On October 31, 2019 a
Proof of Service
was filed
involving a dispute between
Beletsis, Daphne,
Rainey, Yvonne,
Karki, Bobby,
Leitch, John Dylan,
Thomas, Emmanuel,
and
Davis, Zachary Nash,
Garcia, Moises Tenorio,
Garcia, Rafael,
Guevara, Christopher,
Kahlon, Najpreet Singh,
Karki, Bobby,
King, Derek,
Leitch, John Dylan,
Leon, Stefan Matias,
Mclaughlin, Quinn,
Takayama, Jordan Keiichi,
Theta Chi Fraternity, Inc.,
Theta Iota Chapter Of Theta Chi Fraternity,
Thomas, Emmanuel,
Visacki, Brad,
for (23) Unlimited Other PI / PD / WD
in the District Court of Santa Cruz County.
Preview
THE FIERBERG NATIONAL LAW GROUP, PLLC
DOUGLAS E. FIERBERG (admitted pro hac vice)
dfierberg@tfnlgroup.com
JONATHON N. FAZZOLA (admitted pro hac vice)
Jfazzola@t{nlgroup.com
LISA N. CLOUTIER (admitted pro hac vice)
Icloutier@tfnlgroup.com ELECTRONICALLY FILED
161 East Front Street, Suite 200
Superior Court of California
Traverse City, MI 49684 County of Santa Cruz
Telephone: (202) 351-0510 2/20/2020 3:00 PM
Fax: (231) 252-8100 Alex Calvo, Clerk
MK da
Marlen P jnee Dep
SAWYER & LABAR LLP ov len wee
TIVO LABAR, State Bar No. 203492
labar@sawyerlabar.com
201 Mission Street, Suite 2240
San Francisco, California 94105
Telephone: (415) 262-3820
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Attorneys for Plaintiffs
11 DAPHNE BELETSIS
YVONNE RAINEY
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13 SUPERIOR COURT OF CALIFORNIA
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sé 14 COUNTY OF SANTA CRUZ
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26 15 DAPHNE BELETSIS, individually, and as Case No. 19CV03287
&
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& 2 Administrator of the ESTATE OF
a2: 16 ALEXANDER BELETSIS, and PROOF OF SERVICE
YVONNE RAINEY, surviving parent of
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ALEXANDER BELETSIS, deceased
18
Plaintiffs,
19 vs.
20 THETA CHI FRATERNITY, INC., a New York
corporation, individually, as a member of and t/a
21
the Theta Iota Chapter, University of California,
22 Santa Cruz, as a member of the fraternal order
known as Theta Chi Fraternity, and as an alter-
23 ego and successor entity of the Theta Iota
Chapter of Theta Chi Fraternity;
24 THETA IOTA CHAPTER OF THETA CHI
FRATERNITY, individually, and as an and
25
agent and alter-ego of Theta Chi Fraternity, Inc.;
26 CHRISTOPER GUEVARA, individually, and as
an agent/member of Theta Chi Fraternity, Inc.
27 and Theta Iota Chapter of Theta Chi Fraternity;
BRAD VISACKL, individually, and/or as an
28 agent/member of Theta Chi Fraternity, Inc. and
Document2
PROOF OF SERVICE
Theta Iota Chapter of Theta Chi Fraternity;
JORDAN KEIICHI TAKAYAMA, individually,
and as an agent/member of Theta Chi Fraternity,
Inc. and Theta Iota Chapter of Theta Chi
Fraternity;
ZACHARY NASH DAVIS, individually, and as
an agent/member of Theta Chi Fraternity, Inc.
and Theta Iota Chapter of Theta Chi Fraternity;
NAJPREET SINGH KAHLON, individually,
and as an agent/member of Theta Chi Fraternity,
Inc. and Theta Iota Chapter of Theta Chi
Fraternity;
STEFAN MATIAS LEON, individually, and as
an agent/member of Theta Chi Fraternity, Inc.
and Theta Iota Chapter of Theta Chi Fraternity;
MOISES FRANCISCO TENORIO GARCIA,
10 individually, and as an agent/member of Theta
11 Chi Fraternity, Inc. and Theta Iota Chapter of
Theta Chi Fraternity;
12 RAFAEL GARCIA, individually, and as an
agent/member of Theta Chi Fraternity, Inc. and
13 Theta Iota Chapter of Theta Chi Fraternity;
Be
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B35 EMMANUEL THOMAS, individually, and as
sé 14 an agent/member of Theta Chi Fraternity, Inc.
