individually and as Trustee of the Quinn M. McLaughlin Living Trust 7 (“Defendants”). Said settlement is contingent upon a determination of good faith settlement, and 8 Defendants do hereby apply for an Order of this court determining that said settlement meets the 9 standards of good faith within the meaning of California Code of Civil Procedure, § 877.6(a)(2). 10 This Notice, Application and Proposed Order are made pursuant to California Code of Civil 11 Procedure § 877.6(a)(2). Within twenty-five (25) days of the mailing of this Notice, Application and the 12 Proposed Order, a non-settling party may file a Notice of Motion to Contest the Good Faith Settlement. 13 Said Motion by a non-settling party shall be given in a manner provided in subdivision (b) of Section 14 1005 of the California Code of Civil Procedure. If none of the non-settling parties files a Motion within 15 twenty-five (25) days of the mailing of this Notice, Application and Proposed Order, the court may 16 approve the settlement. If the court does approve the settlement and makes a determination that it has 17 been made in good faith, such determination by the court shall bar any other joint tortfeasor or co- 18 obligor from existing or future claims against the settling party for equitable contribution, comparative 19 indemnity, implied indemnity and declaratory relief. 20 This Application is based on this Notice, and the Application and Declaration of John D. 21 Hourihan filed concurrently herewith. 22 23 DATED: April __28___, 2022 STRATMAN & WILLIAMS-ABREGO 24 25 BY: JOHN D. HOURIHAN, ESQ. 26 Attorney for Defendant, QUINN MCLAUGHLIN INDIVIDUALLY AND AS 27 TRUSTEE OF THE QUINN M. MCLAUGHLIN LIVING TRUST 28 Public NOTICE OF SETTLEMENT - 2 1 Re: Beletsis v. Theta Chi Fraternity, et al. Case Number: 19CV03287 2 3 PROOF OF SERVICE Code of Civil Procedure §§ 1013a, 2015.5 4 I am a resident of the State of California and over the age of eighteen years, and not a party to the 5 within action. My business address is P.O. Box 258829, Oklahoma City, OK 73125-8829. On May 12, 2022, I served the following document(s): 6 7 NOTICE OF SETTLEMENT (C.C.P. Section 877.6(a)(2)) by placing the document(s) listed above in a sealed envelope, with prepaid postage 8 √ affixed for CERTIFIED MAIL/RETURN RECEIPT REQUESTED, addressed as 9 set forth below, and placing the envelope for collection and mailing in the place designated for such in our offices, following ordinary business practices. 10 11 I am readily familiar with the firm’s practice of collection and processing correspondence for mailing with the United States Postal Service. Under that practice, it would be deposited with U.S. 12 Postal Service on that same day with postage thereon fully prepaid (Certified Mail/Return Receipt 13 Requested) in the ordinary 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 is more than one day after date of 14 deposit for mailing in affidavit. 15 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 16 17 Executed on May 12, 2022, at San Jose, California. 18 19 20 TIMOTHY C. FEENEY 21 22 23 24 25 26 27 28 Public NOTICE OF SETTLEMENT - 3 1 Re: Beletsis v. Theta Chi Fraternity, et al. Case Number: 19CV03287 2 SERVICE LIST 3 Douglas E. Fierberg, Esq. 4 Fierberg National Law Group 161 East Front Street, Ste. 200 5 Traverse City, MI 49684 Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey 6 Phone: (202) 351-0510 Fax: (231) 252-8100 7 dfierberg@tfnlgroup.com 8 Ivo Labar, Esq. Sawyer & Labar LLP 9 1700 Montgomery Street, Suite 108 San Francisco, CA 941111 10 Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey Phone: (415) 262-3820 11 labar@sawyerlabar.com 12 Michael C. Osborne, Esq. Cokinos/Young 13 900 S. Capitol of Texas Highway Las Cimas IV, Ste. 425 14 Austin, TX 78746 Attorney for Defendant, Theta Chi Fraternity, Inc. 15 Phone: (512) 476-1080 16 Mary Childs, Esq. Yoka & Smith, LLP 17 445 South Figueroa Street, 38th Floor Los Angeles, CA 90071 18 Attorney for Defendants, Emmanuel Thomas; Bobby Karki; John Dylan Lietch Phone: (213) 427-2300 19 Fax: (213) 427-2330 