On July 17, 2018 a
Motion-Secondary
was filed
involving a dispute between
Dreyer Dr. Jerrold S. Md,
Dreyer Rachel Chaim,
Jerrold S. Dreyer Md Trustee,
Macias Kathy,
and
Jm Capital Investments Llc,
Keyes Carlos,
Lluis Miguel,
Macias Kathy,
Marble Arch Entertainment Llc,
Plainfield Pass Media Llc Aka Plainfield Pass Llc A Delaware Corporation,
Red Entertainment Group,
Williams J. David,
Zsemonadi Donald,
for civil
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 09/04/2020 09:12 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Soto,Deputy Clerk
MC-052
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, stale bar number, and address) FOR COURT USE ONLY
Diane, Goldman SBN 89681
Law Office of Diane Goldman
21860 Burbank Blvd. Ste. 370
Woodland Hills, CA 91367
TELEPHONE NO. 818-883-3344 raxno: §18-883-3355
ATTORNEY FOR (Name) Defendant/Cross-complainant, KATHY MACIAS
NAME OF COURT! Superior Court of California
STREET ADDRESS: 111 N. Hill St.
MAILING ADDRESS:
CITY AND ZIP CODE: Los Angeles, CA 90012
BRANCH NAME: Central District - Stanley Mosk Courthouse
CASE NAME: DR JERROLD S. DREYER v. JM CAPITAL INVEST. (CASE NUMBER:
BC714688
HEARING DATE: 1/01/2020
oer: 24 Te: 8:30 a.m
DECLARATION IN SUPPORT OF ATTORNEY'S BeFOREHON: Patricia Nieto
MOTION TO BE RELIEVED AS COUNSEL—CIVIL
pare action ried: (7/17/2018
Tracoate: 03/15/2021
1. Attorney and Represented Party. Attorney (name): DIANE GOLDMAN
is presently counsel of record for (name of party): Defendant/Cross-complainant, KATHY MACIAS
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):
There has been a complete breakdown of communication between attorney and client, rendering further
effective representation impossible. Client has refused to sign a Substitution of Attorney pleading.
[=] Continued on Attachment 2
3. 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. If the nt has been served by mail at the client's last known address, attorney has
(1) 4] confirmed within the past 30 days that the address is current
(a)[_] by mail, return receipt requested.
‘b) [_] by telephone.
(c) [_] by conversation
(d) 1] by other means (specify):
by confirmation of delivery of overnight mail by Fed Ex.
(Continued on reverse)
Page 1 of 2
Form Adopted for Mandatory Use DECLARATION IN SUPPORT OF ATTORNEY'S ‘Code of Civil Procedure, § 284;
yidig! Counc of Calforia Cal, Rules of Court, rule 3.1362
Rev. January 1 04 MOTION TO BE RELIEVED AS COUNSEL—CIVIL wwaw.courtinfo.ca. gov
Document Filed Date
September 04, 2020
Case Filing Date
July 17, 2018
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Electronically FILED by Superior Court of California, County of Los Angeles on 09/04/2020 09:12 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Soto,Deputy Clerk MC-052 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, stale bar number, and address) FOR COURT USE ONLY Diane, Goldman SBN 89681 Law Office of Diane Goldman 21860 Burbank Blvd. Ste. 370 Woodland Hills, CA 91367 TELEPHONE NO. 818-883-3344 raxno: §18-883-3355 ATTORNEY FOR (Name) Defendant/Cross-complainant, KATHY MACIAS NAME OF COURT! Superior Court of California STREET ADDRESS: 111 N. Hill St. MAILING ADDRESS: CITY AND ZIP CODE: Los Angeles, CA 90012 BRANCH NAME: Central District - Stanley Mosk Courthouse CASE NAME: DR JERROLD S. DREYER v. JM CAPITAL INVEST. (CASE NUMBER: BC714688 HEARING DATE: 1/01/2020 oer: 24 Te: 8:30 a.m DECLARATION IN SUPPORT OF ATTORNEY'S BeFOREHON: Patricia Nieto MOTION TO BE RELIEVED AS COUNSEL—CIVIL pare action ried: (7/17/2018 Tracoate: 03/15/2021 1. Attorney and Represented Party. Attorney (name): DIANE GOLDMAN is presently counsel of record for (name of party): Defendant/Cross-complainant, KATHY MACIAS 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): There has been a complete breakdown of communication between attorney and client, rendering further effective representation impossible. Client has refused to sign a Substitution of Attorney pleading. [=] Continued on Attachment 2 3. 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. If the nt has been served by mail at the client's last known address, attorney has (1) 4] confirmed within the past 30 days that the address is current (a)[_] by mail, return receipt requested. ‘b) [_] by telephone. (c) [_] by conversation (d) 1] by other means (specify): by confirmation of delivery of overnight mail by Fed Ex. (Continued on reverse) Page 1 of 2 Form Adopted for Mandatory Use DECLARATION IN SUPPORT OF ATTORNEY'S ‘Code of Civil Procedure, § 284; yidig! Counc of Calforia Cal, Rules of Court, rule 3.1362 Rev. January 1 04 MOTION TO BE RELIEVED AS COUNSEL—CIVIL wwaw.courtinfo.ca. gov