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1 AARON S. CASE, Bar #265751
acase@yokasmith.com
2 MARY CHILDS, Bar # 134274
3 mchilds@yokasmith.com
YOKA | SMITH, LLP
4 445 South Figueroa Street, 38th Floor
Los Angeles, California 90071
5 Phone: (213) 427-2300
6 Fax: (213) 427-2330
Attorneys for Defendants, EMMANUEL THOMAS, BOBBY KARKI, and JOHN DYLAN LEITCH
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF SANTA CRUZ
10
11 DAPHNE BELETSIS, individually, and as ) Case No.: 19CV03287
Administrator of the ESTATE OF ALEXANDER ) Assigned to Hon. Paul Marigonda – Dept. 10
12 BELETSIS, and YVONNE RAINEY, surviving )
13 parent of ALEXANDER BELETSIS, deceased, ) DEFENDANTS BOBBY KARKI, JOHN
) DYLAN LEITCH, EMMANUEL THOMAS
14 Plaintiffs, ) AND BRAD VISACKI’S NOTICE OF
vs. ) SETTLEMENT WITH PLAINTIFFS
15 )
16 THETA CHI FRATERNITY, INC., a New York )
corporation, individually, as a member of and t/a )
17 the Theta Iota Chapter, University of California, ) Action Filed: October 31, 2019
Santa Cruz, as a member of the fraternal order )
18 known as Theta Chi Fraternity, and as an alter-ego) First Amended Complaint
and successor entity of the Theta Iota Chapter of ) Filed: February 5, 2020
19
Theta Chi Fraternity; THETA IOTA CHAPTER )
20 OF THETA CHI FRATERNITY, individually, )
and as an agent and alter-ego of Theta Chi )
21 Fraternity, Inc.; CHRISTOPHER GUEVARA, )
individually, and as an agent/member of Theta )
22
Chi Fraternity, Inc. and Theta Iota Chapter of )
23 Theta Chi Fraternity; BRAD VISACKI, )
individually, and as an agent/member of Theta )
24 Chi Fraternity, Inc. and Theta Iota Chapter of )
Theta Chi Fraternity; JORDAN KEIICHI )
25
TAKAYAMA, individually, and as an )
26 agent/member of Theta Chi Fraternity, Inc. and )
Theta Iota Chapter of Theta Chi Fraternity; )
27 ZACHARY NASH DAVIS, individually, and as )
an agent/member of Theta Chi Fraternity, Inc. and )
28
Theta Iota Chapter of Theta Chi Fraternity; )
1
DEFENDANTS EMMANUEL THOMAS, BOBBY KARKI, JOHN DYLAN LEITCH AND
BRAD VISACKI’S NOTICE OF SETTLEMENT WITH PLAINTIFFS
1 NAJPREET SINGH KAHLON, individually, and )
as an agent/member of Theta Chi Fraternity, Inc. )
2 and Theta Iota Chapter of Theta Chi Fraternity; )
STEFAN MATIAS LEON, individually, and as )
3 an agent/member of Theta Chi Fraternity, Inc. and )
Theta Iota Chapter of Theta Chi Fraternity; )
4
MOISES FRANCISCO TENORIO GARCIA, )
5 individually, and as an agent/member of Theta )
Chi Fraternity, Inc. and Theta Iota Chapter of )
6 Theta Chi Fraternity; RAFAEL GARCIA, )
individually, and as an agent/member of Theta )
7
Chi Fraternity, Inc. and Theta Iota Chapter of )
8 Theta Chi Fraternity; EMMANUEL THOMAS, )
individually, and as an agent/member of Theta )
9 Chi Fraternity, Inc. and Theta Iota Chapter of )
Theta Chi Fraternity; BOBBY KARKI, )
10
individually, and as an agent/member of Theta )
11 Chi Fraternity, Inc. and Theta Iota Chapter of )
Theta Chi Fraternity; DEREK KING, )
12 individually, and as an agent/member of Theta )
Chi Fraternity, Inc. and Theta Iota Chapter of )
13
Theta Chi Fraternity; JOHN DYLAN LEITCH, )
14 individually, and as an agent/member of Theta )
Chi Fraternity, Inc. and Theta Iota Chapter of )
15 Theta Chi Fraternity; QUINN MCLAUGHLIN, )
individually and as Trustee of the QUINN M. )
16 MCLAUGHLIN LIVING TRUST, 117 Pasture )
17 Rd., Santa Cruz, CA 95060; and JOHN DOES 1 )
through 10, inclusive, individually, and as )
18 agents/members of Theta Chi Fraternity, Inc. and )
Theta Iota Chapter of Theta Chi Fraternity, )
19 )
20 Defendants. )
)
21 )
22
23 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
24 PLEASE TAKE NOTICE that this matter has settled as between Plaintiffs, DAPHNE
25 BELETSIS, individually, and as Administrator of the ESTATE OF ALEXANDER BELETSIS, and
26 YVONNE RAINEY, surviving parent of ALEXANDER BELETSIS, deceased (hereafter Plaintiffs),
27 and Defendants, BOBBY KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS and BRAD
