Document for Christopher Smith vs Mark Jones, et al

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                                MC-052
     ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, stale bar number, and address):                                        FOR COURT USE ONLY
     William B. DeClereq (SBN 240538)
     DeClercq Law, P.C.
     440 N. Barranca Ave., #1177
     Covina, CA 91723
         ‘TELEPHONE NO. (626)408-2150            FAX NO.
 ATTORNEY FOR (Name):         Defendants Future 2 Labs, LLC, et al
           NAME OF COURT:      Superior Court of California County of Santa Cruz
         ‘STREET ADDRESS:     701 Ocean St., Room              110
        MAILING ADDRESS:      (same)
       CITY AND ZIP CODE:      Santa Cruz 95060
            BRANCH NAME:       Santa Cruz Branch
     CASE NAME:         Christopher Smith v Future 2 Labs, LLC, et al                                 CASE NUMBER:
                                                                                                                       20CV01307
                                                                                                      Hearine paTE:     March 27, 2024
                                                                                                      vert:   10             TIME: 8:30
                             DECLARATION IN SUPPORT OF ATTORNEY’                                      BEFORE HON.
                            MOTION TO BE RELIEVED AS COUNSEL—CIVIL
                                                                                                      DATE ACTION FILED:
                                                                                                      TRIAL DATE:
1. Attorney and Represented Party. Attorney (name):                         William B. DeClercq
      is presently counsel of record for (name of party):             Future2 Labs Health Services, LLC
      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):
      There has been a breakdown. in the attorney-client relationship which requires withdrawal by counsel.

                                                fe
      The specific facts which ive rise to this motion are confidential and required to be kept confidential
       pursuant to Business Pro: ssions Code 6068 (e), rule 3-100 (A), California Rules of Professional
       Conduct, and by the attomey-client privilege (Evid.C 950, et seq.) In the event that this desires further
       information to ascertain the good faith basis for this motion and for withdrawal, it is respectfully
       requested that the court have an in camera hearing outside of the presence of all other parties so that the
       specific facts demonstrating good cause for this withdrawal may be demonstrated to the court. (Manfredi
       & Levine v. Superior Court (1998) 66 Cal.App.4th 1128, 1136-1137; 3-700(B) or (C))



       [J     Continued on Attachment 2.

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




                                                                        (Continued on reverse)
                                                                                                                                              Page 1 of 2
 Form Adopted for Mandatory Use
   ‘Judicial Council of California                    DECLARATION IN SUPPORT OF ATTORNEY‘:                                    Code of Gil Procedure, § 284
  MC-052 [Rev. January1, 2007]                                                                                                Cal. Rules of Court, rule 3.1362
                                                     MOTION TO BE RELIEVED AS COUNSEL—CIVIL                                              www.courtinfo.ca.gov
MC-052
  CASE NAME:                                                                                           CASE NUMBER:
  Christopher Smith v Future 2 Labs, LLC, et al                                                                       20CV01307

3. b. (2)                een unable to confirm that the address is current or to locate a more current address for the client after making the
                       following efforts:
                        (a)      mailing the motion papers to the client's last known address, return receipt requested.
                        (b)      calling the client's last known telephone number or numbers.
                        (c)      contacting persons familiar with the client (specify):
                                 Mark Jones and Ramie Tritt
                        (d) []   conducting a search (describe):

                        (e) [_] 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):

                                                                            d
         The corporation has closed its doors and no lon jer operating. However, the individuals formerly
         associated with the business have been informet and acknowledged the withdrawal of counsel.
     The next hearing scheduled in this action or proceeding
     a. [__] is not yet set.
                   is set as follows (specify the date, time, and place):
                   March 27, 2024, 8:30 a.m., Department 10
     c. LW] concerns (describe the subject matter of the hearing):
           Motion to Enforce Settlement
     [1] Continued on Attachment 4.

     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):




     [5] Continued on Attachment 5.
     Trial in this action or proceeding
     a.          is not yet set.
     >. 4          is set as follows (specify the date, time, and place):

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




| declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: February 20, 2024
                                                                                          /   p ff              A       “
                                                                                                                      L ec
William B. DeClereq
                  (TYPE OR PRINT NAME)                                                                 (SIGNATURE OF DECLARANT)
8. Number of pages attached:

MC-082 (Rev. January 1, 2007]                   DECLARATION IN SUPPORT OF ATTORNEY'                                                     Page 2 of2
                                               MOTION TO BE RELIEVED AS COUNSEL—CIVIL