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MC-051
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slate bar number, and address): FOR COURT USE ONLY
Vincent T. Martinez, Twitchell and Rice, LLP SBN: 174157
| -TWITCHELL & RICE LLP
215 N. Lincoln Street, P. O. Box 520
Santa Maria, CA 93458
TELEPHONE NO.: (805) 925-2611 Faxno.:(805) 925-1635
ATTORNEY FOR (Name: Saleh Ahmed Saleh
Name oF court: Superior Court of California
street appress: 1200 Aguajito Rd.
MAILING appRess: 1200 Aguajito Rd.
city AND zp cope: Monterey, 93940
BRANCH NAME: Monterey Courthouse
(CASE NAME: Hulad Ahmed Saleh v. Hiliam n Ahmed Saleb, Saleh 4 Ahmed Saleh and Star (GASE NUMBER:
21CV001545
HEARING parE: October 28, 2022
NOTICE OF MOTION AND MOTION errs 15 tue: 8:30 a.m.
TO BE RELIEVED AS serone Hon: Thomas W. Wills
COUNSEL—CIVIL DATE ACTION FLED: August 25, 2022
TRIAL DATE:
TO (name and adaress of client): Saleh Ahmed Saleh
1. PLEASE TAKE NOTICE that (name of withdrawing attorney): Vincent T. Martinez, Twitchell and Rice, LLP
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.
N
A hearing on this motion to be relieved as counsel will be held as follows:
a. Date:October 28, 2022 Time: 8:30 a.m. Dept: 15 Room: n/a
b. The address of the court! | [X]sameasnoted 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): na
(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. [X] an individual. g. [_] atrustee.
b. [__] acorporation. h. [_] apersonal representative.
c. [__] apartnership. i. [7] a probate fiduciary.
d. [__] an unincorporated association. J. [) aguardian ad litem.
e. [__] aguardian. k. other (specify):
f. [2] aconservator.
(Continued on reverse) Page 1 of 2
“orm Adopted for Mandatory Use NOTICE OF MOTION AND MOTION Code of Civil Procedure , § 284;
Cal
eo, TO BE RELIEVED AS COUNSEL—CIVIL oat Fae cuca gor
\Westinw Doe & Form BueMC-051
CASE NAME: Hulad Ahmed Saleh v. Hiliam Ahmed Saleh, Saleh Ahmed Saleh and Star | CASE NUMBER:
1 Petroleum, Inc., a California Corporation and Does 1 through 100 21CV001545
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
+ Aconservator + A probate fiduciary + An unincorporated association
+ Atrustee + Acorporation
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: August 29, 2022
Vincent T. Martinez
(TYPE OR PRINT NAME) (SIGNATURE OF ATTORNEY)
Attorney for (name): Saleh Ahmed Saleh
MC-054 [Rev. January 1, 2007] NOTICE OF MOTION AND MOTION Page 2 0f2
TO BE RELIEVED AS COUNSEL—CIVILPROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA
Iam employed in the County of Santa Barbara, State of California. I am over the age of 18 and
not a party to the within action. My business address is 215 North Lincoln Street, Santa Maria,
California 93458.
On August 25, 2022, I served the document described as: NOTICE OF MOTION AND
MOTION TO BE RELIEVED AS COUNSEL; DECLARATION IN SUPPORT OF
ATTORNEY’S MOTION TO BE RELIEVED AS COUNSEL; PROPOSED ORDER on the parties
in this action by serving:
Matthew K. Nash, Esq. Andrew B. Kreeft, Esq.
Reed & Nash, LLP Alex J. Lorca, Esq.
937 E. Main Street, Suite 207 Fenton & Keller
Santa Maria, CA 93455 2801 Monterey-Salinas Highway
Email: mnash@reednashlaw.com Monterey, CA 93942-0791
Email: akreeft@fentonkeller.com
Saleh A. Saleh Email: alorca@fentonkeller.com
8736 S. Indianola Ave.
Selma, CA 93662
(x ) BY MAIL: By placing (_) the original («_) true copies thereof enclosed in sealed
envelopes addressed as above in the U.S. Mail. I am "readily familiar" with this 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 Santa Maria, California
in the ordinary course of business. I am aware that on motion of the party served, service is presumed
invalid of postal cancellation date or postage meter date is more than one day after date of deposit for
mailing in affidavit.
(_) BY PERSONAL SERVICE: At the addresses listed above.
) BY FEDERAL EXPRESS: On , the envelope was picked up by
Federal Express at 215 North Lincoln Street, Santa Maria, CA, for delivery on the next-business-day
basis to the office of the addressee.
( ) BY FACSIMILE TRANSMISSION: On_, I caused the above-named document to be
transmitted by facsimile transmission, to the office of the addressee at the facsimile number so indicated
above. The transmission was reported as complete and without error. A copy of the transmission report
properly issued by the transmitting facsimile machine is attached hereto.
(_) BY E-MAIL TRANSMISSION: On_, I caused the above-named document to be
transmitted by e-mail to the addressee at the e-mail address so indicated above.