28 VISACKI.
2
DEFENDANTS EMMANUEL THOMAS, BOBBY KARKI, JOHN DYLAN LEITCH AND
BRAD VISACKI’S NOTICE OF SETTLEMENT WITH PLAINTIFFS
1 The aforesaid settlement was entered into pursuant to negotiations and evaluation of
2 potential liability, or lack thereof.
3 PLEASE TAKE FURTHER NOTICE that although this constitutes a complete resolution
4 related to these parties, there are other parties in the case and the matter that have not settled.
5 This Notice and the concurrently served and filed Application and [Proposed] Order are
6 made pursuant to California Code of Civil Procedure Section 977.6(a)(2). Within twenty-five (25)
7 days of the mailing of this Notice, Application and the Proposed Order, a non-settling party may file a
8 Notice of Motion to Contest the Good Faith Settlement. Said Motion by non-settling party shall be
9 given in a manner provided in subdivision (b) of Section 1005 of the California Code of Civil
10 Procedure. If none of the non-settling parties’ files a Motion within twenty-five (25) days of the
11 mailing of this Notice, Application and Proposed Order, the court may approve the settlement. If the
12 Court approves the settlement and makes a determination that it has been made in good faith, such
13 determination by the court shall bar any other joint tortfeasor or co-obligor from existing or future
14 claims against the settling party for equitable contribution, comparative indemnity, implied indemnity
15 and declaratory relief.
16 This Application is based on this Notice and the Application for Good Faith Settlement
17 Determination, the attached Declarations of Mary Childs and Derek H. Lim and exhibits thereto, the
18 concurrently filed [Proposed] Order, the concurrently filed Declaration of Proof of Service by
19 Certified Mail, and all other documents filed concurrently herewith.
20
21 Date: April 4, 2022 YOKA | SMITH, LLP
22
23 By _____________________________________
AARON S. CASE
24 MARY CHILDS
25 Attorneys for Defendants, EMMANUEL
THOMAS, BOBBY KARKI, and JOHN DYLAN
26 LEITCH
27
28
3
DEFENDANTS EMMANUEL THOMAS, BOBBY KARKI, JOHN DYLAN LEITCH AND
BRAD VISACKI’S NOTICE OF SETTLEMENT WITH PLAINTIFFS
CRS.35148-Bele
PROOF OF SERVICE
CCP 1013
1 Daphne Beletsis, et al. v. Theta Chi Fraternity, et al.
Santa Cruz County Case No. 19CV03287
2
I am employed in the County of Los Angeles, State of California. I am over the age of 18 and
3 not a party to the within action; my business address is 445 South Figueroa Street, 38th Floor, Los Angeles,
California 90071.
4
On April 4, 2022, I served true copies of the foregoing document described as DEFENDANTS
5 BOBBY KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS AND BRAD VISACKI’S
NOTICE OF SETTLEMENT WITH PLAINTIFFS on the interested party or parties in this action as
6
follows:
7
***SEE ATTACHED SERVICE LIST***
8
9 [X] (BY CERTIFIED MAIL – RETURN RECEIPT REQUESTED) I am familiar with our
firm’s practice of collection and processing correspondence for mailing. Under that practice it
10 would be deposited with the U.S. Postal Service on that same day in the ordinary course of
business. I am aware that on motion of the party served, service is presumed invalid if the
11 postal cancellation date or postage meter date is more than one working day after the date of
deposit for mailing in this declaration.
12
[ ] (BY FACSIMILE) In addition to regular mail, I sent this document via facsimile, number(s) as
13 listed on the service list on April 4, 2022.
14 [X] (BY EMAIL) I sent a courtesy copy of this document to the email addresses as listed on the
15 service list on April 4, 2022.
