Thomas Quang Vo vs. Jay Van Laanen

Motion to Be Relieved as Counsel of Record

Cal. Super. - 4th Dist.September 5, 2017

MC-051 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slate bar number, and address). Michael R. Cully, Esq. SBN 93718 Law Offices of Michael R. Cully & Associates, APC 18351 Beach Blvd., Suite E Huntington Beach, CA 92648 eepHone no. (714) 596-1111 raxno: (714) 596-1136 arTorney For ame: Plaintiff THOMAS QUANG VO al if on ia , ~ “ name oF court: Superior Court of the State of California streeTappress: 7/00 Civic Center Drive West MAILING ADDRESS: (SaIme) cirvanp zip coe: Santa Ana, CA 92701 ranch nave: CENTRAL JUSTICE CENTER ou nt y of Or an ge 09 /1 4/ 20 17 at 12 :4 7: 00 PM - “ E L E C T R O N I C A L L Y FI LE D Su pe ri or Co ur t of ( FOR COURT USE ONLY le rk of th e Su pe ri or Co ur t By Da ni el le Ju ra do , De pu ty Cl er k ~ CASE NAME: THOMAS QUANG VO v. JAY VAN LAANEN, et al. CASE NUMBER: 30-2017-00941636-CU-PA-CJC NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL—CIVIL DEPT. C21 TRIALDATE: NONE nearing pate: October 20, 2017 serore Hon: Deborah Servino paTE AcTioN FILED: 9/5/2017 me 10:00 a.m. TO (name and address of client): THOMAS QUANG VO, 2213 W. Adams St., Santa Ana, CA 92704, & 476 Duranzo Aisle, Irvine, CA 92606 1. PLEASE TAKE NOTICE that (name of withdrawing attomey): Michael R. Cully, Esq. 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. . A hearing on this motion to be relieved as counsel will be held as follows: a. Date: October 20, 2017 Time: 10:00 a.m. Dept: C21 Room: b. The address of the court: same as noted above [| other (specify): . 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): See attached report of Rick Topping, P.1., dated September 12, 2017 (Note: SS# has been redacted). On September 14, 2017, I called telephone number (949) 362-9725. A male individual answered, who I believe to be Thomas Quang Vo, although he would not so acknowledge. I told him of the time, place and nature of this motion. (This motion does not need to be accompanied by a memorandum of points and authorities. Cal. Rules of Court, rule 3.1362.) . The client presently represented by the attorney is 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. [__] aguardian. k. [_] other (specify): f. [__] a conservator. (Continued on reverse) Page 1 of 2 Fo i ey NOTICE OF MOTION AND MOTION CoC 3 MC-051 [Rev. January 1, 2007] TO BE RELIEVED AS COUNSEL—CIVIL www.courtinfo.ca. gov MC-051 CASE NAME: CASE NUMBER: — THOMAS QUANG VO v. JAY VAN LAANEN, et al. 30-2017-00941636-CU-PA-CIC 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 14, 2017 ~ Michael R. Cully, Esq. SBN 93718 VE e —s — (TYPE OR PRINT NAME) - re OF ATTORNEY) Attorney for (ndme): THOMAS QUANG VO MC-051 [Rev. January 1, 2007] NOTICE OF MOTION AND MOTION Page 20of 2 TO BE RELIEVED AS COUNSEL—CIVIL RICK TOPPING INVESTIGATIONS P.O. BOX 773 Lake Forest, CA 92609 Tel. (949) 837-9946 Fax. (949) 837-9885 www.top-pi.com SLN PI 6336 September 12, 2017 Michael R. Cully, Esq. Michael R. Cully & Associates 18531 Beach Blvd., Suite E Huntington Beach, CA 92649 RE : Thomas Quang Vo Our File No. : 2017-02-01 Dear Mr. Cully: As requested, our office conducted an investigation regarding the above referenced client. We conducted searches to determine a current address for: Thomas Quang Vo a.k.a. Trung Q. Vo Tom Quang Vo DOB 4/30/1968 SSN RR The last address your office had is: 8962 Swordfish Ave. Fountain Valley, CA The address is listed between 2/28/13 to 7/2013 We found two more current addresses reported. 2213 W. Adams St. Santa Ana, CA 92704 (1/98-1/17) 476 Duranzo Aisle Irvine, CA 92606 (1/87-1/17) The Irvine address looks like an older family address. P.2 RE : Thomas Quang Vo Our File No. : 2017-02-01 We found a possible telephone number (949) 362-9725 We searched high and low and didn’t find a newer or positive residence. Should you have questions or further requests please feel free to contact our office at any time. Very truly yours, Rick Topping Investigations Rick Topping Rick Topping, PI E o oN OO 0 3 O Y Wn 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE BY MAIL (C.C.P. Section 1013) STATE OF CALIFORNIA) COUNTY OF ORANGE J > I am over the age of 18, and not a party to the within action. My address is 18351 Beach Boulevard, Suite E, Huntington Beach, CA 92648. On September 14, 2017, I served the attached NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEIL-CIVIL by mail to: THOMAS QUANG VO 2213 W. Adams St. Santa Ana, CA 92704 THOMAS QUANG VO 476 Duranzo Aisle Irvine, CA 92606 Via e-mail: tundravo@gmail.com On September 14, 2017, being readily familiar with this firm’s practice for collection and processing of correspondence for mailing with the United States Postal Service and that the correspondence would be deposited with the United States Postal Service that same day in the ordinary course of business, I placed the attached documents in envelope(s) with first class postage thereon, at the addresses set forth above, and that said envelope(s) were sealed and placed for collection and mailing on that date following ordinary business practices of this firm. I declare that I am a competent adult, over the age of 18 years, and not a party to this action and I further declare under the penalty of perjury of the laws of the State of California, that the above is true and correct. Executed this 14th day of September, 2017, at Huntington Beach, California.