What is a Notice of Limited Scope Representation?

“With the exception of a court appointment, the relationship of lawyer and client is created by contract.” (Houston Gen Ins Co v. Superior Court (1980) 108 Cal.App.3d 958, 964.) An attorney and a person seeking legal services may agree “that the scope of the legal services will be limited to specific tasks that the attorney will perform for the person.” (Cal. Rules of Ct., Rule 5.425; Sullivan v. Dunne (1926) 198 Cal. 183, 190.)

Legal Standard

According to the California Rules of Court, there are two types of limited scope representation:

  1. Noticed representation occurs when an attorney and a party notify the court and other parties of the limited scope representation.
  2. Undisclosed representation occurs when a party contracts with an attorney to draft or assist in drafting legal documents, but the attorney does not make an appearance in the case.

(Cal. Rules of Ct., Rule 5.425(c).)

Procedure

An attorney can elect to notify the Court and other parties of a limited scope representation. (Cal. Rule of Ct., Rule 3.35.) A party and an attorney may provide notice of their agreement to limited scope representation by serving and filing a Notice of Limited Scope Representation (form MC-950). (Cal. Rule of Ct., Rule 3.36(a).) If such a notice is filed and served, then the papers in the case must be served on both the attorney providing the limited scope representation and the client. (Cal. Rule of Ct., Rule 3.36(b).)

Useful Rulings on Notice of Limited Scope Representation

Recent Rulings on Notice of Limited Scope Representation

BRECKENRIDGE PROPERTY FUND 2016 V. ROBINSON

The Court notes that, on October 29, 2020, James Imperiale appeared for the defendant, apparently pursuant to the Notice of Limited Scope Representation filed March 17, 2020. However, on 9-14-20, the defendant filed a substitution of attorney, by which Patricia Rodriguez assumed the representation of the defendant. If Mr. Imperiale again appears, he shall be prepared to explain the nature and source of his authority to appear on behalf of the defendant.

  • Hearing

THE TRAVELERS INDEMNITY COMPANY VS RICARDO LARA

Despite the limited scope of a section 11737(f) proceeding, Adir sought to challenge the overall legality of the Side Agreement rather than the premium charged to it by Travelers.

  • Hearing

  • Type

    Administrative

  • Sub Type

    Writ

JAMES BRITT VS. NICOLE TILLMAN, ET AL.

Limited scope representation This motion was filed by Attorney Christopher Todd, on behalf of plaintiff. Attorney Todd filed a limited scope representation form (CIV-150) on May 20, 2020. The filing states he would represent plaintiff at the August 11, 2020 hearing, in propounding discovery, and in alternative dispute resolution initiated by the parties. The limited scope representation does not extend to motion practice.

  • Hearing

  • Type

    Real Property

  • Sub Type

    Quiet Title

  • Judge

    Maurice A. Leiter or Salvatore Sirna

  • County

    Los Angeles County, CA

LARRY NEUBERG VS FCA US, LLC, ET AL.

Given the statements of compliance that FCA has already offered, as well as the limited scope of this litigation (a car for which Plaintiff paid $57,000), the court finds that to include the emails in FCA’s discovery responses would render discovery of such breadth as to outweigh the likely benefit to this litigation under Code of Civil Procedure § 1985.8.

  • Hearing

MATTER OF CARRARI FAMILY TRUST, EST. FEBRUARY 28, 2002

Angelucci—who had only represented Dettamanti in a limited-scope representation which had terminated earlier this year, and was not representing her with respect to these issues—was killed on July 11, 2020.] Based upon this history, Kopcrak now seeks terminating and monetary sanctions ($7,617.10), for Dettamanti’s willful failure to comply with the court’s order compelling that her deposition take place on July 13 and 14.

  • Hearing

NORTH COUNTY COMMUNICATIONS CORPORATION VS. VAYA TELECOM INC

After a continuance, NCC has obtained counsel for a limited scope representation. NCC filed an opposition, which is essentially identical to the one filed by NCC's prior counsel. The opposition was filed late. The Court need not consider the opposition. But even if the Court considered the merits of the opposition, the Court would still grant the motion. The judgment is hereby amended according to the request made in Defendant/Judgment Creditor VAYA TELECOM, INC.'s amended reply.

  • Hearing

  • Type

    Contract

  • Sub Type

    Breach

NORTH COUNTY COMMUNICATIONS CORPORATION VS. VAYA TELECOM INC

After a continuance, NCC has obtained counsel for a limited scope representation. NCC filed an opposition, which is essentially identical to the one filed by NCC's prior counsel. The opposition was filed late. The Court need not consider the opposition. But even if the Court considered the merits of the opposition, the Court would still grant the motion. The judgment is hereby amended according to the request made in Defendant/Judgment Creditor VAYA TELECOM, INC.'s amended reply.