ONLY BY ELECTRONIC TRANSMISSION. Only by e-mailing the document(s) to the
16
persons at the email address(es) listed. This is necessitated during the declared National
17 Emergency due to the Coronavirus (COVID-19) pandemic, as this office is mostly working
remotely, not able to send physical mail as usual, and is therefore using electronic mail. No
18 electronic message or other indication that the transmission was unsuccessful was received
within a reasonable time after the transmission.
19
[ ] (BY OVERNIGHT DELIVERY) By placing a true copy thereof enclosed in a sealed FedEx
20 envelope, on April 4, 2022, with such fees prepaid, deposited in a FedEx depository at Los
Angeles, CA in the ordinary course of business.
21
[ ] (BY PERSONAL SERVICE) Such envelope was delivered by an agent of Document Delivery
22 Service by hand to the office of the addressee.
23 [X] (STATE) I declare under penalty of perjury under the laws of the State of California that the
24 foregoing is true and correct.
25 Executed on April 4, 2022 at Los Angeles, California.
26
27 _________________________
An McNulty
28
1
CRS.35148-Bele
Daphne Beletsis, et al. v. Theta Chi Fraternity, et al.
Santa Cruz County Case No. 19CV03287
1
SERVICE LIST
2
3 Douglas E. Fierberg (admitted pro hac vice) Daniel R. Friedenthal; James Lee
dfierberg@tfnlgroup.com Jay D. Brown
4
Jonathan N. Fazzola (admitted pro hac vice) ph. FRIEDENTHAL, HEFFERNAN & BROWN, LLP
5 231.933.0180 1520 W. Colorado Boulevard, Second Floor
jfazzola@tfnlgroup.com Pasadena, California 91105
6 Lisa N. Cloutier (admitted pro hac vice) T: (626) 628-2800 F: (626) 628-2828
lcloutier@tfnlgroup.com dfriedenthal@FHBLawyers.com;
7 THE FIERBERG NATIONAL LAW GROUP, PLLC jlee@fhblawyers.com; jbrown@FHBLawyers.com
161 East Front Street, Suite 200 cc: nruiz@FHBLawyers.com
8 Traverse City, MI 49684 Attorneys for Specially Appearing Defendant,
cc: kfarese@tfnlgroup.com THETA IOTA CHAPTER OF THETA CHI
9 (202) 351-0510 Fax: (231) 252-8100 FRATERNITY
10 Ivo Labar Patrick Ball
labar@sawyerlabar.com
11 Idin Kashefipour
SAWYER & LABAR LLP
MESSNER REEVES, LLP
1700 Montgomery, Suite 108
12 650 Town Center Drive, Suite 700
San Francisco, CA 94111
Costa Mesa, CA 92626
13 (415) 262-3820
Tel: (949) 612-9128 Fax: (949) 438-2304
cc: guzman@sawyerlabar.com;
pball@messner.com; ikashefipour@messner.com
14 marinkovich@sawyerlabar.com
Attorneys for Defendant, MOISES TENORIO
Attorneys for Plaintiffs, DAPHNE BELETSIS and
GARCIA
15 YVONNE RAINEY
16 John D. Hourihan John R. Brydon
STRATMAN, SCHWARTZ & WILLIAMS-ABREGO Derek H. Lim
17 P.O. Box 258829 Shannon Mallory
Oklahoma City, OK 73125-8829 DEMLER ARMSTRONG & ROWLAND, LLP
18
(510) 457-3440 1990 N. California Blvd., Eighth Floor
John.Hourihan@farmersinsurance.com Walnut Creek, CA 94596
19
Attorney for Defendant, QUINN McLAUGHLIN T: 415.949-1900 â–ª Cell 415.317.3693
20 lim@darlaw.com; bry@darlaw.com
mal@darlaw.com
21 cc: Peri Clark cla@darlaw.com
Attorney for Defendant, BRAD VISACKI
22
Michael C. Osborne Matthew C. Jaime
23 Jaskiran Samra Robert W. Sweetin
Elaine Kobylecki MATHENY SEARS LINKERT & JAIME LLP
24 COKINOS | YOUNG 3638 American River Drive
611 Gateway Boulevard, Suite 233 Sacramento, CA 95864
25 (916) 978-3434 Fax: (916) 978-3430
South San Francisco, CA 94080
(628) 229-9280 mjaime@mathenysears.com
26 rsweetin@mathenysears.com
mosborne@cokinoslaw.com; jsamra@cokinoslaw.com
ekobylecki@cokinoslaw.com; cc:asanchez@cokinoslaw.com Attorney for Defendant, CHRIS GUEVARA
27
Attorney for Defendant, THETA CHI FRATERNITY, INC.
