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ClV-1 20
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
lvo Labar (203492), Jonathon Fazzola (PHV)*Doug|as E. Fierberg (PHV)*
The Fierberg National Law Group ELECTRONICALLY FILED
161 East Front Street, Suite 200 Superior Court of California
Traverse City, MI 49684
County of Santa Cruz
TELEPHONE N0.:23 1 -933-O1 80 FAX N0-: 231 -252—81 00
6/8/2021 2:11 PM
E-MAILADDRESS:jfazzola@tfnlgroup.com, dfierberg@tfn|group.com Alex Calvo, Clerk
AWORNEY FOR (Name):Plaintiffs
By: Helena Hanson, Deputy
SUPERIOR COURT 0F CALIFORNIA, COUNTY OF Santa Cruz
STREET ADDRESS:701 Ocean Street
MAILING ADDRESS:701Ocean Street
Santa Cruz, CA 95060
CITY AND ZIP CODE:
BRANCH NAME:
PLAINTIFF/PETITIONER: Daphne Beletsis; Yvonne Rainey
DEFENDANT/RESPONDENT: Theta Chi Fraternity,Inc., et aI.
NOTICE OF ENTRY OF DISMISSAL AND PROOF OF SERVICE
x Personal Injury, Property Damage, or Wrongful Death
- CASE NUMBER:
Motor Vehicle Other
_ 190v03287
Family Law
Eminent Domain
Other (specify):
T0 ATTORNEYS AND PARTIES WITHOUT ATTORNEYS: A dismissal was entered clerk as shown on the
in this action by the
Request for Dismissal. (Attach a copy completed by the clerk.)
Date: June 8, 2021
Jonathon N. Fazzola 7L
(TYPE OR PRINT NAME OFX ATTORNEY PARTY WITHOUT ATTORNEY) (SIGNATURE)
PROOF OF SERVICE
1. Iam over the age of 18 and not a party to this cause.My residence or business address is:
SEE ATTACHED PROOF OF SERVICE.
2. I am a resident of or
employed in the county where the mailing occurred. I served a copy of the Notice of Entry ofDismissal
and Request for Dismissal by mailing them, in a sealed envelope with postage fully prepaid, as follows:
I deposited the envelope with the United States Postal Service.
53'5”
I placed the envelope for collection and
processing for mailing following this business's ordinary practice with which I am
readily familiar. On the sameday correspondence is placed for collection and mailing, it is deposited in the ordinary
course of business with the United States Postal Service.
c. Date of deposit: d. Place of deposit (city and state):
e. Addressed as follows (name and address):
3 | served a copy of the Notice of Entry of Dismissal and Request for Dismissal by personally delivering copies as shown below:
a. Name of person served:
b. Address at which person served:
c. On (date): d. At (time):
4. I served a copy of the Notice of Entry of Dismissal and Request for Dismissal by electronically serving copies as shown below
(complete if electronic service is used based on a court order or agreement of the parties):
a. Name of person served:
b. Electronic service address of person served:
c. On (date): d. At (time):
e. Electronic service address from which I served the documents:
Proof of electronic service is attached.
5. Proof of service on additional parties is attached.
I declare under
penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: June 8, 2021
Taylor Picard
(TYPE 0R PRINT NAME)
Use
Form'Adopted for Mandatory
JudICIaI CounCII of Callfornla
’ 4
NOTICE 0F ENTRY 0F DISMISSAL
W (SIGNATURE F DECLARANT)
Page1 of1
Code of Civil Procedure, § 581 et seq.;
Cal. Rules of Court, rule 3.1390
CIv-120 [Rev. January 1, 2012] AND PROOF OF SERVICE www.courts.ca.gov
For your protection and privacy, please press the Clear
This Form button after you haVe Primed the form- Print this form Save this form Clear this form
CIV-1 10
ATTORNEY 0R PARTY WITHOUT ATTORNEY: STATE BAR N0:203492 FOR coum- usE ONLY
NAME: Ivo Labar, Jonathon Fazzola (PHV)*, Douglas Fierberg (PHV)*
FIRM NAME:The Fierberg National Law Group, PLLC*
STREETADDRESS: 161 East Front Street, Suite 200
CITY: Traverse City STATE: MI ZIP CODE: 49684
ELECTRONICALLY FILED
TELEPHONE NO.:231 -933—01 80 FAX N0.
:231-252-81 00 Superior Court of California
E-MAILADDRESS: County of Santa Cruz
labar@sawyerlabar.com,jfazzola@tfnlgroup.com,dfierberg@tfnlgroup.com
ATTORNEY FOR (Name):Plaintiffs 6/8/2021 10:38 AM
SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F Santa Cruz Alex Calvo, Clerk
STREET ADDRESS:701 Ocean Street By: Karen Broughton, Deputy
701
MAILING ADDRESS: Ocean Street
Santa Cruz, CA 95060
CITY AND ZIP CODE:
BRANCH NAME:
Plaintiff/Petitioner:
Daphne Beletsis, et al.
