Elie Abinader vs. Naji Doumit

Motion to Be Relieved as Counsel of Record

Cal. Super. - 4th Dist.August 11, 2017

MC-051 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slate bar number, and address): FOR COURT USE ONLY Kamal A. Bilal, Esq. SBN214892 Bilal Law Group crvannzrcooe Santa Ana, CA 92701 701 North Brand Boulevard #840 ELECTRONICALLY FILED Glendale, CA 91203 Superior Court of California, teLerHoneno: 818/553-1616 raxno 818/221-0543 County of Orange attorney For vamoy Plaintiff Elie Abinader 03/27/2018 name of court SUPERIOR COURT - UNLIMITED CIVIL Clerk of the Superior Court seevaooress 700 Civic Center Drive West By Jeannette Torres, Deputy Clerk MAILING ADDRESS. srancinave. Central Justice Center CASE NAME: CASE NUMBER Elie Abinader v. Naji Doumit, et al. 30-2017-00937211-CU-BC-CIC HEARING DATE May 3,2018 NOTICE OF MOTION AND MOTION cert C33 me 1:30 PM TO BE RELIEVED AS serore von James Crandall OUNSEL—CIVIL _ pate action Fien: Bf nt f1 7 cer vah's nF 12781 SS wriacoate July 2, 2018 TO (name and address of client): Elie Abinader 1. PLEASE TAKE NOTICE that (name of withdrawing attomey): Kamal A. Bilal/Bilal Law Group moves under California Code of Civil Procedure section 284(2) and California Rules of Cour, 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 3, 2018 Time: 1:30 PM Dept.: C33 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. 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. [_] aconservator. (Continued on reverse) Page 1 of 2 Fem Adggied for fsndainy. Jee NOTICE OF MOTION AND MOTION Cephued Mpe kel MC.051 [Rev January 1. 2007) TO BE RELIEVED AS COUNSEL—CIVIL won courino ca gov MC-051 CASE NAME: CASE NUMBER: — Elie Abinader v. Naji Doumit, et al. 30-2017-00937211-CU-BC-CIJC 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. pate: March 27, 2018 Kamal A. Bilal, Esq. ) rr (TYPE OR PRINT NAME) 7 OF ATTORNEY) Attorney for (name): Elie Lire Plaintiff Pago 20f 2 MC-051 Rev. January 1. 2007} NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL—CIVIL PROOF OF SERVICE STATE OF CALIFORNIA ) ) ss. COUNTY OF LOS ANGELES ) I am a resident of the aforesaid county; I am over the age of eighteen years and not a party to the within active-entitled action; my business address is 701 North Brand Boulevard #840 Glendale, CA 91203. On March 27, 2018, | served NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL—CIVIL on the interested parties in said action by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, in the United States Mail at Los Angeles, California, addressed as follows: The Bailey Legal Group Tel 951/304-7566 25014 Las Brisas South, Suite B Fax 951/304-7571 Murietta, CA 92562 ATTN THERESE BAILEY, ESQ. Elie Abinader 340 South Lemon Avenue, Unit 3314 Walnut, CA 91789 /X /U.S. MAIL // FAX // PERSONAL I caused such envelope(s) to be deposited in the mail at Los Angeles, California. The envelope was mailed with postage thereon fully prepaid. I am readily familiar with this firm's practice of collection and processing correspondence for mailing. It is deposited with the U.S. postal service on that same day in the ordinary course of business. I am aware that on motion of party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. I certify (or declare) under penalty of perjury that the foregoing is true and correct. EXECUTED ON MARCH 27, 2018, AT GLENDALE, CALIFORNIA. Hig ilon J ik CHARLEEN H. BUNDA