  • Hearing

  • Type

    Contract

  • Sub Type

    Breach

NORTH COUNTY COMMUNICATIONS CORPORATION VS. VAYA TELECOM INC

After a continuance, NCC has obtained counsel for a limited scope representation. NCC filed an opposition, which is essentially identical to the one filed by NCC's prior counsel. The opposition was filed late. The Court need not consider the opposition. But even if the Court considered the merits of the opposition, the Court would still grant the motion. The judgment is hereby amended according to the request made in Defendant/Judgment Creditor VAYA TELECOM, INC.'s amended reply.

  • Hearing

  • Type

    Contract

  • Sub Type

    Breach

NORTH COUNTY COMMUNICATIONS CORPORATION VS. VAYA TELECOM INC

After a continuance, NCC has obtained counsel for a limited scope representation. NCC filed an opposition, which is essentially identical to the one filed by NCC's prior counsel. The opposition was filed late. The Court need not consider the opposition. But even if the Court considered the merits of the opposition, the Court would still grant the motion. The judgment is hereby amended according to the request made in Defendant/Judgment Creditor VAYA TELECOM, INC.'s amended reply.

  • Hearing

  • Type

    Contract

  • Sub Type

    Breach

NORTH COUNTY COMMUNICATIONS CORPORATION VS. VAYA TELECOM INC

After a continuance, NCC has obtained counsel for a limited scope representation. NCC filed an opposition, which is essentially identical to the one filed by NCC's prior counsel. The opposition was filed late. The Court need not consider the opposition. But even if the Court considered the merits of the opposition, the Court would still grant the motion. The judgment is hereby amended according to the request made in Defendant/Judgment Creditor VAYA TELECOM, INC.'s amended reply.

  • Hearing

  • Type

    Contract

  • Sub Type

    Breach

NORTH COUNTY COMMUNICATIONS CORPORATION VS. VAYA TELECOM INC

After a continuance, NCC has obtained counsel for a limited scope representation. NCC filed an opposition, which is essentially identical to the one filed by NCC's prior counsel. The opposition was filed late. The Court need not consider the opposition. But even if the Court considered the merits of the opposition, the Court would still grant the motion. The judgment is hereby amended according to the request made in Defendant/Judgment Creditor VAYA TELECOM, INC.'s amended reply.

  • Hearing

  • Type

    Contract

  • Sub Type

    Breach

LARRY NEUBERG VS FCA US, LLC, ET AL.

Given the statements of compliance that FCA has already offered, as well as the limited scope of this litigation (a car for which Plaintiff paid $57,000), the court finds that to include the emails in FCA’s discovery responses would render discovery of such breadth as to outweigh the likely benefit to this litigation under Code of Civil Procedure § 1985.8.

  • Hearing

OVERLAND DIRECT, INC. VS YANIV TEPPER, ET AL

Again, one business day prior to the set deposition, Daniel Tepper informed Plaintiff he would not be appearing because he could not get in touch with his limited scope attorney, Robert Smith. Plaintiff informed Daniel Tepper his non-appearance would result in court intervention. (Mobasser Decl., ¶9; Exh. 7.) Daniel Tepper failed to appear on March 5, 2020 and Plaintiff had to take a certificate of non-appearance. (Mobasser Decl., ¶9; Exh. 7 and McCarthy Decl. ¶3; Exh. 1.)

  • Hearing

  • Type

    Real Property

  • Sub Type

    other

  • Judge

    Paul A. Bacigalupo or Virginia Keeny

  • County

    Los Angeles County, CA

ELLIE CHAPPEL VS F C I LENDER SERVICES, INC., ET AL.

On July 27, 2020, Plaintiff filed her opposition and a Notice of Limited Scope of Representation indicating she would be represented by Adela Z. Ulloa (“Plaintiff’s Counsel”) on the limited scope basis of preparing the opposition to the demurrer to the SAC and preparing the Third Amended Complaint (“TAC”) and other matters related to an ex parte application for leave to file a TAC.

  • Hearing

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

BONNIE DUBOFF VS LINDA SCHERMER ET AL

Scope Representation (Judicial Council mandatory form CIV-150) to represent her as her attorney of record in this case.

  • Hearing

TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA VS RICARDO LARA, IN HIS CAPACITY AS CALIFORNIA INSURANCE COMMISSIONER

Paralegals Michael Martel (“Martel”) and Sean An (“An”), provided additional, limited-scope assistance. Michael Adreani, Esq. (“Adreani”), a partner at the firm with 22 years of experience as a civil litigator, consulted very briefly on this attorneys’ fee motion. Roxborough Decl. ¶5.

