On May 12, 2010 a
Stipulation,Agreement
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 §, 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
Attorney for Respondent
GARY WONG
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
03/13/2017
Clerk of the Court
BY-MICHAEL RAYRAY
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
PROBATE DIVISION
Petitioner,
v.
JEANNE KWONG, individually and as a
former trustee of the Stan Kwong Irrevocable
Trust II,
Respondent.
/AND RELATED CROSS-PETITIONS.
BWwoR
Case No. PES-10-293505
STIPULATION MODIFYING BRIEFING
SCHEDULE RE DISCOVERY MOTIONS
Date: N/A
Time: NIA
Dept. 204
Location: 400 McAllister Street
San Francisco, CA 94102
Judge: Hon. Andrew Y,S. Cheng
Action filed: May 12, 2010
The Parties to this Action, by their counsel of record, hereby Stipulate as set forth below.
WHEREAS, under the Court’s current scheduling Order, the last day to hear discovery motions
is April 3, 2017;
1
STIPULATION MODIFYING BRIEFING SCHEDULE RE DISCOVERY MOTIONS;bo
WHEREAS, by Code the last day to file and serve (by hand) discovery motions is March 9,
2017;
WHEREAS, a discovery dispute has arisen between Respondent Gary Wong and Petitioner
Jennifer Shuk-Han Kwok REGARDING DOCUMENTS REQUESTED BY RESPONDENT AND
PRODUCED BY PETITIONER;
WHEREAS, counsel for Respondent and Petitioner have been engaged in good faith efforts to
informally resolve their discovery dispute, and continue to do so;
WHEREAS, the above parties believe that a minor modification of the briefing schedule will
allow the parties to continue their discussions and potentially narrow the issues in dispute;
WHEREAS, the parties agree to maintain the hearing date of April 3, 2017 for the hearing of
discovery motions; and
WHEREAS, the undersigned enter into this stipulation in good faith and not for purposes of
delay;
IT IS HEREBY STIPULATED THAT:
1, The last day for discovery motions to be filed is March 16 , 2017, with service to be
effected by electronic means;
2. Opposition to any motions shall be filed and served by electronic means by March 22,
2017;
3. Replies to any Opposition shall be filed and served by electronic means by March 27,
2017;
4, The hearing on any motions shall remain on April 3, 2017.
Daniel T-Bemhard
2
STIPULATION MODIFYING BRIEFING SCHEDULE RE DISCOVERY MOTIONSCm I A
March &, 2017
March _8 , 2017
Attorneys for Petitioner Jennifer Shuk-Han Kwok, as
Executor of the Estate of Stanley Chong Kwong, and as
Trustee of the Martial Trust under the Stanley Kwong and
Jennifer Kwok Revocable Trust
TOUR-SARKISS/AN p—
By: *
fcr
Phil Foster
Attorneys for Respondent Jeanne Kwong
MARKUN ZUSMAN FRENIERE & COMPTON LLP
By:
Edward S. Zusman
Attorney for Respondent ‘ong
3
STIPULATION MODIFYING BRIEFING SCHEDULE RE DISCOVERY MOTIONS
Document Filed Date
March 13, 2017
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 §, 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 Attorney for Respondent GARY WONG ELECTRONICALLY FILED Superior Court of California, County of San Francisco 03/13/2017 Clerk of the Court BY-MICHAEL RAYRAY Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO PROBATE DIVISION Petitioner, v. JEANNE KWONG, individually and as a former trustee of the Stan Kwong Irrevocable Trust II, Respondent. /AND RELATED CROSS-PETITIONS. BWwoR Case No. PES-10-293505 STIPULATION MODIFYING BRIEFING SCHEDULE RE DISCOVERY MOTIONS Date: N/A Time: NIA Dept. 204 Location: 400 McAllister Street San Francisco, CA 94102 Judge: Hon. Andrew Y,S. Cheng Action filed: May 12, 2010 The Parties to this Action, by their counsel of record, hereby Stipulate as set forth below. WHEREAS, under the Court’s current scheduling Order, the last day to hear discovery motions is April 3, 2017; 1 STIPULATION MODIFYING BRIEFING SCHEDULE RE DISCOVERY MOTIONS;bo WHEREAS, by Code the last day to file and serve (by hand) discovery motions is March 9, 2017; WHEREAS, a discovery dispute has arisen between Respondent Gary Wong and Petitioner Jennifer Shuk-Han Kwok REGARDING DOCUMENTS REQUESTED BY RESPONDENT AND PRODUCED BY PETITIONER; WHEREAS, counsel for Respondent and Petitioner have been engaged in good faith efforts to informally resolve their discovery dispute, and continue to do so; WHEREAS, the above parties believe that a minor modification of the briefing schedule will allow the parties to continue their discussions and potentially narrow the issues in dispute; WHEREAS, the parties agree to maintain the hearing date of April 3, 2017 for the hearing of discovery motions; and WHEREAS, the undersigned enter into this stipulation in good faith and not for purposes of delay; IT IS HEREBY STIPULATED THAT: 1, The last day for discovery motions to be filed is March 16 , 2017, with service to be effected by electronic means; 2. Opposition to any motions shall be filed and served by electronic means by March 22, 2017; 3. Replies to any Opposition shall be filed and served by electronic means by March 27, 2017; 4, The hearing on any motions shall remain on April 3, 2017. Daniel T-Bemhard 2 STIPULATION MODIFYING BRIEFING SCHEDULE RE DISCOVERY MOTIONSCm I A March &, 2017 March _8 , 2017 Attorneys for Petitioner Jennifer Shuk-Han Kwok, as Executor of the Estate of Stanley Chong Kwong, and as Trustee of the Martial Trust under the Stanley Kwong and Jennifer Kwok Revocable Trust TOUR-SARKISS/AN p— By: * fcr Phil Foster Attorneys for Respondent Jeanne Kwong MARKUN ZUSMAN FRENIERE & COMPTON LLP By: Edward S. Zusman Attorney for Respondent ‘ong 3 STIPULATION MODIFYING BRIEFING SCHEDULE RE DISCOVERY MOTIONS