Jeff Olave vs. Shadow Canyon Condominium association

Motion to Be Relieved as Counsel of Record

Cal. Super. - 4th Dist.January 15, 2016

MC-051 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slate bar number, and address): FOR COURT USE ONLY Michael A. Hellbusch (259315) Tredway, Lumsdaine & Doyle, LLP 2010 Main Street Irvine, CA 92614 TELEPHONE NO: 949-756-0684 FAX NO: 866-298-9254 ATTORNEY FOR (Name): Jeff Olave and Pilar Olave name oF court: Orange County Superior Court sTReeT apDRess; 700 Civic Center Drive West MAILING ADDRESS: cry anp zip cone: Santa Ana, CA 92701 srancH Name: Central Justice Center . Hr Tdi CASE NUMBER:case Name: Olave v. Shadow Canyon Condominium Association,et al. 30-2016.00830287 Reservation Number 72451302 HEARING DATE: 11/14/16 NOTICE OF MOTION AND MOTION peer: C26 ve: 10:30 a.m. TO BE RELIEVED AS serore Hon: Gregory H. Lewis COUNSEL—CIVIL DATE ATION FiLen: 1/15/16 TRIAL DATE: 2/16/17 TO (name and address of client). Jeff Olave and Pilar Olave, 260 Gallery Way, Tustin, CA 92782 1. PLEASE TAKE NOTICE that (name of withdrawing attorney): Tredway, Lumsdaine & Doyle, 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: November 14, 2016 Time; 10:30 a.m. Dept.: C26 Room: b. The address of the court: XI same as noted above [1 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 ofpoints and authorities. Cal. Rules of Court, rule 3.1362.) 4. The client presently represented by the attorney is a. x an individual. g. HN a trustee. b. J a corporation. h. ] a personal representative. c. J a partnership. i. [J a probate fiduciary. d. [] an unincorporated association. i. [J a guardian ad litem. e. [1] aguardian. k. [J other (specify): f. [] a conservator. (Continued on reverse) Page 1 of 2 ialCoundofCalfora NOTICE OF MOTION AND MOTION CalRulesofGoonrie31363 MC-051 [Rev. January 1, 2007] TO BE RELIEVED AS COUNSEL—CIVIL MW. 00urBl0:ce. 90% American LegaiNet, Inc www. FormsWorkflow.com MC-051 CASE NAME: CASE NUMBER: —Olave v. Shadow Canyon Condominium Association 30-2016-00830287 NOTICE TO CLIENT 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 default judgment. 5. If this motion is granted and a client is representing himself or herself, the client will be solely responsible for the 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 lose your case. 6. If this motion is granted, the client must keep the court informed of the client's current address. 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 losing the case. Date: September 23, 2016 c 72 / 7 \,// 7 / Michael A. Hellbusch ) AK (TYPE OR PRINT NAME) (SIGNATURE OF ATTORNEY) Attorney for (name): Jeff Olave and Pllar Olave Page 2 of 2MC-051 [Rev. January 1, 2007) NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL—CIVIL American LegalNet, Inc www. FormsWorkflow com TR ED WA Y, LU MS DA IN E & D O Y L E LL P 2 0 1 0 M a i n St re et , Su it e 1 0 0 0 Ir vi ne , Ca li fo rn ia 9 2 6 1 4 (9 49 ) 75 6- 06 84 L o 0 a d S N n n R A W O N e e B N N N N N N N N N e m e m e m e m E m e d p m e d p m 0 I A N n N E A W N = S C 0 N a N N l B R A W N E s PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF ORANGE At the time ofservice, | was over 18 years of age and not a party to this action. I am employed in the County of Orange. State of California. My business address is 2010 Main Street, Suite 1000, Irvine, CA 92614. On September 23, 2016, I served true copies of the following document(s) described as NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL on the interested parties in this action as follows: Jean M. Moriarty, Fsq. LAW OFFICE OF ANDREW W. MACRAE P.O. Box 258829 OklahomaCity, OK 73125-8829 Ph: (714) 541-4454 Fax (714) 558-0967 Jeff Olave Pilar Olave 260 Gallery Way Tustin. CA 92782 BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the persons at the addresses listed in the Service List and placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with Tredway, Lumsdaine & Doyle LLP's practice for collecting and processin correspondence for mailing. On the same day that the correspondence is placed for collection and mailing,it is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on September 23, 2016, at Irvine, California. anet L. Johnso