Motion-Secondary: MARTIN ENG VS. JP MORGAN CHASE BANK, N.A. ET AL (Pltf 170.6 Challenge Judge Quidachay)

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                                Mo-052

AREY OR PARTY WATHOUT ATTORNEY (Mame, staie ber number, and adarass} FOR COURT USE ONLY
eph L. De Clue, Esq. (SBN 163954}
LAW GROUP, PC

72 SE Bristol Street, 2nd Floor

rt Beach, CA 92660 : ELECTRONICALLY
a: (94935G6-T145 — saxna, (949)258-5899 FILED |
San Francisco Superior Court | coun of eas rence [| i;
460 McAllister Street i 08/19/2016 |
! Clerk ofthe Court | i
San Francisco, CA 94102 BY:VANESSA WU i :

Civic Center Courthouse Deputy Clerk :

er

ASE NAME: Martin Eng v. JP Morgan Chase Bank, et al. oe EGC 5-§46377

© September 21, 2016
{ mae, 9:30 a.m
i DECLARATION IN SUPPORT OF ATTORNEY'S Harold Kahn

| MOTION TO BE RELIEVED AS COUNSEL—CIVIL nl
\ parzacron ries June 16, 2015
i

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Reservation No.: 08170921-21 ras. pare) None

Attorney and Represented Party. Atorney (name): Joseph L. De Clue
is presently counsel of record for (name of party)’ Martin Eng
in the above-captioned action or proceeding.

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Reasons for Motion. Attorney makes this metion 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).

Breakdown in attorney-client relationship.

CX] Continued on Attachment 2

we

Service
2, Attorney has.
£4} {_] personaily served the client with copies cf the motion papers filed with this deciaration. A copy of the proof of service
will be filed with the court at least 5 days before the ‘ing.
served the client by mail at the client's last known address with copies of the motion papers served with this declaration.
nt 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
(a)(__] by mail, return receipt requested
(©) _] by telephone.
(c) 1 by convarsation
id} __} by other means (specify):

(Continued on reverse}
Page tof?

DECLARATION IN SUPPORT OF ATTORNEY'S
MOTION TO BE RELIEVED AS COUNSEL —CIVIL

3
i COUMIES 08 HOYMC—052

CASE NUMBER:

y. JP Morgan Chase Bank, et al. | CGC-15-546377 '

3. b. (2) [7] 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) [77] mailing the motion papers to the client's tast known address, retum receint requested.
(2) ("] calling the client's fast known telephone number or numbers:

co
(e) [_] contacting persons familiar with the client (specify):

(d} | conducting a search (describe):

(8) LZo other (specify):
Address provided by client 2 months ago. He refused to verity when asked most recently.
c. Ever if aitomey has been unable te serve the client with the moving pagers, the court should grant attorney's mation to be,
relieved as counsel of record fexplain):
Client previously advised that email is his preferred method of receiving documents. Moving papers were
served via electronic mail as well as by certified mail.
4 The next hearing scheduled in this action or proceeding
a. [1] isnot yet set
b. Wis set as follows (specify the date, time, and place}:
___. Defendants Motion for Judgment on the Pleadings, 09/09/16 at 9:30 am. In Dept. 302
c, [77] concerns (describe the subject matter of the hearing}:

(7) Continued on Attachment 4.

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

ase Management Conference - 9/21/2016, 10:30 a.m. in Dept. 302

o

[1 Contnued on Attachment 6.

this action or proceeding
a. ig not yet set.
b. [7] 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 deciare uncer penalty of perjury under the laws of the State of California that the foregaing is tue and correct,

Date: August 17, 2016

Joseph L. De Clue

SVEE DR ERINT NE)
8, Number of pages attached:

Rev Jers

DECLARATION IN SUPPORT OF ATTORNEY'S rearte?
MOTION TO BE RELIEVED AS COUNSEL—CIVIL,

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) 596-7145 | Fax (949)

