On January 01, 1900 a
Motion-Secondary
was filed
involving a dispute between
Bagga, Surjit,
and
City National Bank,
Fresno Management Company, A California Corporation,
Hutchins, Ray,
Kruse, James,
for 26 Unlimited - Other Real Property
in the District Court of Fresno County.
Preview
MC-052
ATTORtEYORPM1YWITI01T ATTORtEY(Nan&, .tlllB,_tUJw. and~ FORCOURTUSECM.Y
Margarita Salazar,Esq. (SBN224649)
Law Offices of Margarita Salazar,APLC E-FILED
470 Third Avenue,Suite 9
1/22/2020 8:00 AM
Chula Vista CA 9191O Superior Court of California
County of Fresno
lB.EPHOtENO. : (619) 816-5894 FAXNO.: (877) 2~695 By: K. Daves, Deputy
ATTORtEYFOR(NamBJ:Surjit Bagga
NAMEOFCCll.m SuperiorCourt of California County of Fresno
STREETACORESS:1130 0 Street
MAILINGACORESS:
aTYN«>ZIPCOOE: Fresno 93721-2220
BRANCHNAME: B. F. Sisk Courthouse
CASE NAME: Surjit Bagga V. City National Bank.et al. CASEtUIIIER:16CECG03336
tEARING DAlE: 04/08/2020
IEPT .: • 5£JJ TIME: 3:27
p.m.
DECLARATIONIN SUPPORTOF ATTORNEY"S :Hon. Jeffrey Y. Hamilton
BEFOREHCX
MOTIONTO BE RELIEVEDAS COUNSEL-CIVIL
DAlE ACTIQffllm 10/14/2016
TRIALDAlE: 02/22/2021
1. Attorney and Represented Party. Attorney(name): MargaritaSalazar
Is presentlycounselof recordfor (name of party): Surjlt Bagga
In the above-captioned
actionor proceeding
.
2. Reasons for Motion. Attorneymakesthis motionto be relievedas counselunderCodeof Civil Proceduresection284(2) instead
of filing a consentundersection 284(1) for the followingreasons(describe):
Plaintiff Is aware of this motion and has refused to providewritten consent of substitution of attorneys. The specific
facts which give rise to this motion are confidential and requiredto be kept confidential pursuant to Business and
Professions Code §6068(e), rule 3-lOO(A),California Rulesof ProfessionalConduct,and by the attorney-client
privilege (Evld. C., §§950 et seq.). In the eventthat this court desiresfurther Information to ascertain the good faith
basis for this motion and for withdrawal, it Is respectfully requestedthat the court have an In camera hearing outside
of the presence of all other parties so that the specific facts demonstratinggood cause for this withdrawal may be
demonstrated to the court. (Manfredi & Levinev. SuperiorCourt {1998) 66 Cal.App.4th1128, 1136-1137; 3-700{8) or
{C))
D Continuedon Attachment2.
3. Service
a. Attorneyhas
(1) D personallyservedthe clientwith copiesof the motionpapersfiledwiththis declaration . A copyof the proofof service
will be filedwith the courtat least5 daysbeforethe hearing.
(2) 1YJservedthe clientby mailat the client'slast knownaddresswith copiesof the motionpapersservedwith this declaration.
b. If the client has been servedby mailat the client'slast knownaddress,attorneyhas
(1) IYJ confirmedwithinthe past30 daysthatthe addressis current
(a)D by mall,returnreceiptrequested.
(b)D bytelephone.
(c) D by conversation.
(d)~ by othermeans(specify):
Counsel has sent emails to Plaintiffs son, who Is acting with Plaintiffs consent as her English
speaking representative.
(Conllruad on->
Page1 of2
~~.o::.':&r"ttJ.
u.
MC-052(Rev. Jnay 1, 2007)
DECLARATIONINSUPPORTOFATTORNEY"S QxladOvl l'nlcacln_ § 284·
Cal.RMI d Cast, rue3.1362
MOTIONTO BE RELIEVEDAS COUNSEL-CML - -~ca.gov
MC-052
CASE NAME: Surjit Baggav. City National Bank,et al. CASEM.MBER
16CECG03336
3. b. (2) D been unable to confirm that the address is current or to locate a more current address for the client after making the
following efforts:
(a) D mailing the motion papers to the client's last known address, return receipt requested .
(b) D calling the client's last known telephone number or numbers.
