On February 13, 2020 a
449519.1682839.mc051
was filed
involving a dispute between
Pavletich Electric & Communications, Inc.,
Zurich American Insurance Company,
and
Pavletich Electric & Communications, Inc.,
for 23-CV Other PI/PD/WD - Civil Unlimited
in the District Court of Kern County.
Preview
MC-051
ATIORNEY OR PARTY WITHOUT ATIORNEY (Name, slate bar number, and address): FOR COURT USE ONLY
ERNEST A. VARGAS (State Bar# 36623)
-LAW OFFICES OF VARGAS & VARGAS
301 N. LAKE AVENUE, SUITE 120
PASADENA, CALIFORNIA 91101
TELEPHONENO.: (626) 440-1111 FAXNO.: (626) 440-9456
AnoRNEY FoR (Name): Plaintiff-in-Intervention Hugo Gomez
NAMEOFCOURT: KERN COUNTY SUPERIOR COURT
STREET ADDRESS: 1415 TRUXTUN A VENUE
MAILING ADDRESS:
CITY AND ZIP CODE: BAKERSFIELD, CALIFORNIA 93301
BRANcH NAME: Metropolitan Division
CASE NAME: CASE NUMBER:
ZURICH AMERICAN INSURANCE VS. PAVLETIC ELECTRIC et al BCV-20-100473
HUGO GOMEZ VS PAVLETICH ELECTRIC, et al; October 9, 2023 HEARING DATE:
DEPT.: 17 TIME: 8:30 a.m.
NOTICE OF MOTION AND MOTION
TO BE RELIEVED AS BEFoRe HON.: Thomas S. Clark
COUNSEL-CIVIL DATE ACTION FILED: June 23, 2020
TRIAL DATE: February 20, 2024
TO (name and address of client): HUGO GOMEZ, 1025 Mable A venue, Bakersfield, California 93307
1. PLEASE TAKE NOTICE that (name of withdrawing attorney): Ernest A. Vargas of the Law Offices of Vargas & Vargas
moves under California Code of Civil Procedure section 284(2) and California Rules of Court, rule 3.1362, for an order permitting
the attorney to be relieved as attorney of record in this action or proceeding.
2. A hearing on this motion to be relieved as counsel will be held as follows:
a. Date: October 9, 2023 Time: 8:30 a.m. Dept.: 17 Room:
b. The address of the court: 1Z1 same as noted above ~ other (specify):
3. This motion is supported by the accompanying declaration, the papers and records filed in this action or proceeding, and
the following additional documents or evidence (specify):
An irremediable breakdown has occurred in the Attorney-Client relationship which is beyond repair.
Moving party can provide additional specifics in chambers.
(This motion does not need to be accompanied by a memorandum of points and authorities. Cal. Rules of Court, rule 3. 1362.)
4. The client presently represented by the attorney is
a. IZJ
an individual. g. ~a trustee.
b. c=J
a corporation. h. c=J
a personal representative.
c. c=J
a partnership. i. c=J
a probate fiduciary.
d. c=J
an unincorporated association. j. ~ a guardian ad litem.
e. ~ a guardian. k. ~ other (specify):
f. ~ a conservator.
(Continued on reverse) Pa e 1 of2
Form Adopted for Mandatory Use Code of Civil Procedure , § 284;
Judicial Council of California NOTICE OF MOTION AND MOTION Cal. Rules of Court, rule 3.1362
MC.051 [Rev. January 1, 2007] TO BE RELIEVED AS COUNSEL-CIVIL www.courtinfo.ca.gov
MC-051
CASE NAME: CASE NUMBER:
r-ZURICH AMERICAN INSURANCE VS. PAVLETIC ELECTRIC et al BCV-20-100473
NOTICE TO CLIENT
If this motion to be relieved as counsel is granted, your present attorney will no longer be representing you . You
may not in most cases represent yourself if you are one of the parties on the following list:
• A guardian • A personal representative • A guardian ad litem
• A conservator • A probate fiduciary • An unincorporated association
• A trustee • A corporation
If you are one of these parties, YOU SHOULD IMMEDIATELY SEEK LEGAL ADVICE REGARDING LEGAL
REPRESENTATION. Failure to retain an attorney may lead to an order striking the pleadings or to the entry of a
default judgment.
5. If this motion is granted and a client is representing himself or herself, the client will be solely responsible for the case.
NOTICE TO CLIENT WHO WILL BE UNREPRESENTED
If this motion to be relieved as counsel is granted, you will not have an attorney representing you. You may wish to
seek legal assistance. If you do not have a new attorney to represent you in this action or proceeding, and you are
legally permitted to do so, you will be representing yourself. It will be your responsibility to comply with all court
rules and applicable laws. If you fail to do so, or fail to appear at hearings, action may be taken against you. You may
lose your case.
6. If this motion is granted, the client must keep the court informed of the client's current address.
NOTICE TO CLIENT WHO WILL BE UNREPRESENTED
If this motion to be relieved as counsel is granted, the court needs to know how to contact you. If you do not keep the
court and other parties informed of your current address and telephone number, they will not be able to send you
notices of actions that may affect you, including actions that may adversely affect your interests or result in your
losing the case.
