Andreas Lindenthal vs. Sterling Quinn

Motion to Be Relieved as Counsel of Record

Cal. Super. - 4th Dist.February 6, 2017

MC-051 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slate bar number, and address): Adam C. Fullman [SBN 194249] , Christopher J, Peters [SBN 259843] [| Sam Dehbozorgi [SBN 303033], Heidi Joya [SBN 311747] The Fullman Firm PC 11580 Trask Ave, Garden Grove CA 92843 TeLepHoNE NO: 888.622.2367 raxno. 714.534.0550 ATTORNEY FOR Name) Sterling Quinn name of court. Superior Court of Orange street aopress: 700 Civic Center Drive West maine aooress: 700 Civic Center Drive West cryanp zie cone: Santa Ana, Ca 92701 srancrinave. Central Justice Center FOR COURT USE ONLY ELECTRONICALLY FILED Superior Court of California, County of Orange 0613/2017 at 09:51:00 AM Clerk of the Superior Court By Brnma Castle, Deputy Clerk CASE NAME: Andreas Lindenthal vs. Sterling Quinn aka Sterling Quinn Cummings CASE NUMBER 30-2017-00901649 NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL—CIVIL nearing pate. September 18, 2017 pert: C-10 ve 10:00 a.m. gerore Hon. Linda Marks pate action Fieo: 02/06/2017 triapate: 02.13.2018 Pes. 1209018 TO (name and address of client): Sterling Quinn 25108 Marguerite Parkway #A-369, Mission Viejo, Ca 92692 1. PLEASE TAKE NOTICE that (name of withdrawing attorney): The Fullman Firm PC, Sam Dehbozorgi [SBN 303031] 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: 09/18/2017 Time: 10:00 a.m. Dept. C-10 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): Declaration of Sam Dehbozorgi, Esq. (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. g. [_] atrustee. b. [__] a corporation. h. [_] a personal representative. c. [_] a partnership. i. [_] a probate fiduciary. d. [_] an unincorporated association. j. [_] a guardian ad litem. e. [_] aguardian. k. [_] other (specify): f. [_] a conservator. (Continued on reverse) Page 1 of 2 Form Adopted for Mandatory Use NOTICE OF MOTION AND MOTION Code of Civil Procedure , § 284; Judicial Council of California MC-051 [Rev. January 1, 2007] TO BE RELIEVED AS COUNSEL—CIVIL Cal. Rules of Court, rule 3.1362 www.courtinfo.ca.gov MC-051 CASE NAME: L— Andreas Lindenthal vs. Sterling Quinn aka Sterling Quinn Cummings CASE NUMBER: 30-2017-00901649 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. 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. ql 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: [June 12, 2017 71 The Fullman Firm, P.C. Sam Dehbozorgi, Esq. b (TYPE OR PRINT NAME) pu— - {SIGNATURE OF ATTO N Y] Attorney for (name): CHRO I. AIRY 1.2907 NOTICE OF MOTION AND MOTION Page 2 of 2 TO BE RELIEVED AS COUNSEL—CIVIL ro |U 8) PROOF OF SERVICE BY MAIL (2015.5, 1013 (a) C.C.P.) STATE OF CALIFORNIA ) ) ss. COUNTY OF ORANGE ) [am employed in the county aforesaid; I am over the age of eighteen (18) years and not a party to the within-entitled action; my business addresses 11580 Trask Avenue, Garden Grove, California 92843. On June 13, 2017, I served on the interested party in said action a document entitled NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL--CIVIL, by placing a true copy thereof in a sealed envelope addressed as follows: SEE SERVICE LIST (BY MAIL) Iam readily familiar with the firm's practice of collecting and processing document(s) and correspondence for mailing with United States Postal Service. Under that practice, on the above date the envelope was sealed and placed for collection and mailing following the ordinary /business practices of our office. This results in the envelope(s) being delivered to the United States Postal Service that same day, with postage thereon fully prepaid. (BY PERSONAL SERVICE) I delivered the envelope addressed as described above to addressee or the addressee’s agent at the above described address. [ certify (or declare), under penalty of perjury under the laws of the State of California, that the above is true and correct and executed at Garden Grove, California. Executed on June 13, 2017, at Garden Grove, California. Candice Barcfa | ) PROOF OF SERVICE OO © NN A nn bs e W N 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Sterling Quinn 25108 Marguerite Pkwy #A-369 Mission Viejo, Ca 92692 Andreas Lindenthal 27452 Avanti Drive Mission Viejo, Ca 92692 Andreas Lindenthal P.O. Box 2807 San Juan Capistrano, Ca 92690 SERVICE LIST PROOF OF SERVICE