Motion-Secondary: YUYI JIANG VS. ARNOLD CHEN

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 05/18/2021 12:29 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Scott,Deputy Clerk

                                                                                                                                                                 MC–052
      ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state bar number, and address):                                                       FOR COURT USE ONLY
      Daniel A. Friedlander, Esq. (206978)                                                                                 To keep other people from
      Law Offices of Daniel Friedlander                                                                                   seeing what you entered on
      29800 Agoura Road, Suite 101                                                                                        your form, please press the
      Agoura Hills, CA 91301                                                                                             Clear This Form button at the
           TELEPHONE NO.: 805-409-8710     FAX NO.: dan@leglr.com                                                       end of the form when finished.
     ATTORNEY FOR (Name): Defendants Arnold Chen and Timmy La

          NAME OF COURT: Los Angeles County Superior Court

         STREET ADDRESS: 300 East Olive

         MAILING ADDRESS:

        CITY AND ZIP CODE:      Burbank, CA 91502
             BRANCH NAME:       Burbank Courthouse
     CASE NAME:           Yuyi Jiang v. Arnold Chen, et al.                                                            CASE NUMBER:
                                                                                                                                       EC067678
                                                                                                                       HEARING DATE:  June 18, 2021
                                                                                                                       DEPT.: B             TIME: 8:30 a.m.
                             DECLARATION IN SUPPORT OF ATTORNEY'S                                                      BEFORE HON.: John J. Kralik
                            MOTION TO BE RELIEVED AS COUNSEL—CIVIL
                                                                                                                       DATE ACTION FILED: 12/27/2017

                                                                                                                       TRIAL DATE: May 24, 2021

    1. Attorney and Represented Party. Attorney (name): Daniel A. Friedlander, Esq.
       is presently counsel of record for (name of party): Timmy La
       in the above-captioned action or proceeding.
    2. 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):
        In accordance with Rule 3-700(A)(2) of the Rules of Professional Conduct, I have taken multiple and
        repeated steps to avoid reasonably foreseeable prejudice to the rights of the clients before filing this
        motion, including giving due notice to the clients allowing the clients time to retain the employment of
        another attorney. I am familiar with the provisions in Rule 3-700(C), and there are facts and
        circumstances that satisfy the requirements in more than one subsection, even when only one subsection
        is necessary to allow the withdrawal. To protect the attorney-client privilege I cannot recite the detail
        here. If the Court desires I can most certainly provide the facts and circumstance to the Court in chambers
        without opposing counsel present with the acknowledgment that such communication is not intended and
        does not waive the attorney-client privilege or attorney work product doctrine.
                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 client 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):




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     Form Adopted for Mandatory Use                                                                                                            Code of Civil Procedure, § 284;
       Judicial Council of California                DECLARATION IN SUPPORT OF ATTORNEY'S                                                      Cal. Rules of Court, rule 3.1362
      MC-052 [Rev. January 1, 2007]
                                                    MOTION TO BE RELIEVED AS COUNSEL—CIVIL                                                               www.courtinfo.ca.gov