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ELECTRONICALLY RECEIVED
4/4/2022 5:30 PM
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, ) [PROPOSED] ORDER GRANTING
) APPLICATION FOR GOOD FAITH
14 Plaintiffs, ) SETTLEMENT DETERMINATION
vs. ) FILED BY DEFENDANTS BOBBY
15 ) KARKI, JOHN DYLAN LEITCH,
THETA CHI FRATERNITY, INC., a New York ) EMMANUEL THOMAS AND BRAD
16
corporation, individually, as a member of and t/a ) VISACKI
17 the Theta Iota Chapter, University of California, )
Santa Cruz, as a member of the fraternal order )
18 known as Theta Chi Fraternity, and as an alter-ego)
and successor entity of the Theta Iota Chapter of ) Action Filed: October 31, 2019
19
Theta Chi Fraternity; THETA IOTA CHAPTER )
20 OF THETA CHI FRATERNITY, individually, ) First Amended Complaint
and as an agent and alter-ego of Theta Chi ) Filed: February 5, 2020
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
[PROPOSED] ORDER GRANTING APPLICATION FOR GOOD FAITH SETTLEMENT DETERMINATION FILED BY
DEFENDANTS BOBBY KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS AND BRAD VISACKI
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 The Application for Determination of Good Faith Settlement of Defendants, BOBBY
24 KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS and BRAD VISACKI, relating to their
25 settlement with Plaintiffs, DAPHNE BELETSIS, individually and as administrator of the ESTATE OF
26 ALEXANDER BELETSIS, and YVONNE RAINEY, was filed and served in conformance with
27 California Code of Civil Procedure section 877.6(a)(2). The Court having received no opposition
28 within the time period set forth in said Code section, and good cause appearing therefor,
2
[PROPOSED] ORDER GRANTING APPLICATION FOR GOOD FAITH SETTLEMENT DETERMINATION FILED BY
DEFENDANTS BOBBY KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS AND BRAD VISACKI
1 IT IS HEREBY ORDERED, ADJUDGED and DECREED that the Application for
2 Determination of Good Faith Settlement of Defendants, BOBBY KARKI, JOHN DYLAN LEITCH,
3 EMMANUEL THOMAS, and BRAD VISACKI, is granted and that their settlement with Plaintiffs,
4 DAPHNE BELETSIS individually and as administrator of the ESTATE OF ALEXANDER
5 BELETSIS and YVONNE RAINEY, is found to be in good faith within the meaning of California
6 Code of Civil Procedure Sections 866 and 877.6.
7 IT IS FURTHER ORDERED, ADJUDGED, and DECREED that any such Cross-
8 Complaints against Defendants BOBBY KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS,
9 and BRAD VISACKI for equitable comparative contribution, or partial or comparative indemnity,
10 based on comparative negligence or comparative fault, are hereby dismissed with prejudice.
11
12
Dated: ___________________________________
13 HONORABLE PAUL MARIGONDA
JUDGE OF THE SUPERIOR COURT
14
15
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18
19
20
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22
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27
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3
[PROPOSED] ORDER GRANTING APPLICATION FOR GOOD FAITH SETTLEMENT DETERMINATION FILED BY
DEFENDANTS BOBBY KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS AND BRAD VISACKI
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 [PROPOSED]
5 ORDER GRANTING APPLICATION FOR GOOD FAITH SETTLEMENT DETERMINATION
FILED BY DEFENDANTS BOBBY KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS
6
AND BRAD VISACKI on the interested party or parties in this action as 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
ELECTRONICALLY RECEIVED 4/4/2022 5:30 PM 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, ) [PROPOSED] ORDER GRANTING ) APPLICATION FOR GOOD FAITH 14 Plaintiffs, ) SETTLEMENT DETERMINATION vs. ) FILED BY DEFENDANTS BOBBY 15 ) KARKI, JOHN DYLAN LEITCH, THETA CHI FRATERNITY, INC., a New York ) EMMANUEL THOMAS AND BRAD 16 corporation, individually, as a member of and t/a ) VISACKI 17 the Theta Iota Chapter, University of California, ) Santa Cruz, as a member of the fraternal order ) 18 known as Theta Chi Fraternity, and as an alter-ego) and successor entity of the Theta Iota Chapter of ) Action Filed: October 31, 2019 19 Theta Chi Fraternity; THETA IOTA CHAPTER ) 20 OF THETA CHI FRATERNITY, individually, ) First Amended Complaint and as an agent and alter-ego of Theta Chi ) Filed: February 5, 2020 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 [PROPOSED] ORDER GRANTING APPLICATION FOR GOOD FAITH SETTLEMENT DETERMINATION FILED BY DEFENDANTS BOBBY KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS AND BRAD VISACKI 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 The Application for Determination of Good Faith Settlement of Defendants, BOBBY 24 KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS and BRAD VISACKI, relating to their 25 settlement with Plaintiffs, DAPHNE BELETSIS, individually and as administrator of the ESTATE OF 26 ALEXANDER BELETSIS, and YVONNE RAINEY, was filed and served in conformance with 27 California Code of Civil Procedure section 877.6(a)(2). The Court having received no opposition 28 within the time period set forth in said Code section, and good cause appearing therefor, 2 [PROPOSED] ORDER GRANTING APPLICATION FOR GOOD FAITH SETTLEMENT DETERMINATION FILED BY DEFENDANTS BOBBY KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS AND BRAD VISACKI 1 IT IS HEREBY ORDERED, ADJUDGED and DECREED that the Application for 2 Determination of Good Faith Settlement of Defendants, BOBBY KARKI, JOHN DYLAN LEITCH, 3 EMMANUEL THOMAS, and BRAD VISACKI, is granted and that their settlement with Plaintiffs, 4 DAPHNE BELETSIS individually and as administrator of the ESTATE OF ALEXANDER 5 BELETSIS and YVONNE RAINEY, is found to be in good faith within the meaning of California 6 Code of Civil Procedure Sections 866 and 877.6. 7 IT IS FURTHER ORDERED, ADJUDGED, and DECREED that any such Cross- 8 Complaints against Defendants BOBBY KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS, 9 and BRAD VISACKI for equitable comparative contribution, or partial or comparative indemnity, 10 based on comparative negligence or comparative fault, are hereby dismissed with prejudice. 11 12 Dated: ___________________________________ 13 HONORABLE PAUL MARIGONDA JUDGE OF THE SUPERIOR COURT 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 [PROPOSED] ORDER GRANTING APPLICATION FOR GOOD FAITH SETTLEMENT DETERMINATION FILED BY DEFENDANTS BOBBY KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS AND BRAD VISACKI 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 [PROPOSED] 5 ORDER GRANTING APPLICATION FOR GOOD FAITH SETTLEMENT DETERMINATION FILED BY DEFENDANTS BOBBY KARKI, JOHN DYLAN LEITCH, EMMANUEL THOMAS 6 AND BRAD VISACKI on the interested party or parties in this action as 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