Date: SEPTEMBER 18, 2023
ERNEST A. VARGAS
(TYPE OR PRINT NAME)
gornez
MC-{)51 [Rev. January 1. 2007) Page 2 of 2
NOTICE OF MOTION AND MOTION
TO BE RELIEVED AS COUNSEL-CIVIL
Document Filed Date
September 18, 2023
Case Filing Date
February 13, 2020
Category
23-CV Other PI/PD/WD - Civil Unlimited
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MC-051 ATIORNEY OR PARTY WITHOUT ATIORNEY (Name, slate bar number, and address): FOR COURT USE ONLY ERNEST A. VARGAS (State Bar# 36623) -LAW OFFICES OF VARGAS & VARGAS 301 N. LAKE AVENUE, SUITE 120 PASADENA, CALIFORNIA 91101 TELEPHONENO.: (626) 440-1111 FAXNO.: (626) 440-9456 AnoRNEY FoR (Name): Plaintiff-in-Intervention Hugo Gomez NAMEOFCOURT: KERN COUNTY SUPERIOR COURT STREET ADDRESS: 1415 TRUXTUN A VENUE MAILING ADDRESS: CITY AND ZIP CODE: BAKERSFIELD, CALIFORNIA 93301 BRANcH NAME: Metropolitan Division CASE NAME: CASE NUMBER: ZURICH AMERICAN INSURANCE VS. PAVLETIC ELECTRIC et al BCV-20-100473 HUGO GOMEZ VS PAVLETICH ELECTRIC, et al; October 9, 2023 HEARING DATE: DEPT.: 17 TIME: 8:30 a.m. NOTICE OF MOTION AND MOTION TO BE RELIEVED AS BEFoRe HON.: Thomas S. Clark COUNSEL-CIVIL DATE ACTION FILED: June 23, 2020 TRIAL DATE: February 20, 2024 TO (name and address of client): HUGO GOMEZ, 1025 Mable A venue, Bakersfield, California 93307 1. PLEASE TAKE NOTICE that (name of withdrawing attorney): Ernest A. Vargas of the Law Offices of Vargas & Vargas moves under California Code of Civil Procedure section 284(2) and California Rules of Court, rule 3.1362, for an order permitting the attorney to be relieved as attorney of record in this action or proceeding. 2. A hearing on this motion to be relieved as counsel will be held as follows: a. Date: October 9, 2023 Time: 8:30 a.m. Dept.: 17 Room: b. The address of the court: 1Z1 same as noted above ~ other (specify): 3. This motion is supported by the accompanying declaration, the papers and records filed in this action or proceeding, and the following additional documents or evidence (specify): An irremediable breakdown has occurred in the Attorney-Client relationship which is beyond repair. Moving party can provide additional specifics in chambers. (This motion does not need to be accompanied by a memorandum of points and authorities. Cal. Rules of Court, rule 3. 1362.) 4. The client presently represented by the attorney is a. IZJ an individual. g. ~a trustee. b. c=J a corporation. h. c=J a personal representative. c. c=J a partnership. i. c=J a probate fiduciary. d. c=J an unincorporated association. j. ~ a guardian ad litem. e. ~ a guardian. k. ~ other (specify): f. ~ a conservator. (Continued on reverse) Pa e 1 of2 Form Adopted for Mandatory Use Code of Civil Procedure , § 284; Judicial Council of California NOTICE OF MOTION AND MOTION Cal. Rules of Court, rule 3.1362 MC.051 [Rev. January 1, 2007] TO BE RELIEVED AS COUNSEL-CIVIL www.courtinfo.ca.gov MC-051 CASE NAME: CASE NUMBER: r-ZURICH AMERICAN INSURANCE VS. PAVLETIC ELECTRIC et al BCV-20-100473 NOTICE TO CLIENT If this motion to be relieved as counsel is granted, your present attorney will no longer be representing you . You may not in most cases represent yourself if you are one of the parties on the following list: • A guardian • A personal representative • A guardian ad litem • A conservator • A probate fiduciary • An unincorporated association • A trustee • A corporation If you are one of these parties, YOU SHOULD IMMEDIATELY SEEK LEGAL ADVICE REGARDING LEGAL REPRESENTATION. Failure to retain an attorney may lead to an order striking the pleadings or to the entry of a default judgment. 5. If this motion is granted and a client is representing himself or herself, the client will be solely responsible for the case. NOTICE TO CLIENT WHO WILL BE UNREPRESENTED If this motion to be relieved as counsel is granted, you will not have an attorney representing you. You may wish to seek legal assistance. If you do not have a new attorney to represent you in this action or proceeding, and you are legally permitted to do so, you will be representing yourself. It will be your responsibility to comply with all court rules and applicable laws. If you fail to do so, or fail to appear at hearings, action may be taken against you. You may lose your case. 6. If this motion is granted, the client must keep the court informed of the client's current address. NOTICE TO CLIENT WHO WILL BE UNREPRESENTED If this motion to be relieved as counsel is granted, the court needs to know how to contact you. If you do not keep the court and other parties informed of your current address and telephone number, they will not be able to send you notices of actions that may affect you, including actions that may adversely affect your interests or result in your losing the case. Date: SEPTEMBER 18, 2023 ERNEST A. VARGAS (TYPE OR PRINT NAME) gornez MC-{)51 [Rev. January 1. 2007) Page 2 of 2 NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL-CIVIL