Motion to be Relieved as CounselCal. Super. - 6th Dist.December 7, 2020200V37391 6 Santa Clara - Civil MC-051 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slate bar number, and address): FOR COURT USE ONLY Justin Penn (SBN 302350); Shalini Bhasker (SBN 326729)_ HINSHAW & CULBERTSON LLP . . 350 S. Grand Ave., Suite 3600 legtronlfiallé Flled f CALos Angeles, CA 90071 "Perm 0"” ° ’ TELEPHONE No.2 213-680-2800 FAXNO; 213-614-7399 ounty 0f Santa Clara, ATTORNEY FOR (Name): Velocity Investments LLC, Velocity Portfolio Group Inc n 3/26/2021 11 :02 AM NAME OFCOURT: Superior Court 0f California, County of Santa Clara .eviewed By: R. Walker STREETADDRESS: 191 N. lst St. ase #20CV37391 6 MAILING ADDRESS: nvelo e: 61 1 8655 CITY AND ZIP CODE: san JOSC 951 13 p BRANCH NAME; Downtown San Jose mom CASE NAME: CASE NUMBER: David Chai V. Velocity Investments, LLC, et a1. 20CV373916 HEARING DATE: NOTICE OF MOTION AND MOTION DEPT‘ “ME: TO BE RELIEVED AS BEFORE HON; COUNSEL-CIVIL DATE ACTION FILED: TRIAL DATE: TO (name and address of client): Velocity Investments, LLC and Velocity Portfolio Group, Inc. 1800 NJ-34 #404a, Wall Township, NJ O77 19 1. PLEASE TAKE NOTICE that (name of withdrawing attorney): Hinshaw & Culbertson LLP 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: May 26, 2021 Time: 1.30 p..m Dept: 3 Room: b. The address of the court: same as noted above E 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): Declaration of Shalini Bhasker (This motion does not need to be accompanied by a memorandum ofpoints and authorities. Cal. Rules of Court, rule 3. 1362.) 4. The client presently represented by the attorney is a. E anindividual. g. E atrustee. b. E a corporation. h. E a personal representative. c. E a partnership. i. E a probate fiduciary. d. E an unincorporated association. j. E a guardian ad litem. e. E aguardian. k. other(specify): f" E a conservator" an LLC and a corproation (Continued on reverse) page 1 ofz Form Adopted for Mandatory Use NOTICE OF MOTION AND MOTION Code of Civil Procedure , § 284; Judicial Council of California Cal. Rules of Court, rule 3.1362 M0051 [Rev.January1,2oo71 TO BE RELIEVED AS COUNSEL-CIVIL www.courtmrocagov MC-051 CASE NAME: - David Chai V. Velocity Investments, LLC, et a1. CASE NUMBER: 20CV373916 NOTICE TO CLIENT 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 5. Ifthis 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. Ifthis motion is granted, the client must keep the court informed ofthe 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 Date: March 23, 2021 Shalini Bhasker ’SW5W (TYPE OR PRINT NAME) (SIGNATURE OF ATTORNEY) Attorney for (name): Velocity Investments, LLC MC-051 [ReV-January 1, 20071 NOTICE OF MOTION AND MOTION Page 2 of 2 TO BE RELIEVED AS COUNSEL-CIVIL 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE David Chai, et al. v. Velocity Investments, LLC, et al. Case N0. 20CV373916 (STATE OF CALIFORNIA, COUNTY OF LOS ANGELES) I am employed in the County 0f Los Angeles, State 0f California. I am over the age 0f 18 and not a party t0 the Within actions; my business address is 350 South Grand Ave., Suite 3600, Los Angeles, CA 90071-3476. On March 26, 2021, I served the document(s) entitled: 1) NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL; 2) DECLARATION IN SUPPORT OF ATTORNEY’S MOTION TO BE RELIEVED AS COUNSEL; 3) ORDER GRANTING ATTORNEY’S MOTION TO BE RELIEVED AS COUNSEL 0n the interested parties in this action by placing true copies thereof enclosed in a sealed envelope(s) addressed as stated below: SEE ATTACHED SERVICE LIST M (BY MAIL): I placed the envelope for collection and mailing at Los Angeles, California. The envelope was mailed with postage fully prepaid. I am readily familiar With this firm’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited With the U.S. postal service on that same day With postage thereon fillly prepaid at Los Angeles, California, in the ordinary course of business. I am aware that 0n motion 0f party served, service is presumed invalid if postal cancellation date 0r postage meter date is more than 1 day after date of deposit for mailing in affidavit. D (BY FACSIMILE TRANSMISSION): I caused a true copy thereof from sending facsimile machine telephone number 213-614-7399 t0 be sent Via facsimile to the above listed names and facsimile numbers and received confirmed transmission reports indicating that this document was successfully transmitted to the parties named above. D (VIA OVERNIGHT MAIL): I am "readily familiar" with the firm's practice of collection and processing correspondence for overnight delivery. Under that practice it would be deposited in a box 0r other facility regularly maintained by the express service carrier, or delivered t0 an authorized courier or driver authorized by the express service carrier to receive documents, in an envelope 0r package designated by the express service carrier With delivery fees paid or provided for, addressed t0 the person 0n Whom it is to be served, at the office address as last given by that person on any document filed in the cause and served 0n the party making service; otherwise at that party's place 0f residence. D (BY E-MAIL OR ELECTRONIC TRANSMISSION): Based on a court order or an agreement 0f the parties t0 accept service by e-mail 0r electronic transmission, I caused the document(s) t0 be sent t0 the person[s] at the e-mail address[es] set forth herein. I did not receive, A4304\30781 1795.V1 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. See Cal.R.Ct.R. 2060 D (BY HAND DELIVERY): I caused to be delivered by hand each sealed envelope to the addressee(s) mentioned in the attached service/mailing list. D (BY PERSONAL SERVICE): I caused such envelope to be delivered t0 a commercial messenger service with instructions to personally deliver same t0 the offices of the addressee as shown 0n the attached mailing list 0n this date. I declare under penalty of perjury under the laws 0f the State 0f California that the foregoing is true and correct. Executed on March 26, 2021, at Los Angeles, California. mama” Gloria Valles A4304\30781 1795.V1 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SERVICE LIST David Chai, et al. v. Velocity Investments, LLC, et al. Case N0. 20CV373916 Fred W. Schwinn, Esq. Consumer Law Center, Inc. 1435 K011 Circle, Suite 104 San Jose, CA 951 12-4610 Tel: (408) 294-6100 Fax: (408) 294-6190 Email: fred.schwinn@siconsumedrlaw.com Attorneysfor Plaintifl David Chai A4304\30781 1795.V1