I declare under penalty of perjury under the laws of the State of California that the above is true
and correct. Executed on August 25, 2022, at Santa Maria, California.
Dror Frist
Lynn Igmone
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MC-051 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slate bar number, and address): FOR COURT USE ONLY Vincent T. Martinez, Twitchell and Rice, LLP SBN: 174157 | -TWITCHELL & RICE LLP 215 N. Lincoln Street, P. O. Box 520 Santa Maria, CA 93458 TELEPHONE NO.: (805) 925-2611 Faxno.:(805) 925-1635 ATTORNEY FOR (Name: Saleh Ahmed Saleh Name oF court: Superior Court of California street appress: 1200 Aguajito Rd. MAILING appRess: 1200 Aguajito Rd. city AND zp cope: Monterey, 93940 BRANCH NAME: Monterey Courthouse (CASE NAME: Hulad Ahmed Saleh v. Hiliam n Ahmed Saleb, Saleh 4 Ahmed Saleh and Star (GASE NUMBER: 21CV001545 HEARING parE: October 28, 2022 NOTICE OF MOTION AND MOTION errs 15 tue: 8:30 a.m. TO BE RELIEVED AS serone Hon: Thomas W. Wills COUNSEL—CIVIL DATE ACTION FLED: August 25, 2022 TRIAL DATE: TO (name and adaress of client): Saleh Ahmed Saleh 1. PLEASE TAKE NOTICE that (name of withdrawing attorney): Vincent T. Martinez, Twitchell and Rice, LLP 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. N A hearing on this motion to be relieved as counsel will be held as follows: a. Date:October 28, 2022 Time: 8:30 a.m. Dept: 15 Room: n/a b. The address of the court! | [X]sameasnoted 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): na (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. [X] an individual. g. [_] atrustee. b. [__] acorporation. h. [_] apersonal representative. c. [__] apartnership. i. [7] a probate fiduciary. d. [__] an unincorporated association. J. [) aguardian ad litem. e. [__] aguardian. k. other (specify): f. [2] aconservator. (Continued on reverse) Page 1 of 2 “orm Adopted for Mandatory Use NOTICE OF MOTION AND MOTION Code of Civil Procedure , § 284; Cal eo, TO BE RELIEVED AS COUNSEL—CIVIL oat Fae cuca gor \Westinw Doe & Form BueMC-051 CASE NAME: Hulad Ahmed Saleh v. Hiliam Ahmed Saleh, Saleh Ahmed Saleh and Star | CASE NUMBER: 1 Petroleum, Inc., a California Corporation and Does 1 through 100 21CV001545 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 + Aconservator + A probate fiduciary + An unincorporated association + Atrustee + Acorporation 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: August 29, 2022 Vincent T. Martinez (TYPE OR PRINT NAME) (SIGNATURE OF ATTORNEY) Attorney for (name): Saleh Ahmed Saleh MC-054 [Rev. January 1, 2007] NOTICE OF MOTION AND MOTION Page 2 0f2 TO BE RELIEVED AS COUNSEL—CIVILPROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA Iam employed in the County of Santa Barbara, State of California. I am over the age of 18 and not a party to the within action. My business address is 215 North Lincoln Street, Santa Maria, California 93458. On August 25, 2022, I served the document described as: NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL; DECLARATION IN SUPPORT OF ATTORNEY’S MOTION TO BE RELIEVED AS COUNSEL; PROPOSED ORDER on the parties in this action by serving: Matthew K. Nash, Esq. Andrew B. Kreeft, Esq. Reed & Nash, LLP Alex J. Lorca, Esq. 937 E. Main Street, Suite 207 Fenton & Keller Santa Maria, CA 93455 2801 Monterey-Salinas Highway Email: mnash@reednashlaw.com Monterey, CA 93942-0791 Email: akreeft@fentonkeller.com Saleh A. Saleh Email: alorca@fentonkeller.com 8736 S. Indianola Ave. Selma, CA 93662 (x ) BY MAIL: By placing (_) the original («_) true copies thereof enclosed in sealed envelopes addressed as above in the U.S. Mail. I am "readily familiar" with this 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 Santa Maria, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid of postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. (_) BY PERSONAL SERVICE: At the addresses listed above. ) BY FEDERAL EXPRESS: On , the envelope was picked up by Federal Express at 215 North Lincoln Street, Santa Maria, CA, for delivery on the next-business-day basis to the office of the addressee. ( ) BY FACSIMILE TRANSMISSION: On_, I caused the above-named document to be transmitted by facsimile transmission, to the office of the addressee at the facsimile number so indicated above. The transmission was reported as complete and without error. A copy of the transmission report properly issued by the transmitting facsimile machine is attached hereto. (_) BY E-MAIL TRANSMISSION: On_, I caused the above-named document to be transmitted by e-mail to the addressee at the e-mail address so indicated above. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on August 25, 2022, at Santa Maria, California. Dror Frist Lynn Igmone