On June 15, 2020 a
20240220 SmithvsFuture2-F2LHealth LLC (MC051)
was filed
involving a dispute between
Smith, Christopher,
and
Future2 Labs Health Services, Inc.,
Future2 Labs Health Services Llc,
Future 2 Labs Llc,
Future2 Labs Of California, Llc,
Jones, Mark,
for (23) Unlimited Other PI / PD / WD
in the District Court of Santa Cruz County.
Preview
MC-051
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slate bar number, and address): FOR COURT USE ONLY
William B. DeClereq (SBN 240538)
| DeClerceq 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: CASE NUMBER
Christopher Smith v Future 2 Labs, LLC, et al 20CV01307
nearine pate: March 27, 2024
NOTICE OF MOTION AND MOTION DEPT. 10 TIME: 8:30 am
TO BE RELIEVED AS BEFORE HON
COUNSEL—CIVIL DATE ACTION FILED:
TRIAL DATE
TO (name and address of client): Future 2 Labs Health Services, LLC
117 Fern Street, Santa Cruz CA 95060
PLEASE TAKE NOTICE that (name of withdrawing attorney): WILLIAM B. DECLERCQ, DECLERCQ LAW P.C.
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.
A hearing on this motion to be relieved as counsel will be held as follows:
a Date: March 27, 2024 Time: 8:30 Dept: 10 Room:
b. The address of the court: same as noted above [-} other (specify):
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):
There has been a breakdown in the attomey-client relationship which requires withdrawal by counsel.
pursuantto Business Pro: fe
The specific facts which ve rise to this motion are confidential and required to be kept confidential
ssions Code 6068 (e), rule 3-100 (A), California Rules of Professional Conduct,
and by the attorney-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
g od cause for this withdrawal may be demonstrated to the court. (Manfredi
Levine v. Superior Court (1998) 66 Cal.A pp.4th 1128, 1136-1137; 3-700(B) or (C))
(This motion does not need to be accompanied by a memorandum of points and authorities. Cal. Rules of Court, rule 3.1362.)
The client presently represented by the attorney is
a [] an individual. g. [__] 4 trustee.
b. [4] a corporation. h. [J] a personal representative.
c. [] a partnership. i [_] a probate fiduciary.
d [] an unincorporated association. J [Ja guardian ad litem
e. [-_] a guardian. k. [-_] other (specify):
f. [-) a conservator.
(Continued on reverse) Page 1of2
Form Adopted for Mandatory Use NOTICE OF MOTION AND MOTION Code of Civil Procedure, § 284;
Judicial Council of California Cal. Rules of Court, rule 3.1362
MC-051 [Rev. J anuary 1, 2007] TO BE RELIEVED AS COUNSEL— CIVIL www.courtinfo.ca.gov
MC-051
CASE NAME: CASE NUMBER
|- Christopher Smith v Future 2 Labs, LLC, et al 20CV01307
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.
. 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.
. 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: February 20, 2024
J
Chew “ . hi Linea
William B. DeClereq pu
(TYPE OR PRINT NAME) (SIGNATURE OF ATTORNEY)
Attorney for (name): Future 2 Labs Health Services, LLC
MC-051 [Rev. January 1, 2007] NOTICE OF MOTION AND MOTION Page
2 0f2
TO BE RELIEVED AS COUNSEL— CIVIL
Preview
MC-051 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slate bar number, and address): FOR COURT USE ONLY William B. DeClereq (SBN 240538) | DeClerceq 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: CASE NUMBER Christopher Smith v Future 2 Labs, LLC, et al 20CV01307 nearine pate: March 27, 2024 NOTICE OF MOTION AND MOTION DEPT. 10 TIME: 8:30 am TO BE RELIEVED AS BEFORE HON COUNSEL—CIVIL DATE ACTION FILED: TRIAL DATE TO (name and address of client): Future 2 Labs Health Services, LLC 117 Fern Street, Santa Cruz CA 95060 PLEASE TAKE NOTICE that (name of withdrawing attorney): WILLIAM B. DECLERCQ, DECLERCQ LAW P.C. 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. A hearing on this motion to be relieved as counsel will be held as follows: a Date: March 27, 2024 Time: 8:30 Dept: 10 Room: b. The address of the court: same as noted above [-} other (specify): 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): There has been a breakdown in the attomey-client relationship which requires withdrawal by counsel. pursuantto Business Pro: fe The specific facts which ve rise to this motion are confidential and required to be kept confidential ssions Code 6068 (e), rule 3-100 (A), California Rules of Professional Conduct, and by the attorney-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 g od cause for this withdrawal may be demonstrated to the court. (Manfredi Levine v. Superior Court (1998) 66 Cal.A pp.4th 1128, 1136-1137; 3-700(B) or (C)) (This motion does not need to be accompanied by a memorandum of points and authorities. Cal. Rules of Court, rule 3.1362.) The client presently represented by the attorney is a [] an individual. g. [__] 4 trustee. b. [4] a corporation. h. [J] a personal representative. c. [] a partnership. i [_] a probate fiduciary. d [] an unincorporated association. J [Ja guardian ad litem e. [-_] a guardian. k. [-_] other (specify): f. [-) a conservator. (Continued on reverse) Page 1of2 Form Adopted for Mandatory Use NOTICE OF MOTION AND MOTION Code of Civil Procedure, § 284; Judicial Council of California Cal. Rules of Court, rule 3.1362 MC-051 [Rev. J anuary 1, 2007] TO BE RELIEVED AS COUNSEL— CIVIL www.courtinfo.ca.gov MC-051 CASE NAME: CASE NUMBER |- Christopher Smith v Future 2 Labs, LLC, et al 20CV01307 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. . 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. . 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: February 20, 2024 J Chew “ . hi Linea William B. DeClereq pu (TYPE OR PRINT NAME) (SIGNATURE OF ATTORNEY) Attorney for (name): Future 2 Labs Health Services, LLC MC-051 [Rev. January 1, 2007] NOTICE OF MOTION AND MOTION Page 2 0f2 TO BE RELIEVED AS COUNSEL— CIVIL