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  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
						
                                

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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 10 Attorneys for Plaintiffs 11 DAPHNE BELETSIS YVONNE RAINEY 12 13 SUPERIOR COURT OF CALIFORNIA Be 8g Se B35 sé 14 COUNTY OF SANTA CRUZ Gh a 26 15 DAPHNE BELETSIS, individually, and as Case No. 19CV03287 & Za & 2 Administrator of the ESTATE OF a2: 16 ALEXANDER BELETSIS, and PROOF OF SERVICE YVONNE RAINEY, surviving parent of 17 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 8g Se B35 EMMANUEL THOMAS, individually, and as sé 14 an agent/member of Theta Chi Fraternity, Inc. Gh a and Theta Iota Chapter of Theta Chi Fraternity; 26 15 & & 2 BOBBY KARKI, individually, and as an Za 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. 26 27 28 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 8g 14 ‘Attorneys for Defendant, Theta Chi ‘Attorney for Defendant, Quinn McLaughlin Fraternity, Inc. 59 15 2283 gee 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. 28 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 10 11 12 13 Be 8g Se B35 sé 14 Gh aOZ 26 15 & & 2 Za a5? 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE