On August 23, 2018 a
Motion-Secondary
was filed
involving a dispute between
Henry, Billy C,
Sunrise Ford Inc A California Corporation,
and
Bruncati, Daniel,
Bruncati, James,
Bruncati, Robert,
Does 2 Through 50,
Ford Motor Company,
Ford Motor Credit Company,
Sunrise Ford, Inc.,
for Business Tort
in the District Court of San Bernardino County.
Preview
D4r’28a’2022 11:53 ""£X) P.015/DBU
\v x.
ROBERT W. THOMPSON, Esq. (SBN 10641 1)
JIWON MICHAEL SHIN, Esq. (SEN 320504)
CALLAHAN, THOMPSON, SHERMAN F
& CAUDILL, LLP SUPERIOR CO’UL ED
2601 Main Street, Suite 300 Sffigm ORE; 3F CALIFORNM
WW
EHNARow CWBRDINO
Irvine, California 92614 ’V’SION
Tel: (949) 261-2872 A PR 49
Fax: 261 -6060 8 2022
(949)
Email: rthognpson@ctsclaw.com
QOOQGKIIAUJNI—
”Y
msh1n@ctsclgw.cgm
Attorneys for Defendant,
:
DEPUTY
SUNRISE FORD, INC.
SUPERIOR COURT OF CALIFORNIA
COUNTY 0F SAN BERNARDINO
«mumur
BILLY C. EENRY, Case No.: CIVDS l 822222
JUDGE: Hon. Khymberli S. Apaloo
il DEPARTMENT: $25
W» Plaintiff,
COMPLAINT DATE: August 23, 201 8
VS.
mm: DECLARATION OF JIWON MICHAEL
SUNRISE FORD a
INC FORD
-;
MOTOR HIN IN SUPPORT F DEFENDANT
CISC COMPANY; FORD MOTOR CREDIT EUNRISE FORD mg 's OPPOSITION
’
'
mun
COMPANY' and DOES through 50
’
1 ’
TO PLAINTIFF’S MOTION FOR LEAVE
inclusive ’
NNNNNNNNNF‘D—AHI—IHHo—av—Ib—IH
T0 FILE SECOND AMENDED
COMPLAINT
WQGMhWNHOWWQO‘M&WN'—‘o
Defendants.
Date: May 4, 2022
Time: 9:00 am.
Location: Dept. $25
I, JIWON MICHAEL SHIN, declare as follows:
am an associate in the law firm of
1. I am licensed to practice law in California and
Callahan, Thompson, Sherman & Caudill, LLP, counsel of record for defendant SUNRISE FORD,
INC, in the above captioned matter. This declaration is of my own personal knowledge of this case
and if called upon to testify as a witness, I could and
would competently
and the facts set forth herein,
testify as to the matters asserted herein.
- 1 .
SUNRISE FORD, INC.'S
DECLARATION OF JIWON MICHAEL SHIN IN SUPPORT OF DEFENDANT
FILE SECOND AMENDED COMPLAINT
OPPOSITION TO PLAINTIFF‘S MOTION FOR LEAVE TO
O4H'28r’ 2022 11 : 53 max; 9.01smso
2. Attached hereto as Exhibit A is a true and correct copy of emails between Plaintiff
and Defense counsel with meet and confer efforts regarding proposed stipulation to vacate the
5/9/2022 trial date.
3. Attached hereto as Exhibit B is a true and correct copy of emails between Plaintiff
and Defense counsel with meet and confer efforts regarding the Court’s orders at the IDC heard on
\OOOQO‘ALn#WN—c
4/15/2022.
4. Attached hereto as Exhibit C is a true and correct copy of Defendant’s Response to
Plaintiff‘s First Request for Supplemental Responses to Interrogatories, wherein Defendant
represented it had a $1,000,000 insurance policy applicable to the claims in Plaintiff’s operative
complaint.
LU'
true and
GQCHJHLL
I declare under penalty of perjury under the laws of California that the foregoing is
correct. Executed this 21" day of April 2022, at Irvine, California.
