On July 29, 2015 a
Motion-Secondary
was filed
involving a dispute between
Bailey Tory,
and
for Decedent's Estate (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 1/7/2019 10:36 AM Sherri R. Carter, Executive Officer/Clerk, By M. Bansil, Deputy Clerk
MC-052
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state Dar number, and address): FOR COURT USE ONLY
C. Keila Nakasaka, Esq. (SBN. 186520)
ADVANCED LEGAL GROUP
16306 Hawthorne Blvd.
Lawndale, CA 90260
everione no: (310) 921-3120 raxno, (310) 921-2369
ATTORNEY FOR (Name): Petitioner: Tory Baile
nave oF court: Superior Court of the State of California
street aporess: 191 N. Hill St.
waitin aopress: Same as above
crry ano zp cone: Los Angeles, CA 90012
srancH nave: Central Judicial District
CASE NAME: CASE NUMBER:
LA SONYA RENEE ARMSTRONG BP 165 175
nearinc pave, 2/27/2019
DEPT: 5 me: 10:00a.m.
DECLARATION IN SUPPORT OF ATTORNEY'S
BEFORE HON.: Michael C. Small
MOTION TO BE RELIEVED AS COUNSEL-CIVIL
paTeaction Fics: July 29, 2015
‘RIA, DATE:
Attorney and Represented Party. Aitorney (name): C. Keila Nakasaka
is presently counsel of record for (name of party): Tory Bailey
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):
Attorney is unable to effectively assist Mr. Bailey. Mr. Bailey has a habit of dissappearing and then reappearing
when it is convenient for him. Client is uncooperative. Attorney has e-mailed Mr. Bailey on several occasions
requesting information needed to complete paperwork (See attached Exhibit "A"- E-mails to Mr. Bailey). Mr.
Bailey has only responded once to the e-mails sent to him. In his e-mail, he stated that he will look for the paper
work, Attorney has done her due diligence to try to work effectively with Mr. Bailey, but Mr. Bailey refuses to
cooperate.
Furthermore, as of December 6, 2018, Mr. Bailey's phone is out of service. Mr. Bailey has not contacted the office
to provide his new phone number.
[2] 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) [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 lasi known address, attorney has
(1) (CJ confirmed within the past 30 days that the address is current
(a) CD by mail, return receipt requested.
(b) (CY by telephone.
(c) [LJ by conversation.
(d) (CY by other means (specify):
{Continued on reverse) Page 1 of 2
Form Adog ed for Mandatory Use
Judiciak B cuneil of Californie DECLARATION IN SUPPORT OF ATTORNEY'S Code of Civit Procedure, § 284:
Cal. Rules of Court, rule 3.1962
MC-052 (Rev. January #, 2007] MOTION TO BE RELIEVED AS COUNSEL-CIVIL couitinio.ca.gov
CEB’| Essential
cebeom | .2/Forms:
Document Filed Date
January 07, 2019
Case Filing Date
July 29, 2015
Category
Decedent's Estate (General Jurisdiction)
Status
Under Court Supervision 04/30/2016
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Electronically FILED by Superior Court of California, County of Los Angeles 1/7/2019 10:36 AM Sherri R. Carter, Executive Officer/Clerk, By M. Bansil, Deputy Clerk MC-052 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state Dar number, and address): FOR COURT USE ONLY C. Keila Nakasaka, Esq. (SBN. 186520) ADVANCED LEGAL GROUP 16306 Hawthorne Blvd. Lawndale, CA 90260 everione no: (310) 921-3120 raxno, (310) 921-2369 ATTORNEY FOR (Name): Petitioner: Tory Baile nave oF court: Superior Court of the State of California street aporess: 191 N. Hill St. waitin aopress: Same as above crry ano zp cone: Los Angeles, CA 90012 srancH nave: Central Judicial District CASE NAME: CASE NUMBER: LA SONYA RENEE ARMSTRONG BP 165 175 nearinc pave, 2/27/2019 DEPT: 5 me: 10:00a.m. DECLARATION IN SUPPORT OF ATTORNEY'S BEFORE HON.: Michael C. Small MOTION TO BE RELIEVED AS COUNSEL-CIVIL paTeaction Fics: July 29, 2015 ‘RIA, DATE: Attorney and Represented Party. Aitorney (name): C. Keila Nakasaka is presently counsel of record for (name of party): Tory Bailey 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): Attorney is unable to effectively assist Mr. Bailey. Mr. Bailey has a habit of dissappearing and then reappearing when it is convenient for him. Client is uncooperative. Attorney has e-mailed Mr. Bailey on several occasions requesting information needed to complete paperwork (See attached Exhibit "A"- E-mails to Mr. Bailey). Mr. Bailey has only responded once to the e-mails sent to him. In his e-mail, he stated that he will look for the paper work, Attorney has done her due diligence to try to work effectively with Mr. Bailey, but Mr. Bailey refuses to cooperate. Furthermore, as of December 6, 2018, Mr. Bailey's phone is out of service. Mr. Bailey has not contacted the office to provide his new phone number. [2] 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) [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 lasi known address, attorney has (1) (CJ confirmed within the past 30 days that the address is current (a) CD by mail, return receipt requested. (b) (CY by telephone. (c) [LJ by conversation. (d) (CY by other means (specify): {Continued on reverse) Page 1 of 2 Form Adog ed for Mandatory Use Judiciak B cuneil of Californie DECLARATION IN SUPPORT OF ATTORNEY'S Code of Civit Procedure, § 284: Cal. Rules of Court, rule 3.1962 MC-052 (Rev. January #, 2007] MOTION TO BE RELIEVED AS COUNSEL-CIVIL couitinio.ca.gov CEB’| Essential cebeom | .2/Forms: