ashley Crader vs. Metal Art of California, Inc.

Motion to Be Relieved as Counsel of Record

Cal. Super. - 4th Dist.July 21, 2016

MC-051 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slate bar number, and address}: FOR COURT USEONLY Samuel A. Wong (SBN 217104) Ali S. Carlsen (SBN 289964) - AEGIS LAW FIRM, PC 9811 Irvine Center Drive, Suite 100 Irvine, CA 92618 TeLepHONE NO: 949-379-6250 Faxno: 949-379-6251 ATTORNEY FOR name): Plaintiff Ashley Crader nameor court: Orange County Superior Court streetappress: 700 Civic Center Drive West MAILING ADDRESS: cTyanpzpcope; Santa Ana 9270 1 sranchame: Central Justice Center CASE NAME: CASE NUMBER: Ashley Crader v. Metal Arts of California, Inc. 30-2016-00864867 Hearing Date: March 28, 2017 NOTICE OF MOTION AND MOTION peer: C19 ve: 1:30 PM TO BE RELIEVED AS eeFore Hon: Walter Schwarm COUNSEL-CIVIL pate acionrien: July 21, 2016 TRIAL DATE: July 7,2016 TO (name and address ofclient). Ashley Crader, 1631 W Pampas Ln, Apt 2, Anaheim, CA 92802 1. PLEASE TAKE NOTICE that (name of withdrawing attorney). Aegis Law Firm, PC moves under California Code of Civil Procedure section 284(2) and California Rules of Court, rule 3.1362, for an order permitting the attorney fo 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: March 28, 2017 Time: 1:30 PM i Dept. C19 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 ofpoints and authorities. Cal. Rules of Court, rule 3.1362.) 4. The client presently represented by the attorneyis a. an individual. g. [1] atrustee. b. [_] a corporation. h. [__] a personal representative. c. [_] a partnership. i. [| a probate fiduciary. d. [__] an unincorporated association. i. [_] a guardian ad litem. e. [_] a guardian. k. [_] other (specify): f. [1 a conservator. {Continued on reverse) Page 1 of 2 Form Adopted for Mandatory Use NOTICE OF MOTION AND MOTION CetcanFracadure,$= Judicial Councit of California MC-051 [Rev. January 1, 2007] TO BE RELIEVED AS COUNSEL-CIVIL wuw.courtinfo.ca.gov MC-051 CASE NAME: CASE NUMBER: - Ashley Crader v. Metal Arts of California, Inc. 30-2016-00864867 NOTICE TO CLIENT If this motion to be relieved as counselis 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 frustee « 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 counselis 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: February 13, 2017 © Cc Ali S. Carlsen {TYPE OR PRINT NAME) (SIGNATURE OF ATTORNEY) Attomey for (name): Plaintiff Ashley Crader MC-051 [Rev. January 1, 2007] NOTICE OF MOTION AND MOTION Page 2 of 2 TO BE RELIEVED AS COUNSEL-CIVIL N o 0 N N B R W N R N D N N N N N N N M m k e e a e m e d e m p e e m e m e a ° ° 3 a N n n B R A W N = O O N S N R W OR , O o CERTIFICATE OF SERVICE I, the undersigned, am employed in the County of Orange, State of California. I am over the age of 18 and not a party to the within action; am employed with Aegis Law Firm PC and my business address is 9811 Irvine Center Drive, Suite 100, Irvine, California 92618. On February 13, 2017, I served the foregoing documententitled: * NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL -~ CIVIL on all the appearing and/or interested parties in this action by placing {| the original [X] a true copy thereof enclosed in sealed envelope(s) addressed as follows: Alison L. Lynch Ms. Ashley Crader Jeffrey B. Weston 1631 W Pampas Ln, Apt 2 JACKSON LEWIS P.C. Anaheim, CA 92802 200 Spectrum Center Drive, Suite 500 Irvine, CA 92618 Plaintiff Attorneysfor Defendant: Metal Art of California, Inc. x (BY MAIL) I am readily familiar with the 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 fully prepaid at Irvine, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postage cancellation date or postage meter date is more than one day after date of deposit for mailing this affidavit. (Cal Code Civ. Proc. § 1013(a); Fed. R. Civ. Proc. 5(a); Fed. R. Civ. Proc. 5(c).) [RETURN RECEIPT REQUESTED FOR ASHLEY CRADER ONLY] ] (BY OVERNIGHT MAIL) [ am personally and readily familiar with the business practice of Aegis Law Firm PC for collection and processing correspondence for overnight delivery, and I caused such document(s) described herein to be deposited for delivery to a facility regularly maintained Federal Express for overnight delivery. (Cal Code Civ. Proc. § 1013(c); Fed. R. Civ. Proc. 5(c).) [] (BY ELECTRONIC TRANSMISSION) I caused said document(s) to be served via electronic transmission to the addressee(s) listed above on the date below. (Cal. Code Civ. Proc. § 1010.6(6); Fed. R. Civ. Proc. 5(b)(2)(E); Fed. R. Civ. Proc. 5(b)(3).) ] (BY PERSONAL SERVICE) 1 delivered the foregoing document by hand delivery to the addressed named above. (Cal Code Civ. Proc. § 1011; Fed R. Civ. Proc. S(b)(2XA).) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on February 13, 2017, at Irvine, California. Kathyan Alvarez CERTIFICATE OF SERVICE