Sim
m
11w HAEL SHIN, mam
(‘fiim
NNNUNNNNNflwHwn—tn—na—ao—AHH
mquhWNHO‘OWNOfim-QWNHO
- 2 -
DECLARATION 0F “WON MICHAEL sum IN SUPPORT 0F DEFENDANT SUNRISE FORD,
mess
SECOND AMENDED COMPLAINT
OPPOSITION To PLAINTIFF'S MOTION FOR LEAVE To FILE
Document Filed Date
April 28, 2022
Case Filing Date
August 23, 2018
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
D4r’28a’2022 11:53 ""£X) P.015/DBU \v x. ROBERT W. THOMPSON, Esq. (SBN 10641 1) JIWON MICHAEL SHIN, Esq. (SEN 320504) CALLAHAN, THOMPSON, SHERMAN F & CAUDILL, LLP SUPERIOR CO’UL ED 2601 Main Street, Suite 300 Sffigm ORE; 3F CALIFORNM WW EHNARow CWBRDINO Irvine, California 92614 ’V’SION Tel: (949) 261-2872 A PR 49 Fax: 261 -6060 8 2022 (949) Email: rthognpson@ctsclaw.com QOOQGKIIAUJNI— ”Y msh1n@ctsclgw.cgm Attorneys for Defendant, : DEPUTY SUNRISE FORD, INC. SUPERIOR COURT OF CALIFORNIA COUNTY 0F SAN BERNARDINO «mumur BILLY C. EENRY, Case No.: CIVDS l 822222 JUDGE: Hon. Khymberli S. Apaloo il DEPARTMENT: $25 W» Plaintiff, COMPLAINT DATE: August 23, 201 8 VS. mm: DECLARATION OF JIWON MICHAEL SUNRISE FORD a INC FORD -; MOTOR HIN IN SUPPORT F DEFENDANT CISC COMPANY; FORD MOTOR CREDIT EUNRISE FORD mg 's OPPOSITION ’ ' mun COMPANY' and DOES through 50 ’ 1 ’ TO PLAINTIFF’S MOTION FOR LEAVE inclusive ’ NNNNNNNNNF‘D—AHI—IHHo—av—Ib—IH T0 FILE SECOND AMENDED COMPLAINT WQGMhWNHOWWQO‘M&WN'—‘o Defendants. Date: May 4, 2022 Time: 9:00 am. Location: Dept. $25 I, JIWON MICHAEL SHIN, declare as follows: am an associate in the law firm of 1. I am licensed to practice law in California and Callahan, Thompson, Sherman & Caudill, LLP, counsel of record for defendant SUNRISE FORD, INC, in the above captioned matter. This declaration is of my own personal knowledge of this case and if called upon to testify as a witness, I could and would competently and the facts set forth herein, testify as to the matters asserted herein. - 1 . SUNRISE FORD, INC.'S DECLARATION OF JIWON MICHAEL SHIN IN SUPPORT OF DEFENDANT FILE SECOND AMENDED COMPLAINT OPPOSITION TO PLAINTIFF‘S MOTION FOR LEAVE TO O4H'28r’ 2022 11 : 53 max; 9.01smso 2. Attached hereto as Exhibit A is a true and correct copy of emails between Plaintiff and Defense counsel with meet and confer efforts regarding proposed stipulation to vacate the 5/9/2022 trial date. 3. Attached hereto as Exhibit B is a true and correct copy of emails between Plaintiff and Defense counsel with meet and confer efforts regarding the Court’s orders at the IDC heard on \OOOQO‘ALn#WN—c 4/15/2022. 4. Attached hereto as Exhibit C is a true and correct copy of Defendant’s Response to Plaintiff‘s First Request for Supplemental Responses to Interrogatories, wherein Defendant represented it had a $1,000,000 insurance policy applicable to the claims in Plaintiff’s operative complaint. LU' true and GQCHJHLL I declare under penalty of perjury under the laws of California that the foregoing is correct. Executed this 21" day of April 2022, at Irvine, California. Sim m 11w HAEL SHIN, mam (‘fiim NNNUNNNNNflwHwn—tn—na—ao—AHH mquhWNHO‘OWNOfim-QWNHO - 2 - DECLARATION 0F “WON MICHAEL sum IN SUPPORT 0F DEFENDANT SUNRISE FORD, mess SECOND AMENDED COMPLAINT OPPOSITION To PLAINTIFF'S MOTION FOR LEAVE To FILE