On November 20, 2017 a
DECLARATION IN SUPPORT OF ATTORNEY'S MOTION TO BE RELIEVED AS COUNSEL-CIVIL
was filed
involving a dispute between
Johnson Stacy,
and
County Of Los Angeles,
for Wrongful Termination (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
MC-052
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state bar number, and address): FOR COURT USE ONLY
Joseph M. Lovretovich; Eric J. Palmer; Christina R. Manalo
State Bar Nos.: 73403; 231207; 297718
JML LAW, APLC FILED
21052 Oxnard Street, Woodland Hills, CA 91367 Superior Court of Californis
TELEPHONE NO.: 818-610-8800 County af Uns Anoeles
raxno: 818-610-3030
ATTORNEY FOR (Name): Plaintiff FEB 232018
NAME OF COURT: LOS ANGELES SUPERIOR COURT
‘STREET ADDRESS: 111 NORTH HILL STREET Sher} IR, oe execunive ae Clerk of Cours
MAILING ADDRESS: 111 NORTH HILL STREET By,
CITY AND ZIP CODE: LOS ANGELES, CA 90012
» Deputy
Judi Lara
BRANCH NAME: CENTRAL/STANLEY MOSK.
CASE NAME: JOHNSON v COUNTY OF LOS ANGELES CASE NUMBER:
BC683552
VEARNGDATE April 6, 2018
vert: 52 me: 8:30 a.m.
DECLARATION IN SUPPORT OF ATTORNEY'S BEFORE HON.
MOTION TO BE RELIEVED AS COUNSEL—CIVIL Susan Bryant-Deason
pare actionrieo: 11/20/2017
rriat oate: Not Set
1. Attorney and Represented Party. Attorney (name): Joseph M. Lovretovich; Eric J. Palmer; Christina ay analo
is presently counsel of record for (name of party):
in the above-captioned action or proceeding.
Stacy Johnson
(ee Z Bi\CESD]
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):
There has been an irreconcilable breakdown in the attorney-client relationship such that the attorney can
no longer effectively represent the client's interest. Further elaboration of this point would be in violation
of the attorney-client privilege. Plaintiffs counsel will elaborate further in camera at the hearing, if
necessary.
[[) 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) LZ} 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) confirmed within the past 30 days that the address is current
(a) [_] by mail, return receipt requested.
eS=} (b) __] by telephone.
(c) L_] by conversation.
(d) by other means (specify):
confirmation via electronic mail.
Pi
ey
eo
(Continued on reverse)
Page 1 of 2
Form Adopted for Mandatory Use of Civil Procedure, § 284;
Judicial Council of Calfomia DECLARATION IN SUPPORT OF ATTORNEY'S Cal. Rules of Court, rule 3.1362
-052 (Rev. January 1, 2007] MOTION TO BE RELIEVED AS COUNSEL—CIVIL www.courtinfo.ca.gov
Preview
MC-052 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state bar number, and address): FOR COURT USE ONLY Joseph M. Lovretovich; Eric J. Palmer; Christina R. Manalo State Bar Nos.: 73403; 231207; 297718 JML LAW, APLC FILED 21052 Oxnard Street, Woodland Hills, CA 91367 Superior Court of Californis TELEPHONE NO.: 818-610-8800 County af Uns Anoeles raxno: 818-610-3030 ATTORNEY FOR (Name): Plaintiff FEB 232018 NAME OF COURT: LOS ANGELES SUPERIOR COURT ‘STREET ADDRESS: 111 NORTH HILL STREET Sher} IR, oe execunive ae Clerk of Cours MAILING ADDRESS: 111 NORTH HILL STREET By, CITY AND ZIP CODE: LOS ANGELES, CA 90012 » Deputy Judi Lara BRANCH NAME: CENTRAL/STANLEY MOSK. CASE NAME: JOHNSON v COUNTY OF LOS ANGELES CASE NUMBER: BC683552 VEARNGDATE April 6, 2018 vert: 52 me: 8:30 a.m. DECLARATION IN SUPPORT OF ATTORNEY'S BEFORE HON. MOTION TO BE RELIEVED AS COUNSEL—CIVIL Susan Bryant-Deason pare actionrieo: 11/20/2017 rriat oate: Not Set 1. Attorney and Represented Party. Attorney (name): Joseph M. Lovretovich; Eric J. Palmer; Christina ay analo is presently counsel of record for (name of party): in the above-captioned action or proceeding. Stacy Johnson (ee Z Bi\CESD] 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): There has been an irreconcilable breakdown in the attorney-client relationship such that the attorney can no longer effectively represent the client's interest. Further elaboration of this point would be in violation of the attorney-client privilege. Plaintiffs counsel will elaborate further in camera at the hearing, if necessary. [[) 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) LZ} 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) confirmed within the past 30 days that the address is current (a) [_] by mail, return receipt requested. eS=} (b) __] by telephone. (c) L_] by conversation. (d) by other means (specify): confirmation via electronic mail. Pi ey eo (Continued on reverse) Page 1 of 2 Form Adopted for Mandatory Use of Civil Procedure, § 284; Judicial Council of Calfomia DECLARATION IN SUPPORT OF ATTORNEY'S Cal. Rules of Court, rule 3.1362 -052 (Rev. January 1, 2007] MOTION TO BE RELIEVED AS COUNSEL—CIVIL www.courtinfo.ca.gov