On May 12, 2010 a
Motion-Secondary
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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Edward S. Zusman (SBN 154366)
MARKUN ZUSMAN FRENIERE & COMPTON LLP
465 California Street, Suite 401
San Francisco, CA 94104
(415) 438-4515 telephone
(415) 434-4505 facsimile
ezusman@mzclaw.com
Attorney for Respondent
GARY WONG
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
11/08/2016
Clerk of the Court
BY:LYDIA PAREDES
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
PROBATE DIVISION
JENNIFER SHUK-HAN KWOK,
Petitioner,
v.
JEANNE KWONG, individually and as a
former trustee of the Stan Kwong Irrevocable
Trust II,
Respondent.
AND RELATED CROSS-PETITIONS.
Case No. PES-10-293505
DECLARATION OF COUNSEL EDWARD S.
ZUSMAN IN SUPPORT OF MOTION FOR
SUMMARY JUDGMENT OR IN THE
ALTERNATIVE FOR SUMMARY
ADJUDICATION
Date: January 26, 2017
Thursday
Time: 2:00 PM.
Dept. 204
Location: 400 McAllister Street
San Francisco, CA 94102
Judge: Hon. Andrew Y.S. Cheng
Action filed: May 12, 2010
DATE APPROVED BY LESLIE
GOMEZ
I, Edward S. Zusman, declare:
1. Tam an attorney licensed to practice law in the courts of the State of California. I ama
partner with the Markun Zusman Freniere & Compton, LLP, the attorney of record for Respondent
1
DECLARATION OF COUNSEL EDWARD S. ZUSMAN IN SUPPORT OF MOTION FOR SUMMARY
JUDGMENT OR IN THE ALTERNATIVE FOR SUMMARY ADJUDICATIONGARY WONG (“Respondent”). I have personal knowledge of the matters set forth herein and could
testify competently thereto if so called.
2. I submit this declaration in support of Respondent’s Motion For Summary Judgment Or
In The Alternative Motion For Summary Adjudication.
3. Attached as Exhibit “A” to the Evidence in Support of Motion For Summary Judgment
Or In The Alternative Motion For Summary Adjudication filed herewith are true and correct copies of
excerpts from the reporter’s transcript of the deposition of Petitioner Jennifer Shuk-Han Kwok on
August 17, 2010.
4. Attached as Exhibit ““G” to the Evidence in Support of Motion For Summary Judgment
Or In The Alternative Motion For Summary Adjudication filed herewith is a true and correct copy of
the Estate Tax Return for Decedent Stan Kwong, executed by Petitioner Jennifer Shuk-Han Kwok on
October 7, 2010.
5. Attached as Exhibit “H” to the Evidence in Support of Motion For Summary Judgment
Or In The Alternative Motion For Summary Adjudication filed herewith are true and correct copies of
excerpts from the reporter’s trial transcript on July 2, 2015 during trial of a related case known as Jn re:
Stanley Chong Kwong, Case No. PES-09-293019.
6. Attached as Exhibit “K” to the Evidence in Support of Motion For Summary Judgment
Or In The Alternative Motion For Summary Adjudication filed herewith is a true and correct copy of
Petitioner Jennifer Shuk-Han Kwok’s Response to Special Interrogatories, Set One in the case entitled
Estate of Stanley Chong Kwong, Superior Court of San Francisco, Case No. PES-09-292733.
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct. Executed on November 8, 2016 at San Francisco, California.
LAA S. Zusman
2
DECLARATION OF COUNSEL EDWARD S. ZUSMAN IN SUPPORT OF MOTION FOR SUMMARY
JUDGMENT OR IN THE ALTERNATIVE FOR SUMMARY ADJUDICATION
Document Filed Date
November 08, 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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Edward S. Zusman (SBN 154366) MARKUN ZUSMAN FRENIERE & COMPTON LLP 465 California Street, Suite 401 San Francisco, CA 94104 (415) 438-4515 telephone (415) 434-4505 facsimile ezusman@mzclaw.com Attorney for Respondent GARY WONG ELECTRONICALLY FILED Superior Court of California, County of San Francisco 11/08/2016 Clerk of the Court BY:LYDIA PAREDES Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO PROBATE DIVISION JENNIFER SHUK-HAN KWOK, Petitioner, v. JEANNE KWONG, individually and as a former trustee of the Stan Kwong Irrevocable Trust II, Respondent. AND RELATED CROSS-PETITIONS. Case No. PES-10-293505 DECLARATION OF COUNSEL EDWARD S. ZUSMAN IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE FOR SUMMARY ADJUDICATION Date: January 26, 2017 Thursday Time: 2:00 PM. Dept. 204 Location: 400 McAllister Street San Francisco, CA 94102 Judge: Hon. Andrew Y.S. Cheng Action filed: May 12, 2010 DATE APPROVED BY LESLIE GOMEZ I, Edward S. Zusman, declare: 1. Tam an attorney licensed to practice law in the courts of the State of California. I ama partner with the Markun Zusman Freniere & Compton, LLP, the attorney of record for Respondent 1 DECLARATION OF COUNSEL EDWARD S. ZUSMAN IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE FOR SUMMARY ADJUDICATIONGARY WONG (“Respondent”). I have personal knowledge of the matters set forth herein and could testify competently thereto if so called. 2. I submit this declaration in support of Respondent’s Motion For Summary Judgment Or In The Alternative Motion For Summary Adjudication. 3. Attached as Exhibit “A” to the Evidence in Support of Motion For Summary Judgment Or In The Alternative Motion For Summary Adjudication filed herewith are true and correct copies of excerpts from the reporter’s transcript of the deposition of Petitioner Jennifer Shuk-Han Kwok on August 17, 2010. 4. Attached as Exhibit ““G” to the Evidence in Support of Motion For Summary Judgment Or In The Alternative Motion For Summary Adjudication filed herewith is a true and correct copy of the Estate Tax Return for Decedent Stan Kwong, executed by Petitioner Jennifer Shuk-Han Kwok on October 7, 2010. 5. Attached as Exhibit “H” to the Evidence in Support of Motion For Summary Judgment Or In The Alternative Motion For Summary Adjudication filed herewith are true and correct copies of excerpts from the reporter’s trial transcript on July 2, 2015 during trial of a related case known as Jn re: Stanley Chong Kwong, Case No. PES-09-293019. 6. Attached as Exhibit “K” to the Evidence in Support of Motion For Summary Judgment Or In The Alternative Motion For Summary Adjudication filed herewith is a true and correct copy of Petitioner Jennifer Shuk-Han Kwok’s Response to Special Interrogatories, Set One in the case entitled Estate of Stanley Chong Kwong, Superior Court of San Francisco, Case No. PES-09-292733. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on November 8, 2016 at San Francisco, California. LAA S. Zusman 2 DECLARATION OF COUNSEL EDWARD S. ZUSMAN IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE FOR SUMMARY ADJUDICATION