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  • ANA CORDON VS SEAN XIA M D ET AL Medical Malpractice - Physicians & Surgeons (General Jurisdiction) document preview
  • ANA CORDON VS SEAN XIA M D ET AL Medical Malpractice - Physicians & Surgeons (General Jurisdiction) document preview
						
                                

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Electronically FILED by Superior Court of California, County of Los Angeles on 05/20/2022 04:20 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk IIC-052 ATTORNEY OR PARTY WITHOUT ATTORNEY (slams, state Par numtmn and sddiessf: FOR COURT USE ONLY David Azizi, Esq. SBN 198803 LAW OFFICES OF DAVID AZIZI 3435 Wilshire Blvd., Suite 1800 Los Angeles, CA 90010 TELEIHoHENo. 310-284-9600 FANNO. 888-400-8944 ATTDRNEYFDR (Name). Plaintiff, Ana COrdOn NAME oF coURT; Spring Street Courthouse sTREETADDREss 312 N. Spring Street MAILING Angeles, CA 90012 ADDRESS'nYANDZIPDCDE'os BRANGH NAME'entral Civil ff(fvriA/&SmkWSS l 1 /(MVQI GAsE NAME: Ana Cordon v. Sean Xia, MD., et. al. HEARING DATE. (P (lf ( Za OEPr 3I TIME I:30 p.m. DECLARATION IN SUPPORT OF ATTORNEY'S BEFORE HONc IIOTION TO BE RELIEVED AS COUNSEL—CIVIL DATE ACTION FILED: 01/30/18 TRIAL DATE I I /02/2022 1. Attorney and Represented Party. Attorney (name): David Azizi, Esq. is presently counsel of record for (nsme of periy)( Ana Cordon in the above-ceplioned 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 e consent under section 284(1) for the following reasons (describe): There has been irreconcilable differences of opinion between Plaintiff and PlaintifFs counsel leading to a complete breakdown in the attorney-client relationship. Specifically, certain significant issues surfaced related to the prosecution of this case, which to date remain unresolved. Current counsel and plaintiff are at an impasse with respect to these issues. Consequently, a dispute has arisen as to whether plaintiffs counsel can proceed as attorney of record. The issues in question are fundamental and crucial to the outcome of this case. Therefore it is respectfully submitted that attorneys be relieved as counsel of record due to Justifiable cause. Present counsels has informed Plaintiff of this position and have requested Plaintiff agree to relieve counsel due to Justifiable cause. Plaintiff, however has been unresponsive to this request, thereby requiring the instant motion. M Continued on Attachment 2. 3. Service a. Attorney has (1) M 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) C/3 served the client by mail at the dient's last known address with copies of the motion papers served with this dedaration. b. If the dieni hes been served by mail ai the client's last known address, attorney hes (1) H3 confirmed within the past 30 days that the address is current (a) ~ ~by mail, return receipt requested. (b) (c) (d) ~V ~by telephone. by conversation. by other means (specify): mail. (continued on reverse) Page 1 of 2 Form Adopted for Mandatoir Use Code of Civil Pfocedum, E 2aa: Judidal Council of Calfomm DECLARATION IN SUPPORT OF ATTORNEY'S Cal. Rules of Court, rule 3.1362 MC JM2 )Rav. Januaff I, 2COT) MOTION TO BE RELIEVED AS COUNSEL— CIVIL Ivww coisenfo oe oov