8/21/2020 Herbers vs.

Hamburger 19CWCS10310

On Tuesday, July 30, 2020, Lisa Kaucher of Alliant Insurance Services (AIS)
emailed Jonathan Epstein, AIS, notifying Epstein that Kris Hamburger (RP)
would be terminated the next day. The termination of employment was
noted as “involuntary” siting the reason “for poor performance” (EXHIBIT
A, pg 3).

Petitioner received email from RP, suggesting that Petitioner had caused
the termination of employment with RP’s employer, Alliant Insurance
Services, however, RP’s personnel le was subpoenaed and it is clear that
RP was, in fact, dismissed “involuntarily” for “poor performance” on the
job, as he had relapsed and begun using and drinking again in June
(EXHIBIT B, pg 1). Additionally, RP also received a severance check from
Alliant Insurance services in the amount of $50,000.00 on August 5, 2020
(EXHIBIT A, pg 38).

On August 7, 2019, Mr. Hamburger signed a contract of employment with

Mark Edward Partners, an insurance brokerage based in New York, thus
beginning his employment with the company (EXHIBIT C, pg 3). This is
a rmed, just recently, by a lawsuit led on behalf Mark Edward Partners
against Mr. Hamburger seeking damages in excess of $3,000,000 as a
result of RP violating a non-compete he agreed to, and signed, on August
17, 2020. Mr. Hamburger went to great lengths to avoid paying child
support, including claiming unemployment bene ts. Mr. Hamburger was
red from Mark Edward Partners April 1, 2020 (EXHIBIT C, pg 7) due to the
afore mentioned violation of the non-compete, then transitioned to his
current employer, another insurance brokerage, HUB (EXHIBIT C, pg 7).
RP is now actively employed by HUB Insurance, and advertises this on his
LinkedIn pro le (EXHIBIT E). Whether or not RP continues to claim that he
is unemployed in the state of California in order to collect unemployment
bene ts is currently unknown to petitioner. However, during the last
hearing on this case, RP was gainfully employed and still collecting
unemployment bene ts from EDD.

On October 14, 2020, Renee Ben Shmuel (the mother of RP’s eldest child,
Presley Hamburger, and his roommate) lled out RP’s FL-330 in response
to the county of Los Angeles opening a case against Mr. Hamburger in an
e ort to establish a child support order. 

Form is lled by hand, RP’s handwriting is evident. RP uses derogatory
language to describe petitioner, suggesting that petitioner is lying about
parentage, and claiming the Mr. Hamburger is currently “unemployed”,
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 8/21/2020 Herbers vs. Hamburger 19CWCS10310

which she knew to be untrue. RP details the “arrearages” she herself is

owed by Mr. Hamburger, and attempts to perpetuate the false narrative
that Petitioner had acted in a way which caused Mr. Hamburger to be
terminated from Alliant Insurance services on July, 5 2020 (EXHIBIT D, pg
5).

As a result of RP and Mr. Hamburger’s conspiracy to evade child support,

Petitioner su ered great nancial and legal issues. Renee Ben Shmuel’s
lling out forms, by hand, on October 14, 2020 is another e ort to
surreptitiously harass petitioner, paint petitioner in a bad light, and
evidence of Ms. Ben Shmuel’s malicious and unnecessary involvement in
private legal matters in which she not be involved.

Mr. Hamburger, with the help of Renee Ben Shmuel, has violated California
Penal Code 270 by hiding assets along with his active employment status,
and by doing so neglected and nancially abandoned Claudia Hamburger,
daughter of petitioner and RP. Ms. Ben Shmuel has aided and abetted RP
in his e orts to evade child support, a violation of California Code, Civil
Code - CIV § 1714.4, which states:

(a) Any person or business entity that knowingly assists a child

support obligor who has an unpaid child support obligation to
escape, evade, or avoid paying court-ordered or court-approved
child support shall be liable for three times the value of the
assistance provided, such as the fair market value of the obligor's
assets transferred or hidden.  The maximum liability imposed by this
section shall not exceed the entire child support obligation due.  Any
funds or assets collected pursuant to this section shall be paid to the
child support obligee, and shall not reduce the amount of the unpaid
child support obligation.  Upon the satisfaction of the unpaid child
support obligation, this section shall not apply.

Renee Ben Shmuel has also aided and abetted RP in defrauding the
Employment Development Department in her failure to notify the
department of Mr. Hamburger’s fraudulent claim to collect unemployment
bene ts, a violation of both Unemployment Insurance Code Section 2101,
and California Penal Code 550.

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8/21/2020 Herbers vs. Hamburger 19CWCS10310

It is evident that RP has been gainfully employed throughout 2019 and

2020, but refuses to acknowledge this in this case. His current rent is
nearly $6,000 per month at his apartment located at 10724 Wilshire Blvd,
#803, Los Angeles CA (EXHIBIT F).

In conclusion, petitioner requests that the court grants a child support

order for the original amount requested by the county of Los Angeles
(exact amount not available), based on RP’s presumed income last year,
and apply the originally requested support gure to arrearages backdating
to September 1, 2019. The superior court failed to apply equitable
estoppel in granting a child support order to petitioner in mid-2019, when
RP maliciously, and without reason, began claiming that Claudia
Hamburger was not his biological child, another e ort to evade paying
support. The DNA test provided by Los Angeles DCFS in late 2019
showed RP to be the biological father of Claudia Hamburger, a fact of
which RP was well aware of, but chose to abandon and nancially neglect
his own child as a means to harass and abuse petitioner.

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8/21/2020 Herbers vs. Hamburger 19CWCS10310

EXHIBIT A
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EXHIBIT B
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EXHIBIT C
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EXHIBIT D
8/21/2020 Herbers vs. Hamburger 19CWCS10310

EXHIBIT E
8/21/2020 Herbers vs. Hamburger 19CWCS10310

EXHIBIT F