28
2
Preview
1 AARON S. CASE, Bar #265751 acase@yokasmith.com 2 MARY CHILDS, Bar # 134274 3 mchilds@yokasmith.com YOKA | SMITH, LLP 4 445 South Figueroa Street, 38th Floor Los Angeles, California 90071 5 Phone: (213) 427-2300 6 Fax: (213) 427-2330 Attorneys for Defendants, EMMANUEL THOMAS, BOBBY KARKI, and JOHN DYLAN LEITCH 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SANTA CRUZ 10 11 DAPHNE BELETSIS, individually, and as ) Case No.: 19CV03287 Administrator of the ESTATE OF ALEXANDER ) Assigned to Hon. Paul Marigonda – Dept. 10 12 BELETSIS, and YVONNE RAINEY, surviving ) 13 parent of ALEXANDER BELETSIS, deceased, ) DEFENDANTS BOBBY KARKI, JOHN ) DYLAN LEITCH, EMMANUEL THOMAS 14 Plaintiffs, ) AND BRAD VISACKI’S NOTICE OF vs. ) SETTLEMENT WITH PLAINTIFFS 15 ) 16 THETA CHI FRATERNITY, INC., a New York ) corporation, individually, as a member of and t/a ) 17 the Theta Iota Chapter, University of California, ) Action Filed: October 31, 2019 Santa Cruz, as a member of the fraternal order ) 18 known as Theta Chi Fraternity, and as an alter-ego) First Amended Complaint and successor entity of the Theta Iota Chapter of ) Filed: February 5, 2020 19 Theta Chi Fraternity; THETA IOTA CHAPTER ) 20 OF THETA CHI FRATERNITY, individually, ) and as an agent and alter-ego of Theta Chi ) 21 Fraternity, Inc.; CHRISTOPHER GUEVARA, ) individually, and as an agent/member of Theta ) 22 Chi Fraternity, Inc. and Theta Iota Chapter of ) 23 Theta Chi Fraternity; BRAD VISACKI, ) individually, and as an agent/member of Theta ) 24 Chi Fraternity, Inc. and Theta Iota Chapter of ) Theta Chi Fraternity; JORDAN KEIICHI ) 25 TAKAYAMA, individually, and as an ) 26 agent/member of Theta Chi Fraternity, Inc. and ) Theta Iota Chapter of Theta Chi Fraternity; ) 27 ZACHARY NASH DAVIS, individually, and as ) an agent/member of Theta Chi Fraternity, Inc. and ) 28 Theta Iota Chapter of Theta Chi Fraternity; ) 1 DEFENDANTS EMMANUEL THOMAS, BOBBY KARKI, JOHN DYLAN LEITCH AND BRAD VISACKI’S NOTICE OF SETTLEMENT WITH PLAINTIFFS 1 NAJPREET SINGH KAHLON, individually, and ) as an agent/member of Theta Chi Fraternity, Inc. ) 2 and Theta Iota Chapter of Theta Chi Fraternity; ) STEFAN MATIAS LEON, individually, and as ) 3 an agent/member of Theta Chi Fraternity, Inc. and ) Theta Iota Chapter of Theta Chi Fraternity; ) 4 MOISES FRANCISCO TENORIO GARCIA, ) 5 individually, and as an agent/member of Theta ) Chi Fraternity, Inc. and Theta Iota Chapter of ) 6 Theta Chi Fraternity; RAFAEL GARCIA, ) individually, and as an agent/member of Theta ) 7 Chi Fraternity, Inc. and Theta Iota Chapter of ) 8 Theta Chi Fraternity; EMMANUEL THOMAS, ) individually, and as an agent/member of Theta ) 9 Chi Fraternity, Inc. and Theta Iota Chapter of ) Theta Chi Fraternity; BOBBY KARKI, ) 10 individually, and as an agent/member of Theta ) 11 Chi Fraternity, Inc. and Theta Iota Chapter of ) Theta Chi Fraternity; DEREK KING, ) 12 individually, and as an agent/member of Theta ) Chi Fraternity, Inc. and Theta Iota Chapter of ) 13 Theta Chi Fraternity; JOHN DYLAN LEITCH, ) 14 individually, and as an agent/member of Theta ) Chi Fraternity, Inc. and Theta Iota Chapter of ) 15 Theta Chi Fraternity; QUINN MCLAUGHLIN, ) individually and as Trustee of the QUINN M. ) 16 MCLAUGHLIN LIVING TRUST, 117 Pasture ) 17 Rd., Santa Cruz, CA 95060; and JOHN DOES 1 ) through 10, inclusive, individually, and as ) 18 agents/members of Theta Chi Fraternity, Inc. and ) Theta Iota Chapter of Theta Chi Fraternity, ) 19 ) 20 Defendants. ) ) 21 ) 22 23 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: 24 PLEASE TAKE NOTICE that this matter has settled as between Plaintiffs, DAPHNE 25 BELETSIS, individually, and as Administrator of the ESTATE OF ALEXANDER BELETSIS, and 26 YVONNE RAINEY, surviving parent of ALEXANDER BELETSIS, deceased (hereafter Plaintiffs), 27 and Defendants, BOBBY KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS and BRAD 28 VISACKI. 