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a and Theta Iota Chapter of Theta Chi Fraternity;
26 15
& & 2 BOBBY KARKI, individually, and as an
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a2: 16 agent/member of Theta Chi Fraternity, Inc. and
Theta Iota Chapter of Theta Chi Fraternity;
17 DEREK KING, individually, and as an
agent/member of Theta Chi Fraternity, Inc. and
18
Theta Iota Chapter of Theta Chi Fraternity;
19 JOHN DYLAN LEITCH, individually, and as
an agent/member of Theta Chi Fraternity, Inc.
20 and Theta Iota Chapter of Theta Chi Fraternity;
QUINN MCLAUGHLIN, individually and as
21 Trustee of the QUINN M. MCLAUGHLIN
LIVING TRUST, 117 Pasture Rd., Santa Cruz,
22
CA 95060; and
23 JOHN DOES 1 through 10, inclusive,
individually, and as agents/members of Theta
24 Chi Fraternity, Inc. and Theta Iota Chapter of
Theta Chi Fraternity;
25
Defendants.
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PROOF OF SERVICE
PROOF OF SERVICE
At the time of service, I was over 18 years of age and not a party to this action. I am
employed in the County of San Francisco, State of California. My business address is 201
Mission Street, 22nd Floor, San Francisco, CA 94105.
On February 20, 2020, I served true copies of the following document(s) described as
. APPLICATION AND STIPULATION FOR ORDER TO CONTINUE
MEDIATION HEARING AND/OR CASE MANAGEMENT CONFERENCE
e DECLARATION OF JONATHON N. FAZZOLA IN SUPPORT OF
APPLICATION AND STIPULATION FOR ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE
on the interested parties in this action as follows:
Michael C. Osborne, Esq. ‘Andrew M. Lauderdale, Esq.
10
Stevie Newton, Esq. IHARTSUYKER, STRATMAN & WILLIAMS-
11
Cokinos / Young (ABREGO
ne Embarcadero Center, Suite 390 P.O.Box 258829
12
San Francisco, CA 94111 klahoma City, OK 73125-8829
osborne@cokinoslaw.com ndrew.lauderdale@farmersinsurance.com
13 SNewton@cokinoslaw.com
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14 ‘Attorneys for Defendant, Theta Chi ‘Attorney for Defendant, Quinn McLaughlin
Fraternity, Inc.
59 15
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CERE BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
Bed ae document(s) to be sent from e-mail address guzman@sawyerlabar.com to the persons at the e-mail
16
addresses listed in the Service List. I did not receive, within a reasonable time after the
17 transmission, any electronic message or other indication that the transmission was unsuccessful.
18
19 [Derek Lim
\Demler Armstrong & Rowland, LLP
20 1350 Treat Blvd., Suite 400
(Walnut Creek, CA 94597
21 llim@darlaw.com
22 |Attorneys for Defendant
|Brad Visacki
23
BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the
24 persons at the addresses listed in the Service List and placed the envelope for collection and
mailing, following our ordinary business practices. I am readily familiar with the practice of
25 Sawyer & Labar LLP for collecting and processing correspondence for mailing. On the same day
that correspondence is placed for collection and mailing, it is deposited in the ordinary course of
26 business with the United States Postal Service, in a sealed envelope with postage fully prepaid. I
am a resident or employed in the county where the mailing occurred. The envelope was placed in
27 the mail at San Francisco, California.
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PROOF OF SERVICE
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed on February 20, 2020, at San Francisco, California.
Jd du Loy
Sarah Guzman
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PROOF OF SERVICE