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MNT
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Oct-22-2014 4:22 pm
Case Number: CGC-13-535864
Filing Date: Oct-22-2014 4:17
Filed by: CAROL BALISTRERI
Juke Box: 001 Image: 04664332
MOTION FOR WITHDRAWAL OF ATTORNEY OF RECORD
BENTLY BIOFUELS COMPANY LLC DBA BENTLY BIOFUELS VS. K. DAVID
FISHER et al
001004664332
Instructions:
Please place this sheet on top of the document to be scanned.@ MC-051
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slate bar number, and address): FOR COURT USE ONLY
|__ Stephen D. Collins (SBN 277482) / Kevin W. Isaacson (SBN 281067) Go
TINGLEY LAW GROUP, PC E D
10 Almaden Boulevard, Suite 430 ‘superior of California
San Jose, California 95113 founty of San Francisco
TevepHONENo.: (408) 283-7000 Fax no.: (408) 283-7010
ATTORNEY FOR (Name): Defendants Oct 2 9 2014
NAME OF COURT: SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO RT
street appress: 400 McAllister Street oe OF THE COU AW
MAILING ADDRESS: B& Hd epury —
ciry ano zip cone: San Francisco, California 94102
BRANCH NAME:
ss (CASE NUMBER:
CASE NAME: BENTLY BIOFUELS COMPANY LLC v. FISHER, et al. CGC.13-535864
Hearn pate: December 15, 2014
NOTICE OF MOTION AND MOTION pert: 302 Time: 9:30 a.m.
TO BE RELIEVED AS Reservation No. 102114-07
COUNSEL—CIVIL DATE ACTION FiteD: December 3, 2013
triat pate: April 6, 2015,
TO (name and address of client): K. David Fisher, 3D Oil&Grease LLC, 74 Kelloch Avenue, San Francisco, CA 94134
Curtis Tingley, Stephen Collins, Kevin Isaacson
. PLEASE TAKE NOTICE that (name of withdrawing attorney): and Kevin P. O'Brien / TINGLEY LAW GROUP, PC.
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. Ahearing on this motion to be relieved as counsel will be held as follows:
a. Date: December 15, 2014 Time: 9:30 a.m. Dept.: 302 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):
Good cause exists for this motion, which is best provided in further detail to the Court in camera, as to provide
otherwise would compromise the confidentiality of the attorney-client relationship.
(This motion does not need fo 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. BJ an individual. g. a trustee.
b. a corporation. h, a personal representative.
c. a partnership. i, a probate fiduciary.
d. an unincorporated association. je a guardian ad litem.
e. a guardian. k. EX} other (specify): Limited Liability Company
f. a conservator.
(Continued on reverse) Page 1of2
Ferm Adopted ior Mandatory Use NOTICE OF MOTION AND MOTION Gece! Coun eS acd
N05 Rev. January 1, 2007) TO BE RELIEVED AS COUNSEL—CIVIL vnew.coutino ca. gov
‘American LegalNet, Inc.
www. Forms Workfiow.comCASE NUMBER:
CGC-13-535864
MC-051
CASE NAME:
|--BENTLY BIOFUELS COMPANY LLC v. FISHER, et al.
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: October 22, 2014
Stephen D. Collins » —~..
(TYPE OR PRINT NAME) UW {SIGNATURE OF ATTORNEY)
Attorney for (name): Defendants
MC-061 [Rev. January 1, 2007) NOTICE OF MOTION AND MOTION Page 2 of2
TO BE RELIEVED AS COUNSEL—CIVIL “American LegalNe, nc,
‘wnew Forms Workdow.com
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MNT SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Oct-22-2014 4:22 pm Case Number: CGC-13-535864 Filing Date: Oct-22-2014 4:17 Filed by: CAROL BALISTRERI Juke Box: 001 Image: 04664332 MOTION FOR WITHDRAWAL OF ATTORNEY OF RECORD BENTLY BIOFUELS COMPANY LLC DBA BENTLY BIOFUELS VS. K. DAVID FISHER et al 001004664332 Instructions: Please place this sheet on top of the document to be scanned.@ MC-051 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slate bar number, and address): FOR COURT USE ONLY |__ Stephen D. Collins (SBN 277482) / Kevin W. Isaacson (SBN 281067) Go TINGLEY LAW GROUP, PC E D 10 Almaden Boulevard, Suite 430 ‘superior of California San Jose, California 95113 founty of San Francisco TevepHONENo.: (408) 283-7000 Fax no.: (408) 283-7010 ATTORNEY FOR (Name): Defendants Oct 2 9 2014 NAME OF COURT: SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO RT street appress: 400 McAllister Street oe OF THE COU AW MAILING ADDRESS: B& Hd epury — ciry ano zip cone: San Francisco, California 94102 BRANCH NAME: ss (CASE NUMBER: CASE NAME: BENTLY BIOFUELS COMPANY LLC v. FISHER, et al. CGC.13-535864 Hearn pate: December 15, 2014 NOTICE OF MOTION AND MOTION pert: 302 Time: 9:30 a.m. TO BE RELIEVED AS Reservation No. 102114-07 COUNSEL—CIVIL DATE ACTION FiteD: December 3, 2013 triat pate: April 6, 2015, TO (name and address of client): K. David Fisher, 3D Oil&Grease LLC, 74 Kelloch Avenue, San Francisco, CA 94134 Curtis Tingley, Stephen Collins, Kevin Isaacson . PLEASE TAKE NOTICE that (name of withdrawing attorney): and Kevin P. O'Brien / TINGLEY LAW GROUP, PC. 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. Ahearing on this motion to be relieved as counsel will be held as follows: a. Date: December 15, 2014 Time: 9:30 a.m. Dept.: 302 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): Good cause exists for this motion, which is best provided in further detail to the Court in camera, as to provide otherwise would compromise the confidentiality of the attorney-client relationship. (This motion does not need fo 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. BJ an individual. g. a trustee. b. a corporation. h, a personal representative. c. a partnership. i, a probate fiduciary. d. an unincorporated association. je a guardian ad litem. e. a guardian. k. EX} other (specify): Limited Liability Company f. a conservator. (Continued on reverse) Page 1of2 Ferm Adopted ior Mandatory Use NOTICE OF MOTION AND MOTION Gece! Coun eS acd N05 Rev. January 1, 2007) TO BE RELIEVED AS COUNSEL—CIVIL vnew.coutino ca. gov ‘American LegalNet, Inc. www. Forms Workfiow.comCASE NUMBER: CGC-13-535864 MC-051 CASE NAME: |--BENTLY BIOFUELS COMPANY LLC v. FISHER, et al. 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: October 22, 2014 Stephen D. Collins » —~.. (TYPE OR PRINT NAME) UW {SIGNATURE OF ATTORNEY) Attorney for (name): Defendants MC-061 [Rev. January 1, 2007) NOTICE OF MOTION AND MOTION Page 2 of2 TO BE RELIEVED AS COUNSEL—CIVIL “American LegalNe, nc, ‘wnew Forms Workdow.com