Defendant/Respondent: Theta Chi Fraternity, |nc., et al.
CASE NUMBER:
REQUEST FOR DISMISSAL 19CV03287
A conformed copy will not be returned by the clerk unless a method of return is provided with the document.
This form may not be used for dismissal of a derivative action or a class action or of any party or cause of action in a class
action. (Cal. Rules of Court, rules 3.760 and 3.770.)
1. TO THE CLERK: Please dismiss this action as follows:
a. (1) x With prejudice (2) Without prejudice
b. (1) Complaint (2) Petition
(3) Cross-complaint filed by (name): on (date):
(4) Cross-complaint filed by (name): on (date):
(5) Entire action of all parties and all causes
of action
(6) x Other (specify)? All causes of action against JORDAN KEIICHI TAKAYAMA, only.
2. (Complete in all cases except family law cases.)
The court did x did not waive court fees and costs for a party in this case.
(This information may be obtained from the
clerk. If court fees and costs were waived, the declaration on the back of thi m must be completed).
Date: June 8. 2021
Jonathon N. Fazzola
(TYPE 0R PRINT NAME 0F x ATTORNEY PARTY WITHOUT ATTORNEY) (SIGNATURE)
dismissal requested is of specied
*If causes of action only,
parties only of Specied Attorney 0r party Without attorney for:
or of specified cross-complaints only, so state and identify the parties, causes of
x plaintiff/petitioner Defendant/Respondent
action, or cross-complaints to be dismissed. ,
Cross ComplaInant
3. TO THE CLERK: Consent to the above dismissal is hereby given.**
Date:
(TYPE OR PRINT NAME 0F ATTORNEY PARTY WITHOUT ATTORNEY) (SIGNATURE)
**
cross-complaint — or Response (Family Law) seeking affirmative
If a Attorney or party without attorney for:
relief — is on file, the attorney for cross-complainant (respondent) must Sign
Plaintiff/Petitioner Defendant/Respondent
this consent if required by Code of Civil Procedure section 581 (i) or (j). .
C ross C omp aInan t
I
(To be completed by clerk)
4. Dismissal entered as requested on (date):
5 X Dismissal entered on (date): 6/8/2021 as to only (name): as above
6. Dismissal not entered as requested for the following reasons (specify):
7. a. Attorney or party without attorney notified on
(date):
b. Attorney or party without attorney not notified. Filing pa ovide
a copy to be conformed means to retur
Date: 6/8/2021 m Ell-W Clerkv by uDepUty Page1 on
Form Adopted for Mandatory Use Code of Civil Procedure, § 581 et seq.; Gov. Code,
Judicial Council of California REQU EST FOR D SMISSAL § 68637(c); Cal. Rules of Court, rule 3.1390
CIV—1 1 0 [Rev. Jan. 1, 201 3] www.courts.ca.gov
CIV-1 10
CASE NUMBER:
Daphne BeletSIS, et al.
Plalntlff/Petltloner:
1 QCVO3287
Defendant/Respondent: Theta Chi Fraternity,|nc., et al.
COURT'S RECOVERY OF WAIVED COURT FEES AND COSTS
party whose court fees and costs were initially waived has recovered or will recover $10,000 or more in
If a
value by way of settlement, compromise, arbitration award, mediation settlement, or other means, the
court has a statutory lien on that recovery. The court may refuse to dismiss the case
until the lien is
satised. (Gov. Code, § 68637.)
Declaration Concerning Waived Court Fees
1. The court waived court fees and costs inthis action for (name):
2. The person named in item1 is (check one below):
a. not recovering anything of value by this action.
b- recovering less than $10,000 in value by this action.
C. recovering $10,000 or more in value by this action. (Ifitem 2c is checked, item 3 must be completed.)
3. All court fees and court costs that were waived in this action have been paid to the court
(check one): Yes No
ldeclare under penalty of perjury under the laws of the State of California that the information above is true and correct.
Date:
(TYPE 0R PRINT NAME 0F ATrORNEY PARTY MAKING DECLARATION)
’ (S'GNATURE)
CIV-11o [Rem January 1. 20131 REQUEST FOR DISMISSAL Page 2°”
For your protection and privacy, please press the Clear
This Form button after you have printed the form. Save this form _|
PROOF OF SERVICE
1 At the time of service, I was over 18 years of age and not a party to this action. I am
2 employed in the County of Grand Traverse, State of Michigan. My business address is 161 East
3 Front Street, Suite 200, Traverse City, Michigan 49684.
4
5 On June 8, 2021, I served a true copy of the foregoing document described as
6 PLAINTIFFS’ NOTICE OF ENTRY OF DISMISSAL OF ALL CAUSES OF ACTION
7 AGAINST DEFENDANT JORDAN KEIICHI TAKAYAMA on the interested parties in this
8 action as follows:
9 Ray Tamaddon, Esq. Matthew C. Jaime, Esq.
Hinshaw & Culbertson LLP Robert W. Sweetin, Esq.