mchilds@yokasmith.com 20 Derek H. Lim, Esq. 21 Demler, Armstrong & Rowland LLP 1350 Treat Boulevard, Suite 400 22 Walnut Creek, CA 94597 Attorney for Defendants, Chris Guevara; Bradley Visacki 23 Phone: (415) 949-1900 lim@darlaw.com 24 Chris A. Tarkington, Esq. 25 Tarkington, O'Neill, Barrack & Chong - SF 201 Mission Street, Suite 710 26 San Francisco, CA 94105 Attorney for Defendant, Najpreet Kahlon 27 Phone: (415) 777-5501 Fax: (415) 546-4962 28 Public NOTICE OF SETTLEMENT - 4 1 ctark@to2law.com 2 Robert Mackey, Esq. Veatch Carlson, LLP 3 1055 Wilshire Blvd., 11th Floor Los Angeles, CA 90017 4 Attorney for Defendant, Stefan Leon Phone: (213) 381-2861 5 Fax: (213) 383-6370 rmackey@veatchfirm.com 6 Matthew C. Jaime, Esq. 7 Metheny Sears Linkert & Jaime LLP 3638 American River Drive 8 Sacramento, CA 95864 Attorney for Defendant, Chris Guevara 9 Phone: (916) 978-3434 Fax: (916) 978-3430 10 mjaime@mathenysears.com 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Public NOTICE OF SETTLEMENT - 5 1 JOHN D. HOURIHAN, ESQ. – State Bar No. 099799 STRATMAN & WILLIAMS-ABREGO 2 P.O. Box 258829 Oklahoma City, OK 73125-8829 3 Phone: (510) 457-3440 Email: norcal.legal@farmersinsurance.com 4 Attorney for Defendant, 5 QUINN MCLAUGHLIN INDIVIDUALLY AND AS TRUSTEE OF THE QUINN M. MCLAUGHLIN LIVING TRUST 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SANTA CRUZ 10 11 DAPHNE BELETSIS, individually, and as Case No.: 19CV03287 Administrator of the Estate of ALEXANDER UNLIMITED JURISDICTION 12 BELETSIS, and YVONNE RAINEY, a surviving parent of ALEXANDER BELETSIS, deceased, ASSIGNED TO FOR ALL PURPOSES: 13 DEPT: Not Assigned Plaintiffs, 14 NOTICE OF SETTLEMENT (C.C.P. Section vs. 877.6(a)(2)) 15 THETA CHI FRATERNITY, INC., a New York 16 corporation, individually, as a member of the t/a the Theta Iota Chapter, University of California, Santa 17 Cruz, as a member of the fraternal order known as Theta Chi Fraternity, and as an alter-ego and 18 successor entity of the Theta Iota Chapter of the Theta Chi Fraternity; THETA IOTA CHAPTER OF 19 THETA CHI FRATERNITY, individually, and as an and agent and alter-ego of the Theta Chi 20 Fraternity, Inc.; CHRISTOPHER GUEVARA, individually, and as an agent/member of the Theta 21 Chi Fraternity, Inc. and Theta Iota Chapter of the Theta Chi Fraternity; BRAD VISACKI, individual, 22 and/or as an agent/member of Theta Chi Fraternity, Inc., and Theta Iota Chapter of Theta Chi 23 Fraternity; QUINN MCLAUGHLIN, individually and as Trustee of the QUINN M. MCLAUGHLIN 24 LIVING TRUST, 117 Pasture Road., Santa Cruz, CA, 95060, and JOHN DOES 1 through 25, 25 inclusive, individually, and as agents/members of Theta Chi Fraternity, Inc. and Theta Iota Chapter of 26 Theta Chi Fraternity, 27 Defendants. 28 Public NOTICE OF SETTLEMENT - 1 1 2 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: 3 NOTICE IS HEREBY GIVEN that a settlement has been entered into by and between 4 Plaintiffs, Daphne Beletsis, individually, and as Administrator of the Estate of Alexander Beletsis, and 5 Yvonne Rainey, a surviving parent of Alexander Beletsis, deceased, (“Plaintiffs”) and Defendants, 6 Quinn McLaughlin individually and as Trustee of the Quinn M. McLaughlin Living Trust 7 (“Defendants”). Said settlement is contingent upon a determination of good faith settlement, and 8 Defendants do hereby apply for an Order of this court determining that said settlement meets the 9 standards of good faith within the meaning of California Code of Civil Procedure, § 877.6(a)(2). 10 This Notice, Application and Proposed Order are made pursuant to California Code of Civil 11 Procedure § 877.6(a)(2). Within twenty-five (25) days of the mailing of this Notice, Application and the 12 Proposed Order, a non-settling party may file a Notice of Motion to Contest the Good Faith Settlement. 