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DE CLUE LAW GROUP, PC

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| Dated: August 18, 2016

| ATTORNEYS MOTION FO BE RELIEVED on the interested parties in said action by

_| tbereon,

PROOF OF SERVICE
STATE OF CALIFORNIA
SS:
COUNTY OF ORANGE

lam employed in the County of Orange, State of California. I am over the age of 18 and not |
a party to the within action; my business address is 2372 SE Bristol Street, 284 Floor, Newport
Beach, California 92660. On August 18, 2016, I served the within NOTICE OF MOTION AND
MOTION TO BE RELIEVED AS COUNSEL; DECLARATION IN SUPPORT GF

placing __ the original X_ a true copy thereof, enclosed in a sealed envelope and addressed as
follows:

MARTI G
818 Green Street
San Francisco, CA 94133
me2461111@gmaii.com

> of collection
ractice, it would bi osited in a box or
vith First-Class postage
e ordinary course of business.
valid if postal cancellation date or |
yin affidavit.

_X_ BY UNITED STATES CERTIFIED MAIL, Lam “reai
and processing correspondence for mailing. Under that
other facility regularly maintained by the United $
thereon fully prepaid that same day at
Lam aware that on motion of party served, service is presurne:
postage meter dete is more than one day after date of deposit for mall:

s Postal Service

lewport Beach, Californi:

_X_ BY ELECTRONIC TRANSMISSION —! caused a PDF version of said document(s) to be
erved by electronic mail to the parties identified above using the email addresses indicated

FACSIMILE TRANSMISSION, I caused the above-referenced
to the above-listed addressee(s).

cument(s) to be transmit

_X State I declare under penalty of perjury under the laws of the State of California that the
Pp y of perjury

above is true and correct.

PROOF OF SERVICEPROGF OF SERVICE

|| STATE OF CALIFORNIA }
3 SS:
COUNTY OF ORANGE }

[am employed in the County of Orange, State of California. I am over the age of 18 and not
a party to the within action; my business address is 2372 SE Bristol Sireet, 2°" Floor, Newport
|| Beach, California 92660. On August 18, 2016, I served the within NOTICE OF MOTION AND |
MOTION TO BE RELIEVED AS COUNSEL; DECLARATION IN SUPPORT OF
ATTORNEYS MOTION TO BE RELIEVED on the interested parties in said action by
placing __ the original _X_ a true copy thereof, enclosed in a sealed envelope and addressed as
follows:

Leticia Butier, Esq. |

McCARTHY & HOLTHUS, LLP i BRYAN CAVE Li :
1770 Fourth Avenue i 560 Mission Street, 25" Floor
San Diego, CA 92101 i 94105

400
3434 |
Attorneys for Defendan MORGAN CHASE |

Tel: (619)685-4800
Attorneys for Defendant, QUALITY LOAN
SERVICE CORPORATION

3675

Stan Smith

NIVEN & SMITH

555 Montgomery St., Suite 1756 i

San Francisco, CA 94111-2517 I :

Tel: 415.981.5451 :

Fax: 415.433.5439 i

Attorney for Defendants, SOTHEBY’S
INTERNATIONAL LY, INC. and MARY

LOU CASTELLANOS

DE CLUE LAW GROUP, PC

_X_ BY UNITED STATES MAIL, Lam “readily familiar" with the practice of collection and processing |
correspondence for mailing. Under that practice, it would be deposited in a box or other facility | |
regularly maintained by the United States Postal Service with First-Ciass postage thereon fully
23 prepaid that same day at Newport Beach, California, in the ordinary course of business.

__. BY FACSIMILE TRAN!
to the above-listed addres:

ISSION, | caused the above-referenced document(s) to be transmitted

1 _X State i declare under penalty of perjury ander iuglaws of the State of California that the
' abe true and correct.

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26 | Dated: August 18, 2016 SEE |
MELISSA. ALVRREZ, |

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PROOF OF SERVICE