On January 30, 2023 a
Motion-Secondary
was filed
involving a dispute between
Hernandez Martinez, Martha Alicia,
and
Does 1-25, Inclusive,
Fleet Services Inc.,
Morales, John,
for Auto PI/PD/WD Unlimited
in the District Court of San Bernardino County.
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MC—052
FOR COURT USE ONLY
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State bar number, and address):
Ardy Pirnia, Esq. (SBN: 288805)
Brankica Balaban - Calvignac, Esq. (SBN:3 l 8248)
THE PIRNIA LAW GROUP F I L E
SUPERIOR COURT 0F CALnFORNIA
8549 Wilshire B1Vd., Suite 1193, Beverly Hills California 90211 COUNTY OF SAN BERNARmNO
— 3010 SAN BERNARDINO DISTRICT
TELEPHONE No; (844) 747 - 5294 FAX N0: (213) 986
ATTORNEY FOR (Name): MARTHA ALICIA HERNANDEZ MARTINEZ
FEB 05
m5m—
20215
NAME 0F COURT: SAN BERNARDINO SUPERIOR COURT
STREET ADDRESS: 247 West 3rd Street ‘
MAiLING ADDRESS: 247 West 3rd Street .
CITY AND ZIP CODE: San Bemardino, CA 92415 " o' \"Pmueva
-~ Dem“ y .
.
BRANCH NAME: Justice Center
CASE NUMBER:
CASE NAME: and DOES 1-25 inclusive CIVSB2303547
MARTHA ALICIA HERNANDEZ MARTINEZ v, JOHN MORALES, FLEET SERVICES, INC.
HEARING DATE: 02/22/2024
DEPT; R 17 TIME: 081303111
DECLARATION IN sup P ORT 0F A TTORNEY s
'
BEFORE HON" .
Tony Raphael \g
A
MOTION To BE RELIEVED As COUNSEL—CIVIL DATE ACTION FILED: 01/30/2023 7
TRIAL DATE None {‘2
1. Attorney and Represented Party. Attorney (name): Ardy Pimia, Esq. /The Pirnia Law Group
i5 presently counsel 0f record for (name OfpafTY)“ MARTHA ALICIA HERNANDEZ MARTINEZ
in the above-captioned action or proceeding.
Code Procedure section 284(2) instead
for Motion. Attorney makes this motion to be relieved as counsel under
of Civil
2. Reasons
of filing a consent under section 284(1) for the following reasons (describe):
There has been a breakdown of the working relationship. The specific facts which given
rise t0 this
Motion are confidential and required to be kept confidential pursuant to Business and Professions Code
Section 6068(6), rule 3-100(A), California Rules 0f Professional Conduct, and by the
attorney-client
privilege (Evidence Code Section 950, et seq). In the event that this court desires further information to
motion and for withdrawal, it is respectfully requested that the court
ascertain the good faith basis for this
allows oral arguments to all the parties involved in the case.
E Continued on Attachment 24
3. Service
Attorney has
D
a.
declaration. A copy ofthe proof of service
(1) personally served the client with copies of the motion papers filed with this
will be filed with the court at least 5 days before the hearing.
served the client by mail at the client's last known address with copies of the motion
papers served with this declaration.
(2)
b. lfthe client has been served by mail at the client's last known address, attorney has
confirmed within the past 30 days that the address is current
(1)
(a) D
by mail, return receipt requested.
(mm bytelephone.
(c)
(d)
E by conversation.
by other means (specify):
Skip Trace
(Continued on reverse)
Page 1 of 2
Code of Civil Procedure‘ § 284:
Fm“ Adw‘edfmmandam” U“
Judicial Council of California
DECLARATION IN SUPPORT OF ATTORNEY'S w Wes ofCOUn' Me 31362
MC‘OSZIRev- Januaw 1. 20°71
MOTION To BE RELIEVED As COUNSEL—CIVIL www.counmrocagov
MC—052
CASE NUMBER:
CASE NAME:
MARTHA ALICIA HERNANDEZ MARTINEZ v. JOHN MORALES, FLEET SERVICES, INC. and DOES 1-25 inclusive CIVS 823 03 547
3. b. (2) D been unable to confirm thatthe address is current or to locate a more current address for the client after making the
(a) D
following efforts:
D mailing the motion papers to the client's last
calling the client's last
known address,
known telephone number or numbers.
return receipt requested.
(b)
(c) D contacting persons familiarwith the client (specify):
(d) E conducting a search (describe):
(e) D other (specify):
attorney's motion t0 be
c. Even if attorney has been unable to serve the client with the moving papers, the court should grant
relieved as counsel of record (explain):
The next hearing scheduled in this action or proceeding
4.
D
3A
bv
is
is
not yet set.
set as follows (specify the date, time, and place):
R
E
C-
02/22/2024, 08:30 Department
concerns (describe the subjectmatter of the hearing):
Motion to be Relieved as Counsel
17
E Continued on Attachment 4.
are presently scheduled in this case (for each,
5. The following additional hearings and other proceedings (including discovery matters)
describe the date, time, place, and subject matter):
[j Continued on Attachment 5.
6. Trial in this action or proceeding
a.
b. D is
is
notyetset.
set as follows (specifythe date, time, and place):
7. Other. Other matters that the court should consider in determining whether to grant this motion are the following (explain):
the foregoing true and correct.
declare under penalty of perjury under the |aws of the State of California that
is
|
Date: 02/02/2024
Ardy Pirnia, Esq.