10 350 S. Grand Avenue, Suite 3600 K. Moji Majekodunmi, Esq.
Los Angeles, CA 90071 Rhonda Ladrido, Esq.
11 rtamaddon@hinshawlaw.com Matheny Sears Linkert & Jaime, LLP
3638 American River Drive
12 Robert J. Romero, Esq. Sacramento, CA 95864
Hinshaw & Culbertson LLP mjaime@mathenysears.com
13 One California Street, 18th Floor rsweetin@mathenysears.com
San Francisco, CA 94111 kmajekodunmi@mathenysears.com
14 rromero@hinshawlaw.com rladrido@mathenysears.com
Attorneys for Defendant Zachary Nash Davis Attorneys for Defendant Christopher Guevara
15
Julie Azevedo, Esq. John R. Brydon, Esq.
16 Shawn Toliver, Esq. Derek H. Lim, Esq.
Janet H. Leader, Esq. Shannon Mallory, Esq.
17 Lewis Brisbois Bisgaard & Smith LLP Demler, Armstrong & Rowland, LLP
2185 N. California Boulevard, Suite 300 1350 Treat Boulevard #400
18 Walnut Creek, CA 94596 Walnut Creek, CA 94597
Julie.Azevedo@lewisbrisbois.com bry@darlaw.com
19 Shawn.Toliver@lewisbrisbois.com lim@darlaw.com
Janet.Leader@lewisbrisbois.com mal@darlaw.com
20 Attorneys for Defendant Jordan Keiichi Attorneys for Defendant Brad Visacki
Takayama
21 Alan F. Hunter, Esq.
Michael C. Osborne, Esq. Elizabeth Gong Landess, Esq.
22 Jaskiran Samra, Esq. Gavin Cunningham & Hunter
Elaine Kobylecki, Esq. 1530 The Alameda, Suite 210
23 Cokinos | Young San Jose, CA 95126
One Embarcadero Center, Suite 390 hunter@gclitigation.com
24 San Francisco, CA 94111 landess@gclitigation.com
mosborne@cokinoslaw.com Attorneys for Defendant Rafael Garcia, Jr.
25 jsamra@cokinoslaw.com
ekobylecki@cokinoslaw.com Patrick Ball, Esq.
26 Attorneys for Defendant Theta Chi Fraternity, Iden Kashefipour, Esq.
Inc. Messner Reeves LLP
27 610 Newport Center Drive, Suite 420
Mary Childs, Esq. Newport Beach, CA 92660
28 Aaron Case, Esq. pball@messner.com
PROOF OF SERVICE
1 Yoka & Smith, LLP ikashefipour@messner.com
445 South Figueroa Street, 38th Floor Attorneys for Defendant Moises Tenorio Garcia
2 Los Angeles, CA 90071
mchilds@yokasmith.com Andrew M. Lauderdale, Esq.
3 acase@yokasmith.com Timothy Feeney, Esq.
Attorneys for Defendants Emmanuel Thomas, Hartsuyker, Stratman & Williams-Abrego
4 Bobby Karki & John Dylan Leitch One Almaden Boulevard #400
San Jose, CA 95113
5 Thomas M. Phillips, Esq. andrew.lauderdale@farmersinsurance.com
Jodi Rosner, Esq. timothy.feeney@farmersinsurance.com
6 The Phillips Firm, APC Attorneys for Defendant Quinn McLaughlin
800 West 6 th Street, Suite 980
7 Los Angeles, CA 90017 Dan Friedenthal, Esq.
tphillips@thephillipsfirm.com Friedenthal, Heffeman & Brown, LLP
8 jrosner@thephillipsfirm.com 1520 W. Colorado Blvd., 2nd Floor
Attorneys for Defendant Stefan Matias Leon Pasadena, CA 91105
9 dfriedenthal@FHBlawyers.com
Norman L. Chong, Esq. Attorney for Defendant Theta Iota Chapter of
10 Samantha Lewin, Esq. Theta Chi Fraternity
Joseph D. O’Neil, Esq.
11 Tarkington, O’Neill, Barrack & Chong
201 Mission Street, Suite 710
12 San Francisco, CA 94105
nchong@to2law.com
13 slewin@to2law.com
joneil@to2law.com
14 Attorneys for Defendant Najpreet Singh
Kahlon
15
16 BY EMAIL OR ELECTRONIC TRANSMISSION: In accordance with the California
17 Code of Civil Procedure 1010.6(e), I caused the following document(s) to be sent from e-mail
18 address tpicard@tfnlgroup.com to the person(s) at the email address(es) above. No electronic
19 messages or other indication that the transmission was unsuccessful was received within a
20 reasonable time after the transmission.
21
22 I declare under penalty of perjury under the laws of the State of Michigan that the
23 foregoing is true and correct.
24 Executed on June 8, 2021, at Traverse City, Michigan.
25 /s/ Taylor Picard
26 Taylor Picard
27
28
PROOF OF SERVICE