(c) D contacting persons familiar with the client (specify):
(d) D conducting a search {describe):
(e) D other (specify):
c. Even if attorney has been unable to serve the client with the moving papers, the court should grant attorney's motion to be
relieved as counsel of record (explain):
4. The next hearing scheduled in this action or proceeding
a. D is not yet set.
b . ~ is set as follows (specify the date, time, and place):
MANDATORYSETTLEMENT
CONFERENCE 02/19/2021 @ 9:30 a.to\;
02/03/2021 @ 10:00a.m.; TRIALREADINESS
c. D co~cerns(describethesubjectmatterofthehearing): 0--" 'T(\o.( 0-i/z'Z-/>1.l 9 'i~«Jo\
D Continued on Attachment 4 .
5. The following additional hearings and other proceedings (including discovery matters) are presently scheduled in this case (for each,
describe the date, time, place, and subject matter):
MANDATORYSETTLEMENT CONFERENCE 02/03/2021 @ 10:00a.m.(Room575);
TRIAL READINESS 02/19/2021 @ 9:30 a.m. (Dept. 502);and
TRIAL 02/22/2021 @ 9:00 a.m. (Dept.502).
D Continued on Attachment 5.
6. Trial in this action or proceeding
a. D is not yet set.
b. ~ is set as follows (specify the date, time, and place):
TRIAL02/22/2021 @ 9:00 a.m. Dept.502
7. Other. Other matters that the court should consider in determining whether to grant this motion are the following (explain) :
Plaintiff is aware of this motion and has refusedto providewritten consent of substitution of attorneys. The specific
facts which give rise to this motion are confidential and requiredto be kept confidential pursuantto Business and
Professions Code §6068{e),rule 3-100{A),CaliforniaRulesof ProfessionalConduct,and by the attorney-client privilege
(Evld. c.,§§950 et seq.). In the eventthat this court desiresfurther Informationto ascertainthe good faith basis for this
motion and for withdrawal,It Is respectfullyrequestedthat the court havean In camerahearing outside of the presence
Date: r •• ·z,
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
7-,o,_..
Margarita Salazar
(TYPEORPRINTNAME)
8. Number of pages attached :
---
MC-052[Rav. Ja.-y 1, 2007)
DECLARATIONINSUPPORTOFATTORNEY'S Paue2of2
MOTIONTO BE RELIEVEDAS COUNSEL-CML
Document Filed Date
January 22, 2020
Case Filing Date
January 01, 1900
Category
26 Unlimited - Other Real Property
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MC-052 ATTORtEYORPM1YWITI01T ATTORtEY(Nan&, .tlllB,_tUJw. and~ FORCOURTUSECM.Y Margarita Salazar,Esq. (SBN224649) Law Offices of Margarita Salazar,APLC E-FILED 470 Third Avenue,Suite 9 1/22/2020 8:00 AM Chula Vista CA 9191O Superior Court of California County of Fresno lB.EPHOtENO. : (619) 816-5894 FAXNO.: (877) 2~695 By: K. Daves, Deputy ATTORtEYFOR(NamBJ:Surjit Bagga NAMEOFCCll.m SuperiorCourt of California County of Fresno STREETACORESS:1130 0 Street MAILINGACORESS: aTYN«>ZIPCOOE: Fresno 93721-2220 BRANCHNAME: B. F. Sisk Courthouse CASE NAME: Surjit Bagga V. City National Bank.et al. CASEtUIIIER:16CECG03336 tEARING DAlE: 04/08/2020 IEPT .: • 5£JJ TIME: 3:27 p.m. DECLARATIONIN SUPPORTOF ATTORNEY"S :Hon. Jeffrey Y. Hamilton BEFOREHCX MOTIONTO BE RELIEVEDAS COUNSEL-CIVIL DAlE ACTIQffllm 10/14/2016 TRIALDAlE: 02/22/2021 1. Attorney and Represented Party. Attorney(name): MargaritaSalazar Is presentlycounselof recordfor (name of party): Surjlt Bagga In the above-captioned actionor proceeding . 2. Reasons for Motion. Attorneymakesthis motionto be relievedas counselunderCodeof Civil Proceduresection284(2) instead of filing a consentundersection 284(1) for the followingreasons(describe): Plaintiff Is aware of this motion and has refused to providewritten consent of substitution of attorneys. The specific facts which give rise to this motion are confidential and requiredto be kept confidential pursuant to Business and Professions Code §6068(e), rule 3-lOO(A),California Rulesof ProfessionalConduct,and by the attorney-client privilege (Evld. C., §§950 et seq.). In the eventthat this court desiresfurther Information to ascertain the good faith basis for this motion and for withdrawal, it Is respectfully requestedthat the court have an In camera hearing outside of the presence of all other parties so that the specific facts demonstratinggood cause for this withdrawal may be demonstrated to the court. (Manfredi & Levinev. SuperiorCourt {1998) 66 Cal.App.4th1128, 1136-1137; 3-700{8) or {C)) D Continuedon Attachment2. 