(SIGNATURE OF DECLARANT)
(TYPE OR PRINT NAME)
8. Number of pages attached:
Page 2 °”
MC'OWGV- Jaw 1- 20°71
DECLARATION IN SUPPORT 0F ATTORNEY'S
MOTION TO BE RELIEVED AS COUNSEL—CIVIL
Document Filed Date
February 05, 2024
Case Filing Date
January 30, 2023
Category
Auto PI/PD/WD Unlimited
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MC—052 FOR COURT USE ONLY ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State bar number, and address): Ardy Pirnia, Esq. (SBN: 288805) Brankica Balaban - Calvignac, Esq. (SBN:3 l 8248) THE PIRNIA LAW GROUP F I L E SUPERIOR COURT 0F CALnFORNIA 8549 Wilshire B1Vd., Suite 1193, Beverly Hills California 90211 COUNTY OF SAN BERNARmNO — 3010 SAN BERNARDINO DISTRICT TELEPHONE No; (844) 747 - 5294 FAX N0: (213) 986 ATTORNEY FOR (Name): MARTHA ALICIA HERNANDEZ MARTINEZ FEB 05 m5m— 20215 NAME 0F COURT: SAN BERNARDINO SUPERIOR COURT STREET ADDRESS: 247 West 3rd Street ‘ MAiLING ADDRESS: 247 West 3rd Street . CITY AND ZIP CODE: San Bemardino, CA 92415 " o' \"Pmueva -~ Dem“ y . . BRANCH NAME: Justice Center CASE NUMBER: CASE NAME: and DOES 1-25 inclusive CIVSB2303547 MARTHA ALICIA HERNANDEZ MARTINEZ v, JOHN MORALES, FLEET SERVICES, INC. HEARING DATE: 02/22/2024 DEPT; R 17 TIME: 081303111 DECLARATION IN sup P ORT 0F A TTORNEY s ' BEFORE HON" . Tony Raphael \g A MOTION To BE RELIEVED As COUNSEL—CIVIL DATE ACTION FILED: 01/30/2023 7 TRIAL DATE None {‘2 1. Attorney and Represented Party. Attorney (name): Ardy Pimia, Esq. /The Pirnia Law Group i5 presently counsel 0f record for (name OfpafTY)“ MARTHA ALICIA HERNANDEZ MARTINEZ in the above-captioned action or proceeding. Code Procedure section 284(2) instead for Motion. Attorney makes this motion to be relieved as counsel under of Civil 2. Reasons of filing a consent under section 284(1) for the following reasons (describe): There has been a breakdown of the working relationship. The specific facts which given rise t0 this Motion are confidential and required to be kept confidential pursuant to Business and Professions Code Section 6068(6), rule 3-100(A), California Rules 0f Professional Conduct, and by the attorney-client privilege (Evidence Code Section 950, et seq). In the event that this court desires further information to motion and for withdrawal, it is respectfully requested that the court ascertain the good faith basis for this allows oral arguments to all the parties involved in the case. E Continued on Attachment 24 3. Service Attorney has D a. declaration. A copy ofthe proof of service (1) personally served the client with copies of the motion papers filed with this will be filed with the court at least 5 days before the hearing. served the client by mail at the client's last known address with copies of the motion papers served with this declaration. (2) b. lfthe client has been served by mail at the client's last known address, attorney has confirmed within the past 30 days that the address is current (1) (a) D by mail, return receipt requested. (mm bytelephone. (c) (d) E by conversation. by other means (specify): Skip Trace (Continued on reverse) Page 1 of 2 Code of Civil Procedure‘ § 284: Fm“ Adw‘edfmmandam” U“ Judicial Council of California DECLARATION IN SUPPORT OF ATTORNEY'S w Wes ofCOUn' Me 31362 MC‘OSZIRev- Januaw 1. 20°71 MOTION To BE RELIEVED As COUNSEL—CIVIL www.counmrocagov MC—052 CASE NUMBER: CASE NAME: MARTHA ALICIA HERNANDEZ MARTINEZ v. JOHN MORALES, FLEET SERVICES, INC. and DOES 1-25 inclusive CIVS 823 03 547 3. b. (2) D been unable to confirm thatthe address is current or to locate a more current address for the client after making the (a) D following efforts: D mailing the motion papers to the client's last calling the client's last known address, known telephone number or numbers. return receipt requested. (b) (c) D contacting persons familiarwith the client (specify): (d) E conducting a search (describe): (e) D other (specify): attorney's motion t0 be c. Even if attorney has been unable to serve the client with the moving papers, the court should grant relieved as counsel of record (explain): The next hearing scheduled in this action or proceeding 4. D 3A bv is is not yet set. set as follows (specify the date, time, and place): R E C- 02/22/2024, 08:30 Department concerns (describe the subjectmatter of the hearing): Motion to be Relieved as Counsel 17 E Continued on Attachment 4. are presently scheduled in this case (for each, 5. The following additional hearings and other proceedings (including discovery matters) describe the date, time, place, and subject matter): [j Continued on Attachment 5. 6. Trial in this action or proceeding a. b. D is is notyetset. set as follows (specifythe date, time, and place): 7. Other. Other matters that the court should consider in determining whether to grant this motion are the following (explain): the foregoing true and correct. declare under penalty of perjury under the |aws of the State of California that is | Date: 02/02/2024 Ardy Pirnia, Esq. (SIGNATURE OF DECLARANT) (TYPE OR PRINT NAME) 8. Number of pages attached: Page 2 °” MC'OWGV- Jaw 1- 20°71 DECLARATION IN SUPPORT 0F ATTORNEY'S MOTION TO BE RELIEVED AS COUNSEL—CIVIL