2 DEFENDANTS EMMANUEL THOMAS, BOBBY KARKI, JOHN DYLAN LEITCH AND BRAD VISACKI’S NOTICE OF SETTLEMENT WITH PLAINTIFFS 1 The aforesaid settlement was entered into pursuant to negotiations and evaluation of 2 potential liability, or lack thereof. 3 PLEASE TAKE FURTHER NOTICE that although this constitutes a complete resolution 4 related to these parties, there are other parties in the case and the matter that have not settled. 5 This Notice and the concurrently served and filed Application and [Proposed] Order are 6 made pursuant to California Code of Civil Procedure Section 977.6(a)(2). Within twenty-five (25) 7 days of the mailing of this Notice, Application and the Proposed Order, a non-settling party may file a 8 Notice of Motion to Contest the Good Faith Settlement. Said Motion by non-settling party shall be 9 given in a manner provided in subdivision (b) of Section 1005 of the California Code of Civil 10 Procedure. If none of the non-settling parties’ files a Motion within twenty-five (25) days of the 11 mailing of this Notice, Application and Proposed Order, the court may approve the settlement. If the 12 Court approves the settlement and makes a determination that it has been made in good faith, such 13 determination by the court shall bar any other joint tortfeasor or co-obligor from existing or future 14 claims against the settling party for equitable contribution, comparative indemnity, implied indemnity 15 and declaratory relief. 16 This Application is based on this Notice and the Application for Good Faith Settlement 17 Determination, the attached Declarations of Mary Childs and Derek H. Lim and exhibits thereto, the 18 concurrently filed [Proposed] Order, the concurrently filed Declaration of Proof of Service by 19 Certified Mail, and all other documents filed concurrently herewith. 20 21 Date: April 4, 2022 YOKA | SMITH, LLP 22 23 By _____________________________________ AARON S. CASE 24 MARY CHILDS 25 Attorneys for Defendants, EMMANUEL THOMAS, BOBBY KARKI, and JOHN DYLAN 26 LEITCH 27 28 3 DEFENDANTS EMMANUEL THOMAS, BOBBY KARKI, JOHN DYLAN LEITCH AND BRAD VISACKI’S NOTICE OF SETTLEMENT WITH PLAINTIFFS CRS.35148-Bele PROOF OF SERVICE CCP 1013 1 Daphne Beletsis, et al. v. Theta Chi Fraternity, et al. Santa Cruz County Case No. 19CV03287 2 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and 3 not a party to the within action; my business address is 445 South Figueroa Street, 38th Floor, Los Angeles, California 90071. 4 On April 4, 2022, I served true copies of the foregoing document described as DEFENDANTS 5 BOBBY KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS AND BRAD VISACKI’S NOTICE OF SETTLEMENT WITH PLAINTIFFS on the interested party or parties in this action as 6 follows: 7 ***SEE ATTACHED SERVICE LIST*** 8 9 [X] (BY CERTIFIED MAIL – RETURN RECEIPT REQUESTED) I am familiar with our firm’s practice of collection and processing correspondence for mailing. Under that practice it 10 would be deposited with the U.S. Postal Service on that same day in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if the 11 postal cancellation date or postage meter date is more than one working day after the date of deposit for mailing in this declaration. 12 [ ] (BY FACSIMILE) In addition to regular mail, I sent this document via facsimile, number(s) as 13 listed on the service list on April 4, 2022. 