On October 11, 2019 a
Motion-Secondary
was filed
involving a dispute between
Flores Luis Manuel,
Solorio Alejandro,
Solorio Alejandro An Individual,
and
Naranjo David,
Naranjo David An Individual,
Naranjo Rosa,
Naranjo Stephany Aka E.Z. Express,
Naranjo Stephany Dba E.Z. Express,
Rough Road Trucking Llc,
for Other Employment Complaint Case (General Jurisdiction)
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 01/23/2023 03:05 PM David W. Slayton, Executive Officer/Clerk of Court, by K. Hung, Deputy Clerk
MC-052
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state bar number, and address): FOR COURT USE ONLY
Sarkis Sirmabekian [SBN 278588]
Sirmabekian Law Firm, PC
3435 Wilshire Blvd., Ste 1710
Los Angeles, California 90010
‘TELEPHONE NO. (818) 473-5003 FAX NO. (818) 476-5619
ATTORNEY FOR (Name): Plaintiff Alejandro Solorio
NAME OF COURT: Superior Court of California - County of Los Angeles
STREET ADDRESS: 111 N. Hill Street
MAILING ADDRESS: 111 N. Hill Street
CITY AND ZIP CODE: Los Angeles 90012
BRANCH NAME: Stanley Mosk Courthouse
CASE NAME: Alejandro Solorio, et al. vs. Rough Road Trucking LLC, et CASE NUMBER:
19STCV36520
HeaRneoaTe: February 16, 2023
pept: 55 TIME: 8:30 AM
DECLARATION IN SUPPORT OF ATTORNEY’ seroreHON: Mackey, Malcolm
MOTION TO BE RELIEVED AS COUNSEL—CIVIL
pate action rien: October 11, 2019
Taw oate: May 8, 2023
Attorney and Represented Party. Attorney (name): Sarkis Sirmabekian, Esq. [SBN 278588]
is presently counsel of record for (name of party): Plaintiff ALEJANDRO SOLORIO
in the above-captioned action or proceeding.
Reasons for Motion. Attorney makes this motion to be relieved as counsel under Code of Civil Procedure section 284(2) instead
of filing a consent under section 284(1) for the following reasons (describe):
The reasons for this motion to be relieved are related to a conflict that developed between Plaintiff
Alejandro Solorio ("Plaintiff") and Counsel. Plaintiff is in breach of its retainer agreement. Specific facts
which give rise to this motion are confidential and required to be kept confidential pursuant to Busine:
and Professions Code Section 6068(e), rule 1.6 (formerly rule 3-100(A)), California Rules of Professional
Conduct, and by the attorney-client privilege (Evid. Code Sections 950, et seq.) Further information and
details may be provided to the Court in camera upon request.
[J] Continued on Attachment 2.
Service
a. Attorney has
(1)[_] personally served the client with copies of the motion papers filed with this declaration. A copy of the proof of service
will be filed with the court at least 5 days before the hearing.
(2) served the client by mail at the client's last known address with copies of the motion papers served with this declaration.
b. Ift nt has been served by mail at the client's last known address, attorney has
(1) confirmed within the past 30 days that the address is current
(a)_] by mail, return receipt requested.
(b) _] by telephone.
(c) by conversation.
(d) [_] by other means (specify):
(Continued on reverse)
Page 1 of 2
Form Adopted for Mandatory Use DECLARATION IN SUPPORT OF ATTORNEY'S Code of Civil Procedure, § 284;
Judicial Council of California Cal. Rules of Court, rule 3.1362
MC-052 [Rev. January 1, 2007] MOTION TO BE RELIEVED AS COUNSEL—CIVIL www.courtinfo.ca.gov
Document Filed Date
January 23, 2023
Case Filing Date
October 11, 2019
Category
Other Employment Complaint Case (General Jurisdiction)
Status
Court-Ordered Dismissal - Before Trial - Lack of Prosecution 05/08/2023
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Electronically FILED by Superior Court of California, County of Los Angeles on 01/23/2023 03:05 PM David W. Slayton, Executive Officer/Clerk of Court, by K. Hung, Deputy Clerk MC-052 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state bar number, and address): FOR COURT USE ONLY Sarkis Sirmabekian [SBN 278588] Sirmabekian Law Firm, PC 3435 Wilshire Blvd., Ste 1710 Los Angeles, California 90010 ‘TELEPHONE NO. (818) 473-5003 FAX NO. (818) 476-5619 ATTORNEY FOR (Name): Plaintiff Alejandro Solorio NAME OF COURT: Superior Court of California - County of Los Angeles STREET ADDRESS: 111 N. Hill Street MAILING ADDRESS: 111 N. Hill Street CITY AND ZIP CODE: Los Angeles 90012 BRANCH NAME: Stanley Mosk Courthouse CASE NAME: Alejandro Solorio, et al. vs. Rough Road Trucking LLC, et CASE NUMBER: 19STCV36520 HeaRneoaTe: February 16, 2023 pept: 55 TIME: 8:30 AM DECLARATION IN SUPPORT OF ATTORNEY’ seroreHON: Mackey, Malcolm MOTION TO BE RELIEVED AS COUNSEL—CIVIL pate action rien: October 11, 2019 Taw oate: May 8, 2023 Attorney and Represented Party. Attorney (name): Sarkis Sirmabekian, Esq. [SBN 278588] is presently counsel of record for (name of party): Plaintiff ALEJANDRO SOLORIO in the above-captioned action or proceeding. Reasons for Motion. Attorney makes this motion to be relieved as counsel under Code of Civil Procedure section 284(2) instead of filing a consent under section 284(1) for the following reasons (describe): The reasons for this motion to be relieved are related to a conflict that developed between Plaintiff Alejandro Solorio ("Plaintiff") and Counsel. Plaintiff is in breach of its retainer agreement. Specific facts which give rise to this motion are confidential and required to be kept confidential pursuant to Busine: and Professions Code Section 6068(e), rule 1.6 (formerly rule 3-100(A)), California Rules of Professional Conduct, and by the attorney-client privilege (Evid. Code Sections 950, et seq.) Further information and details may be provided to the Court in camera upon request. [J] Continued on Attachment 2. Service a. Attorney has (1)[_] personally served the client with copies of the motion papers filed with this declaration. A copy of the proof of service will be filed with the court at least 5 days before the hearing. (2) served the client by mail at the client's last known address with copies of the motion papers served with this declaration. b. Ift nt has been served by mail at the client's last known address, attorney has (1) confirmed within the past 30 days that the address is current (a)_] by mail, return receipt requested. (b) _] by telephone. (c) by conversation. (d) [_] by other means (specify): (Continued on reverse) Page 1 of 2 Form Adopted for Mandatory Use DECLARATION IN SUPPORT OF ATTORNEY'S Code of Civil Procedure, § 284; Judicial Council of California Cal. Rules of Court, rule 3.1362 MC-052 [Rev. January 1, 2007] MOTION TO BE RELIEVED AS COUNSEL—CIVIL www.courtinfo.ca.gov