On May 12, 2010 a
Conference
was filed
involving a dispute between
Kwok, Jennifer Shuk-Han,
Kwong, Jeanne,
Ouyang, Feng,
Wong, Gary,
and
Kwok, Jennifer Shuk-Han,
Kwong, Jeanne,
Ouyang, Feng,
Stan Kwong Irrevocable Trust Ii,
Wong, Gary,
for OTHER PROBATE (petition by beneficiary to recover benefits of insurance proceeds from trustee on claims of breach of fiduciary duty, negligence and fraud)
in the District Court of San Francisco County.
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FREELAND COOPER & FOREMAN LLP.
150 Spear Street, Suite 1800
San Francisco, California 94105
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Daniel T. Bernhard (CSB #104229)
FREELAND COOPER & FOREMAN LLP.
150 Spear Street, Suite 1800
oa ana Neshsiea eeBOOHEE ELECTRONICALLY
elephone: -
Facsimile: (415) 495-4332 si ee
Email: bernhard@freelandlaw.com Caduty bi aun Pidacaecolt
Attorneys for Executor and Trustee 93/07/2016
Jennifer Shuk-Han Kwok BY:KURT KYAUK
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
PROBATE DIVISION
IN RE: STAN KWONG IRREVOCABLE CASE NO.: PES-10-293505
TRUST IE
PETITIONER’S RESPONSE TO
RESPONDENT’S OBJECTIONS TO REQUEST
FOR CASE MANAGEMENT CONFERENCE
TO SET MATTER FOR TRIAL
Petitioner Jennifer Shuk-Han Kwok, as the executor of the estate of Stan Kwong, and the
trustee and beneficiary of various Trusts created by Stan Kwong (“Petitioner”), responds to
Respondent Jeanne Kwong’s Objections to Petitioner’s Request for Case Management Conference to
Set Matter for Trial.
First, Petitioner’s action to recover $1,000,000 of life insurance proceeds paid out to the wrong
party as a result of Respondent’s errors, omissions and misconduct has not been resolved, directly,
indirectly or otherwise. Respondent describes no facts in her objections that support such a
remarkable assertion; instead, she discusses a Court of Appeal decision which is unrelated to this
insurance claim. The action remains pending, as it has for more than five years; it needs to be set for
trial.
Second, Respondent acknowledges that a case Management Conference is appropriate at this
1
PETITIONER’S RESPONSE TO OBJECTIONS TO REQUEST FOR CASE MANAGEMENT CONFERENCE TO SET MATTER FOR TRIAL
CASE NO.: PES-10-293505
(00238374 2}FREELAND COOPER & FOREMAN LLP
150 Spear Street, Suite 1800
San Francisco, California 94105
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time, although she believes it should be used to set a different matter for trial: Petitioner's pending
Allocation of Debt Petition. Petitioner disagrees, as the Court’s recent verdict in Petitioner’s
Disclaimer Petition resolves the most immediate issues raised in that Allocation Petition.
Nevertheless, these parties agree that a Case Management Conference is needed at this time; no other
party has objected, and thus Petitioner asks the Court to set one,
Respectfully Submitted,
FREELAND, COOPER & F'
March -) 2016
DANIEL T. BE
dttomneys for Petitioner
JENNIFER SHUK-HAN KWOK
2
PETITIONER'S RESPONSE TO OBJECTIONS TO REQUEST FOR CASE MANAGEMENT CONFERENCE TO SET MATTER FOR TRIAL
CASE NO.: PES-10-293505
{00238374 2}
Document Filed Date
March 07, 2016
Case Filing Date
May 12, 2010
Category
OTHER PROBATE (petition by beneficiary to recover benefits of insurance proceeds from trustee on claims of breach of fiduciary duty, negligence and fraud)
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FREELAND COOPER & FOREMAN LLP. 150 Spear Street, Suite 1800 San Francisco, California 94105 NN NY N NN NN N Be Be Be OS ec NAA BF BH =F SO we AA Daniel T. Bernhard (CSB #104229) FREELAND COOPER & FOREMAN LLP. 150 Spear Street, Suite 1800 oa ana Neshsiea eeBOOHEE ELECTRONICALLY elephone: - Facsimile: (415) 495-4332 si ee Email: bernhard@freelandlaw.com Caduty bi aun Pidacaecolt Attorneys for Executor and Trustee 93/07/2016 Jennifer Shuk-Han Kwok BY:KURT KYAUK Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO PROBATE DIVISION IN RE: STAN KWONG IRREVOCABLE CASE NO.: PES-10-293505 TRUST IE PETITIONER’S RESPONSE TO RESPONDENT’S OBJECTIONS TO REQUEST FOR CASE MANAGEMENT CONFERENCE TO SET MATTER FOR TRIAL Petitioner Jennifer Shuk-Han Kwok, as the executor of the estate of Stan Kwong, and the trustee and beneficiary of various Trusts created by Stan Kwong (“Petitioner”), responds to Respondent Jeanne Kwong’s Objections to Petitioner’s Request for Case Management Conference to Set Matter for Trial. First, Petitioner’s action to recover $1,000,000 of life insurance proceeds paid out to the wrong party as a result of Respondent’s errors, omissions and misconduct has not been resolved, directly, indirectly or otherwise. Respondent describes no facts in her objections that support such a remarkable assertion; instead, she discusses a Court of Appeal decision which is unrelated to this insurance claim. The action remains pending, as it has for more than five years; it needs to be set for trial. Second, Respondent acknowledges that a case Management Conference is appropriate at this 1 PETITIONER’S RESPONSE TO OBJECTIONS TO REQUEST FOR CASE MANAGEMENT CONFERENCE TO SET MATTER FOR TRIAL CASE NO.: PES-10-293505 (00238374 2}FREELAND COOPER & FOREMAN LLP 150 Spear Street, Suite 1800 San Francisco, California 94105 nN DN KR NN NM oe ee ee oe A Fo v8 —§ SF CH RDA A Fw time, although she believes it should be used to set a different matter for trial: Petitioner's pending Allocation of Debt Petition. Petitioner disagrees, as the Court’s recent verdict in Petitioner’s Disclaimer Petition resolves the most immediate issues raised in that Allocation Petition. Nevertheless, these parties agree that a Case Management Conference is needed at this time; no other party has objected, and thus Petitioner asks the Court to set one, Respectfully Submitted, FREELAND, COOPER & F' March -) 2016 DANIEL T. BE dttomneys for Petitioner JENNIFER SHUK-HAN KWOK 2 PETITIONER'S RESPONSE TO OBJECTIONS TO REQUEST FOR CASE MANAGEMENT CONFERENCE TO SET MATTER FOR TRIAL CASE NO.: PES-10-293505 {00238374 2}