No Value: Valera vs Foppiano

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                                FOR COURT USE ONLY
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                                                                                                                                      MC 052
 ATTORNEY OR PARTY WITHOUT ATTORNEY (Nem0, stale bar number, and address):
 Gregmy P. Wayland (SBN: 277437)
 Attorneys Real Estate Group, APC
 905 Highland Pointe Drive, Suite 100
 Roseville, CA 95678
      TELEPHONE NO.: 916-671-3138     FAX NO.:

ATTORNEY FOR (Name): Susan Foppiano Valera

     NAME OF COURT: Sonoma Superior Court

    STREET ADDRESS: 600 Administrative Drive

    MAILING ADDRESS:

   CITY AND ZIP CODE:     Santa Rosa 95403
        BRANCH NAME:      Hall of Justice
                                                                                             CASE NUMBER:
CASE NAME:          Susan Foppiano Valera v. Louis M. Foppiano, et al.                                        SCV-269355
                                                                                              HEARING DATE:

                                                                                              DEPT.:                 TIME:
                       DECLARATION IN SUPPORT OF ATTORNEY'S                                   BEFORE HON.:
                      MOTION TO BE RELIEVED AS COUNSEL-CIVIL                                  DATE ACTION FILED:

                                                                                             TRIAL DATE·


1. Attorney and Represented Party. Attorney (name): Greg my P. Wayland
   is presently counsel of record for (name of party): Susan Foppiano Valera
   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):
   Client( s) is/are in substantial breach of agreement for legal services. Multiple opportunities to cure.
   (State Bar Rule l.16(b)(4) and (5)).

   Inability to effectively work with the client (State Bar Rule l .16(b)(4) render withdrawal necessary.

   Notice and opportunitites to cure are longstanding; opportunity to avoid motion provided multiple times
   via email, mail, and docusign to valid and current contact both electronic and physical addresses.
   Counsel has fully complied with CRC 3.1362 and CCP 284(1 ).


    D      Continued on Attachment 2.

3. Service
   a. Attorney has
       (1) D      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) 0      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) 0      confirmed within the past 30 days that the address is current
                  (a)D by mail, return receipt requested.
                  (b)W by telephone.
                  (c) D      by conversation.
                  {d) D by other means (specify):




                                                                    (Continued on reverse)
                                                                                                                                       Page 1 of 2
                                                                                                                      Code of Civil Procedure,§ 284;
 FoTt]lc1~fb~t~~1~f~~1i}~%1~se                  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.courlinfo.ca.gov
                                                                                                                                     MC-052
 CASE NAME:                                                                                         CASE NUMBER:

 Susan Foppiano Valera v. Louis M. Foppiano, et al.                                                                SCV-269355

3. b. (2)     D       been unable to confirm that the address Is current or to locate a more current address for the client after making the
                      following efforts:
                      (a) D malling the motion papers to the client's last known address, return receipt requested.
                      (b)   D   calling the client's last known telephone number or numbers.
                      (c)   D   contacting persons familiar with the client (specify):

                      (d)   D     conducting a search (describe):

                      (e) D       other (specify):

   c. Even if attorney has been unable to serve the client with the moving papers, the court should grant attorney's motion to be
      relieved as counsel of record (explain):
         Undue hardship on Firm, inability to effectively work with the client(s), render withdrawal necessary.


4. The next hearing scheduled in this action or proceeding
   a. D     is not yet set.
   b.    0  is set as follows (specify the date, time, and place):
                 Case Management Conference, December 12, 2023, at 3:00 p.m., Dept. 18
    c.   D       concerns (describe the subject matter of the hearing):


    D        Continued on Attachment 4.


5. The following additional hearings and other proceedings (including discovery matters) are presently scheduled in this case (for each,
   describe the date, time, place, and subject matter):




    D        Continued on Attachment 5.

6. Trial in this action or proceeding
   a. 0       is not yet set.
   b. D       is set as follows (specify the date, time, and place):

7. other. Other matters that the court should consider in determining whether to grant this motion are the following (explain):




I declare under penalty of perjury under the laws of the State of California that the
Date: November 7, 2023



Gregory P. Wayland
                                {TYPE OR PRINT NAME)                                                  SIGNATURE OF DECLARANli)

8. Number of pages attached: _ __

MC-052 [Rev. January 1, 2007]
                                                                                                                                      Page 2 of2
                                                   DECLARATION IN SUPPO
                                                  MOTION TO BE RELIEVED