14 [X] (BY EMAIL) I sent a courtesy copy of this document to the email addresses as listed on the 15 service list on April 4, 2022. ONLY BY ELECTRONIC TRANSMISSION. Only by e-mailing the document(s) to the 16 persons at the email address(es) listed. This is necessitated during the declared National 17 Emergency due to the Coronavirus (COVID-19) pandemic, as this office is mostly working remotely, not able to send physical mail as usual, and is therefore using electronic mail. No 18 electronic message or other indication that the transmission was unsuccessful was received within a reasonable time after the transmission. 19 [ ] (BY OVERNIGHT DELIVERY) By placing a true copy thereof enclosed in a sealed FedEx 20 envelope, on April 4, 2022, with such fees prepaid, deposited in a FedEx depository at Los Angeles, CA in the ordinary course of business. 21 [ ] (BY PERSONAL SERVICE) Such envelope was delivered by an agent of Document Delivery 22 Service by hand to the office of the addressee. 23 [X] (STATE) I declare under penalty of perjury under the laws of the State of California that the 24 foregoing is true and correct. 25 Executed on April 4, 2022 at Los Angeles, California. 26 27 _________________________ An McNulty 28 1 CRS.35148-Bele Daphne Beletsis, et al. v. Theta Chi Fraternity, et al. Santa Cruz County Case No. 19CV03287 1 SERVICE LIST 2 3 Douglas E. Fierberg (admitted pro hac vice) Daniel R. Friedenthal; James Lee dfierberg@tfnlgroup.com Jay D. Brown 4 Jonathan N. Fazzola (admitted pro hac vice) ph. FRIEDENTHAL, HEFFERNAN & BROWN, LLP 5 231.933.0180 1520 W. Colorado Boulevard, Second Floor jfazzola@tfnlgroup.com Pasadena, California 91105 6 Lisa N. Cloutier (admitted pro hac vice) T: (626) 628-2800 F: (626) 628-2828 lcloutier@tfnlgroup.com dfriedenthal@FHBLawyers.com; 7 THE FIERBERG NATIONAL LAW GROUP, PLLC jlee@fhblawyers.com; jbrown@FHBLawyers.com 161 East Front Street, Suite 200 cc: nruiz@FHBLawyers.com 8 Traverse City, MI 49684 Attorneys for Specially Appearing Defendant, cc: kfarese@tfnlgroup.com THETA IOTA CHAPTER OF THETA CHI 9 (202) 351-0510 Fax: (231) 252-8100 FRATERNITY 10 Ivo Labar Patrick Ball labar@sawyerlabar.com 11 Idin Kashefipour SAWYER & LABAR LLP MESSNER REEVES, LLP 1700 Montgomery, Suite 108 12 650 Town Center Drive, Suite 700 San Francisco, CA 94111 Costa Mesa, CA 92626 13 (415) 262-3820 Tel: (949) 612-9128 Fax: (949) 438-2304 cc: guzman@sawyerlabar.com; pball@messner.com; ikashefipour@messner.com 14 marinkovich@sawyerlabar.com Attorneys for Defendant, MOISES TENORIO Attorneys for Plaintiffs, DAPHNE BELETSIS and GARCIA 15 YVONNE RAINEY 16 John D. Hourihan John R. Brydon STRATMAN, SCHWARTZ & WILLIAMS-ABREGO Derek H. Lim 17 P.O. Box 258829 Shannon Mallory Oklahoma City, OK 73125-8829 DEMLER ARMSTRONG & ROWLAND, LLP 18 (510) 457-3440 1990 N. California Blvd., Eighth Floor John.Hourihan@farmersinsurance.com Walnut Creek, CA 94596 19 Attorney for Defendant, QUINN McLAUGHLIN T: 415.949-1900 ▪ Cell 415.317.3693 20 lim@darlaw.com; bry@darlaw.com mal@darlaw.com 21 cc: Peri Clark cla@darlaw.com Attorney for Defendant, BRAD VISACKI 22 Michael C. Osborne Matthew C. Jaime 23 Jaskiran Samra Robert W. Sweetin Elaine Kobylecki MATHENY SEARS LINKERT & JAIME LLP 24 COKINOS | YOUNG 3638 American River Drive 611 Gateway Boulevard, Suite 233 Sacramento, CA 95864 25 (916) 978-3434 Fax: (916) 978-3430 South San Francisco, CA 94080 (628) 229-9280 mjaime@mathenysears.com 26 rsweetin@mathenysears.com mosborne@cokinoslaw.com; jsamra@cokinoslaw.com ekobylecki@cokinoslaw.com; cc:asanchez@cokinoslaw.com Attorney for Defendant, CHRIS GUEVARA 27 Attorney for Defendant, THETA CHI FRATERNITY, INC. 28 2