3. Service a. Attorneyhas (1) D personallyservedthe clientwith copiesof the motionpapersfiledwiththis declaration . A copyof the proofof service will be filedwith the courtat least5 daysbeforethe hearing. (2) 1YJservedthe clientby mailat the client'slast knownaddresswith copiesof the motionpapersservedwith this declaration. b. If the client has been servedby mailat the client'slast knownaddress,attorneyhas (1) IYJ confirmedwithinthe past30 daysthatthe addressis current (a)D by mall,returnreceiptrequested. (b)D bytelephone. (c) D by conversation. (d)~ by othermeans(specify): Counsel has sent emails to Plaintiffs son, who Is acting with Plaintiffs consent as her English speaking representative. (Conllruad on-> Page1 of2 ~~.o::.':&r"ttJ. u. MC-052(Rev. Jnay 1, 2007) DECLARATIONINSUPPORTOFATTORNEY"S QxladOvl l'nlcacln_ § 284· Cal.RMI d Cast, rue3.1362 MOTIONTO BE RELIEVEDAS COUNSEL-CML - -~ca.gov MC-052 CASE NAME: Surjit Baggav. City National Bank,et al. CASEM.MBER 16CECG03336 3. b. (2) D been unable to confirm that the address is current or to locate a more current address for the client after making the following efforts: (a) D mailing the motion papers to the client's last known address, return receipt requested . (b) D calling the client's last known telephone number or numbers. (c) D contacting persons familiar with the client (specify): (d) D conducting a search {describe): (e) D other (specify): c. Even if attorney has been unable to serve the client with the moving papers, the court should grant attorney's motion to be relieved as counsel of record (explain): 4. The next hearing scheduled in this action or proceeding a. D is not yet set. b . ~ is set as follows (specify the date, time, and place): MANDATORYSETTLEMENT CONFERENCE 02/19/2021 @ 9:30 a.to\; 02/03/2021 @ 10:00a.m.; TRIALREADINESS c. D co~cerns(describethesubjectmatterofthehearing): 0--" 'T(\o.( 0-i/z'Z-/>1.l 9 'i~«Jo\ D Continued on Attachment 4 . 5. The following additional hearings and other proceedings (including discovery matters) are presently scheduled in this case (for each, describe the date, time, place, and subject matter): MANDATORYSETTLEMENT CONFERENCE 02/03/2021 @ 10:00a.m.(Room575); TRIAL READINESS 02/19/2021 @ 9:30 a.m. (Dept. 502);and TRIAL 02/22/2021 @ 9:00 a.m. (Dept.502). D Continued on Attachment 5. 6. Trial in this action or proceeding a. D is not yet set. b. ~ is set as follows (specify the date, time, and place): TRIAL02/22/2021 @ 9:00 a.m. Dept.502 7. Other. Other matters that the court should consider in determining whether to grant this motion are the following (explain) : Plaintiff is aware of this motion and has refusedto providewritten consent of substitution of attorneys. The specific facts which give rise to this motion are confidential and requiredto be kept confidential pursuantto Business and Professions Code §6068{e),rule 3-100{A),CaliforniaRulesof ProfessionalConduct,and by the attorney-client privilege (Evld. c.,§§950 et seq.). In the eventthat this court desiresfurther Informationto ascertainthe good faith basis for this motion and for withdrawal,It Is respectfullyrequestedthat the court havean In camerahearing outside of the presence Date: r •• ·z, I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 7-,o,_.. Margarita Salazar (TYPEORPRINTNAME) 8. Number of pages attached : --- MC-052[Rav. Ja.-y 1, 2007) DECLARATIONINSUPPORTOFATTORNEY'S Paue2of2 MOTIONTO BE RELIEVEDAS COUNSEL-CML