  • Hearing

  • Type

    Administrative

  • Sub Type

    Writ

SCOTT ERIC ROSENSTIEL VS CANDACE HOWELL, ET AL.

(See e.g., CRC Rule 3.36 [CIV-150 Form re Notice of Limited Scope Representation]; CCP §§284-285 [MC-050 Form re Substitution of Attorney – Civil].) On July 1, 2020, Defendant filed a Notice of Limited Scope Representation, but this was done only days before the hearing and after the meet and confer efforts and motion papers were filed. Thus, at this time, the Court will grant the motion to quash the subpoena issued on Citibank.

  • Hearing

  • County

    Los Angeles County, CA

DANNIEL MADRID VS CANDACE HOWELL

(See e.g., CRC Rule 3.36 [CIV-150 Form re Notice of Limited Scope Representation]; CCP §§284-285 [MC-050 Form re Substitution of Attorney – Civil].) On July 1, 2020, Defendant filed a Notice of Limited Scope Representation, which this was done only days before the hearing and after the meet and confer efforts and motion papers were filed. Thus, at this time, the Court will grant the motion to quash the subpoena issued on Citibank.

  • Hearing

  • County

    Los Angeles County, CA

SCOTT ERIC ROSENSTIEL VS CANDACE HOWELL, ET AL.

(See e.g., CRC Rule 3.36 [CIV-150 Form re Notice of Limited Scope Representation]; CCP §§284-285 [MC-050 Form re Substitution of Attorney – Civil].) On July 1, 2020, Defendant filed a Notice of Limited Scope Representation, but this was done only days before the hearing and after the meet and confer efforts and motion papers were filed. Thus, at this time, the Court will grant the motion to quash the subpoena issued on Citibank.

  • Hearing

  • County

    Los Angeles County, CA

VALERIE PACHECO VS NISSAN NORTH AMERICA, INC., A CALIFORNIA CORPORATION

Defendant emphasizes that Plaintiff’s fraud claim rests only on alleged omissions and concealment, which fall outside of the limited scope of the Robinson exception, which applies only to affirmative representations. (Demurrer, at p. 9.) Defendant relies as well upon Thompson v. BMW of North America, LLC (C.D. Cal. 2019), No. SACV 17-01912-CJC-KS, 2019 WL 988694, at *5 (applying California law and finding omission claim not falling under Robinson exception).

  • Hearing

  • Type

    Contract

  • Sub Type

    Breach

DR ELLIE KAUCHER VS PHILLIPS GRADUATE UNIVERSITY ET AL

Analysis The Court finds that Bohm and Ciarimboli did not file an Application to Be Relieved as Attorney on Completion of Limited Scope Representation using form CIV-151. Bohm and Ciarimboli filed a motion to be relieved as counsel using forms MC-051, MC-052, and MC-053. Plaintiff was served with the motion to be relieved as counsel on March 2, 2020 via overnight mail. Plaintiff did not file her objection until June 9, 2020.

  • Hearing

  • Type

    Employment

  • Sub Type

    Wrongful Term

BEATA KAMINSKA VS ELIZABETH KANSKI

The Court also notes that Lentz admits that he is in a limited scope representation with Defendant. (Lentz Decl., ¶ 2.) Per CRC Rule 3.36(a), the attorney and client must provide notice of their agreement by serving and filing a mandatory Judicial Council form that discloses the nature and duration of the attorney's representation. Lentz has not complied with his obligations to notice the court and Plaintiff of this limited scope representation.

  • Hearing

MANUEL DE JESUS MORALES VS EDUARDO A. CANAS, ET AL.

On November 12, 2019, Defendant Best Alliance Foreclosure and Lien Services filed a declaration of trustee’s non-monetary status to Plaintiff’s complaint pursuant to Civil Code section 2924l notice of limited scope representation pursuant to Civil Code section 2924l. On January 30, 2020, Defendant Eduardo A. Canas was dismissed by the Court pursuant to an oral request made by Plaintiff.

  • Hearing

  • Type

    Real Property

  • Sub Type

    Quiet Title

ADRIANA LAYMAN AND JARED F. LAYMAN

Frederick Seigenfeld, under a limited scope agreement to advise and prepare court documents for an uncontested dissolution of marriage and associated requests for orders. Mr. Seigenfeld has been practicing in family law since 2016 and charges $300/hr. Father is employed by the City of Santa Barbara.

  • Hearing

MATTER OF CARRARI FAMILY TRUST

Angelucci for Angelina Dettamanti on a limited scope basis formotion to vacate orders only Angelina Dettamanti is in pro per on all other matters Rafael G. Gutierrez for non-party Marcial Lopez TENTATIVE RULINGS: (1) The motion to disqualify counsel is denied in its entirety.

  • Hearing

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