Motion_to_be_relieved_as_counsel

Motion

Cal. Super. - 2nd Dist.March 29, 2019

Electronically FILED by Superior Court of California, County of Los Angeles on 07/01/2020 11:24 AM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk MC-051 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slste bar number, and address): FOR COURT USE ONLY Jennifer L. Sturges (SBN: 155703) Carley M. Ryckman (SBN: 314621) Carroll, Kelly, Trotter & Franzen P.O. Box 22636 Long Beach, CA 90801 TeLerHone NO: 562-432-5855 raxno: 562-432-8785 arrorney For ame). L€ Jolie Medi Spa, Parvaneh and Sharona Rafaeloff name oF court: Los Angeles Superior Court street aooress: 312 North Spring Street waunc aooress: 312 North Spring Street crvanoziecope: LOS Angeles, California 90012 sranch nave: opring Street Courthouse CASE NAME: CASE NUMBER: Dafoe v. Le Jolie Medi Spa, et al. 19STCV10809 HEARING DATE: 1 BD NOTICE OF MOTION AND MOTION oer: 29 wwe: TBD TO BE RELIEVED AS serore Hon: Kristin S. Escalante COUNSEL—CIVIL pateacrionrien: March 29, 2019 ria DATE: September 25, 2020 TO (name and address of client): Le Jolie Medi Spa, Parvaneh Rafaeloff, M.D., and Sharona Rafaeloff 13041 Ventura Boulevard, Los Angeles, CA 91604 1. PLEASE TAKE NOTICE that (name of withdrawing attorney). Jennifer L. Sturges moves under California Code of Civil Procedure section 284(2) and California Rules of Court, rule 3.1362, for an order permitting the attorney to be relieved as attorney of record in this action or proceeding. 2. A hearing on this motion to be relieved as counsel will be held as follows: a. Date: TBD Time: TBD Dept. 29 Room: b. The address of the court: same as noted above [| other (specify): 3. This motion is supported by the accompanying declaration, the papers and records filed in this action or proceeding, and the following additional documents or evidence (specify): (This motion does not need to be accompanied by a memorandum of points and authorities. Cal. Rules of Court, rule 3.1362.) 4. The client presently represented by the attorney is a. an individual. 9. [] atrustee. b. [V] a corporation. h. [_] a personal representative. c. [1 a partnership. i. [_] a probate fiduciary. d. [_] an unincorporated association. i. [] a guardian ad litem. e. [__] aguardian. k. [_] other (specify): f. [__] aconservator. (Continued on reverse) Page 10f 2 Far Coun of Gafomia. NOTICE OF MOTION AND MOTION Cal Res of Coun. nab 31362 MC-051 [Rev. January 1, 2007] TO BE RELIEVED AS COUNSEL—CIVIL www.courtinfo.ca.gov MC-051 CASE NAME: — Dafoe v. Le Jolie Medi Spa, et al. CASE NUMBER: 19STCV 10809 default judgment. If this motion to be relieved as counsel is granted, your present attorney will no longer be representing you. You may not in most cases represent yourself if you are one of the parties on the following list: * A guardian » A personal representative « A guardian ad litem + A conservator * A probate fiduciary + An unincorporated association *» A trustee + A corporation If you are one of these parties, YOU SHOULD IMMEDIATELY SEEK LEGAL ADVICE REGARDING LEGAL REPRESENTATION. Failure to retain an attorney may lead to an order striking the pleadings or to the entry of a NOTICE TO CLIENT 5. If this motion is granted and a client is representing himself or herself, the client will be solely responsible for the case. lose your case. NOTICE TO CLIENT WHO WILL BE UNREPRESENTED If this motion to be relieved as counsel is granted, you will not have an attorney representing you. You may wish to seek legal assistance. If you do not have a new attorney to represent you in this action or proceeding, and you are legally permitted to do so, you will be representing yourself. It will be your responsibility to comply with all court rules and applicable laws. If you fail to do so, or fail to appear at hearings, action may be taken against you. You may 6. If this motion is granted, the client must keep the court