13 Said Motion by a non-settling party shall be given in a manner provided in subdivision (b) of Section 14 1005 of the California Code of Civil Procedure. If none of the non-settling parties files a Motion within 15 twenty-five (25) days of the mailing of this Notice, Application and Proposed Order, the court may 16 approve the settlement. If the court does approve the settlement and makes a determination that it has 17 been made in good faith, such determination by the court shall bar any other joint tortfeasor or co- 18 obligor from existing or future claims against the settling party for equitable contribution, comparative 19 indemnity, implied indemnity and declaratory relief. 20 This Application is based on this Notice, and the Application and Declaration of John D. 21 Hourihan filed concurrently herewith. 22 23 DATED: April __28___, 2022 STRATMAN & WILLIAMS-ABREGO 24 25 BY: JOHN D. HOURIHAN, ESQ. 26 Attorney for Defendant, QUINN MCLAUGHLIN INDIVIDUALLY AND AS 27 TRUSTEE OF THE QUINN M. MCLAUGHLIN LIVING TRUST 28 Public NOTICE OF SETTLEMENT - 2 1 Re: Beletsis v. Theta Chi Fraternity, et al. Case Number: 19CV03287 2 3 PROOF OF SERVICE Code of Civil Procedure §§ 1013a, 2015.5 4 I am a resident of the State of California and over the age of eighteen years, and not a party to the 5 within action. My business address is P.O. Box 258829, Oklahoma City, OK 73125-8829. On May 12, 2022, I served the following document(s): 6 7 NOTICE OF SETTLEMENT (C.C.P. Section 877.6(a)(2)) by placing the document(s) listed above in a sealed envelope, with prepaid postage 8 √ affixed for CERTIFIED MAIL/RETURN RECEIPT REQUESTED, addressed as 9 set forth below, and placing the envelope for collection and mailing in the place designated for such in our offices, following ordinary business practices. 10 11 I am readily familiar with the firm’s practice of collection and processing correspondence for mailing with the United States Postal Service. Under that practice, it would be deposited with U.S. 12 Postal Service on that same day with postage thereon fully prepaid (Certified Mail/Return Receipt 13 Requested) in the ordinary 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 is more than one day after date of 14 deposit for mailing in affidavit. 15 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 16 17 Executed on May 12, 2022, at San Jose, California. 18 19 20 TIMOTHY C. FEENEY 21 22 23 24 25 26 27 28 Public NOTICE OF SETTLEMENT - 3 1 Re: Beletsis v. Theta Chi Fraternity, et al. Case Number: 19CV03287 2 SERVICE LIST 3 Douglas E. Fierberg, Esq. 4 Fierberg National Law Group 161 East Front Street, Ste. 200 5 Traverse City, MI 49684 Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey 6 Phone: (202) 351-0510 Fax: (231) 252-8100 7 dfierberg@tfnlgroup.com 8 Ivo Labar, Esq. Sawyer & Labar LLP 9 1700 Montgomery Street, Suite 108 San Francisco, CA 941111 10 Attorney for Plaintiffs, Daphne Beletsis and Yvonne Rainey Phone: (415) 262-3820 11 labar@sawyerlabar.com 12 Michael C. Osborne, Esq. Cokinos/Young 13 900 S. Capitol of Texas Highway Las Cimas IV, Ste. 425 14 Austin, TX 78746 Attorney for Defendant, Theta Chi Fraternity, Inc. 15 Phone: (512) 476-1080 16 Mary Childs, Esq. Yoka & Smith, LLP 17 445 South Figueroa Street, 38th Floor Los Angeles, CA 90071 18 Attorney for Defendants, Emmanuel Thomas; Bobby Karki; John Dylan Lietch Phone: (213) 427-2300 19 Fax: (213) 427-2330 mchilds@yokasmith.com 20 Derek H. Lim, Esq. 21 Demler, Armstrong & Rowland LLP 1350 Treat Boulevard, Suite 400 22 Walnut Creek, CA 94597 Attorney for Defendants, Chris Guevara; Bradley Visacki 23 Phone: (415) 949-1900 lim@darlaw.com 24 Chris A. Tarkington, Esq. 25 Tarkington, O'Neill, Barrack & Chong - SF 201 Mission Street, Suite 710 26 San Francisco, CA 94105 Attorney for Defendant, Najpreet Kahlon 27 Phone: (415) 777-5501 Fax: (415) 546-4962 28 Public NOTICE OF SETTLEMENT - 4 1 ctark@to2law.com 2 Robert Mackey, Esq. Veatch Carlson, LLP 3 1055 Wilshire Blvd., 11th Floor Los Angeles, CA 90017 4 Attorney for Defendant, Stefan Leon Phone: (213) 381-2861 5 Fax: (213) 383-6370 rmackey@veatchfirm.com 6 Matthew C. Jaime, Esq. 7 Metheny Sears Linkert & Jaime LLP 3638 American River Drive 8 Sacramento, CA 95864 Attorney for Defendant, Chris Guevara 9 Phone: (916) 978-3434 Fax: (916) 978-3430 10 mjaime@mathenysears.com 11 12 13 14 15 16 17 18 19 20 21 22