Summons: DO WOO KIM, ET AL. VS HYUN JONG HAN, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 12/09/2019 03:31 PM Sherri R. Carter, Executive Officer/Clerk of Court, by E. Gregg,Deputy Clerk




                      Jae S. Kim, Esq. (State Bar No:134336)
               1      James A. Prietto, Esq. (State Bar No: 136831)
                      LAW FIRM OF J S KIM & ASSOCIATES
               2      3600 Wilshire Blvd., Suite 914
                      Los Angeles, California 90010
               3      Telephone:     (213) 389-0884
                      Facsimile:     (213) 389-0885
               4      JSKIM@JSKIMLAW.COM
               5
                       Attorneys for Plaintiffs,
               6       THE WILTON KOREAN PRESBYTERIAN CHURCH IN LOS ANGELES, et al.

               7                           SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                       FOR THE COUNTY OF LOS ANGELES – CENTRAL DISTRICT
               8

               9      THE WILTON KOREAN                                                       Case No: 19STCV16827
                      PRESBYTERIAN CHURCH IN LOS                                              (Related Case 19STCP02628)
              10
                      ANGELES, a Non-Profit Religious                                         (Related Case 19STCP04605)
                      Corporation; DO WOO KIM, an individual;
              11
                      DO RIM KIM, an individual;                                              [Assigned to the Honorable Richard E. Rico]

              12                                                                              PLAINTIFFS’ OPPOSITION TO
                                                           Plaintiffs,                        DEFENDANTS’ MOTION TO QUASH
              13                                                                              SERVICE OF SUMMONS
                      vs.
              14      HYUN JONG HAN, an individual; YONG                                      (Filed Concurrently with the Declaration of
                      CHUL CHO, an individual; FRANCIS                                        Muchin Deitke)
              15      KIM, an individual; NEE DON CHU, an
                      individual; DAE WON PARK, an                                            Date: December 20, 2019
              16      individual; & DOES 1 through 50, inclusive                              Time: 8:30 a.m.
                                                                                              Location: Dept. 17
              17                                           Defendants,
                                                                                              Complaint Filed: May 14, 2019
              18                                                                              Trial Date: None
              19                 Plaintiffs The Wilton Korean Presbyterian Los Angeles (“CHURCH”), Do Woo Kim
              20      (“WOO”) and Do Rim Kim (“RIM”) in the lead case submit their Opposition to Defendants’
              21      Motion to Quash Service of Summons.
              22

              23                                               I.          STATEMENT OF FACTS
              24      1. In early May of 2019, in order to protect CHURCH and its various properties, CHURCH, its
              25            Chairman of Board, WOO, along with its Secretary, RIM filed LASC Case No.
              26            19STCV18751’s Complaint (“CHURCH V. HAN”) and was served.
              27      2. Additional defendants, Jin Ho Seo, Grace Ran Seo, Grace Eunyoo Lee, Kyung A. Hong, and
              28            Sharon Kyuong Kim (collectively “MOVING PARTY”) were added as DOE defendants.


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                            PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION TO QUASH SERVICE OF SUMMONS