informed of the client's current address. losing the case. NOTICE TO CLIENT WHO WILL BE UNREPRESENTED If this motion to be relieved as counsel is granted, the court needs to know how to contact you. If you do not keep the court and other parties informed of your current address and telephone number, they will not be able to send you notices of actions that may affect you, including actions that may adversely affect your interests or result in your pate: 6/26/20 Jennifer Sturges (TYPE OR PRINT NAME) ) [7 OF ATTORNEY) Attorney for (name). MC-051 [Rev. January 1, 2007) NOTICE OF MOTION AND MOTION Page 20f2 TO BE RELIEVED AS COUNSEL—CIVIL AN nn BA W N 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action. My business address is Post Office Box 22636, Long Beach, CA 90801-5636. On July 1, 2020, I served a true and correct copy of the following document on the list of interested parties attached: “Notice of Motion and Motion to Be Relieved as Counsel - Civil” By United States Certified Mail, Return Receipt Requested (CCP §§1013a, ef seq.): 1 enclosed said document(s) in a sealed envelope or package to each addressee. I placed the envelope for collection and mailing, following our ordinary business practices. 1 am readily familiar with the firm’s practice 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 business with the United States Postal Service, with postage fully prepaid. (TO PARVANEH RAFAELOFF, M.D., SHARONA RAFAELOFF, and LE JOLIE MEDI SPA ONLY) Od By Overnight Delivery/Express Mail (CCP §§1013(c)(d), et seq.): I enclosed said document(s) in a sealed envelope or package provided by an overnight delivery carrier to each addressee. I placed the envelope or package, delivery fees paid for, for collection and overnight delivery at an office or at a regularly utilized drop box maintained by the express service carrier at 111 West Ocean Boulevard, Long Beach, California. 0 By Fax Transmission (CRC 2.306): Based on a written agreement of the parties to accept service by fax transmission, I faxed said document(s) to each addressee's fax number. The facsimile machine that I utilized, (562) 432-8785, complied with California Rules of Court, Rule 2.301(3), and no error was reported by the machine. Pursuant to Rule 2.306(h)(4), 1 caused the machine to print a record of the transmission, a copy of which is attached to the original of this proof of service. 0 By Messenger Service: I enclosed said document(s) in a sealed envelope or package to each addressee. I provided them to a professional messenger service (Signal Attorney Service) for service. An original proof of service by messenger will be filed pursuant to California Rules of Court, Rule 3.1300(c). Electronic Mail: Via e-mail to the address shown per the attached list. I declare under the penalty of perjury under the laws of the State of California and of the United States that the foregoing is true and correct. Executed on July 1, 2020, at Long Beach, California. Rose Battles Rosa Battles E:\52\5799-02\PLD\POS MTBR.Docx 1 PROOF OF SERVICE AN nn BA W N 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 Proof of Service Mailing List Re: Dafoe v Le Joli Med Spa, et al. Case No. 19STCV10809 Michael R. Rhames, Esq. MICHAEL R. RHAMES & ASSOCIATES, PC 600 Corporate Pointe, Suite 1170 Culver City, CA 90230 (310) 216-2500 (310) 216-7308 facsimile mrhames @mrrandassoc.com Attorney for Plaintiff James J. Kjar, Esq. Jon R. Schwalbach, Esq. KJAR, McKENNA & STOCKALPER LLP 841 Apollo Street, Suite 100 El Segundo, CA 90245 Tel. No.: (424) 217-3026 Fax. No.: (424) 367-0400 kjar@kmslegal.com ischwalbach@kmslegal.com Attorneys for Defendant INVASIX, INC. [Sued as Doe 52] VIA CERTIFIED MAIL/RETURN RECEIPT REQUESTED Parvaneh Rafaeloff, M.D. Sharona Rafaeloff Le Jolie Medi Spa 13041 Ventura Boulevard Los Angeles, CA 91604 E:\52\5799-02\PLD\POS MTBR.Docx 2 52-5799-02 52-5799-02 52-5799-02 PROOF OF SERVICE