On March 09, 2017 a
Party Statement
was filed
involving a dispute between
James Kishiyama,
and
Beverly Goodrow,
Larry Goodrow,
Lighthouse Mortgage Company, Inc.,
for civil
in the District Court of Placer County.
Preview
MC-052
ATTORNEYORPARTYWITHOUTATTORNEY(Name.
state
bar
number,
and address): FORCOURT USEONLY
J. David Nick (157687)
Law Office of David Nick 7 op me pn
345 Franklin Street SUPERIOR o Bea Ea ff
San Francisco, CA 94102 OUNTY aed CALIFORNIA
FOX
recepHoneno: 415-552-4444 FAXNO.
aTrorneYFor(Nae) Defendant Lighthouse Mortgage Company, Inc. = EB 19 2019
nameof court: Placer County
4 Superior ; Court AKE > CHAT-
CHATTE
By
streetaooress:]0820 Justice Center Drive EXEQUT VE OFFICES a
waiineaooress:
PO Box 619072 Roseville, CA 95661 fac aggoner, Gacck
city
ano zipcone: Roseville 95678 y
BRANCHNAME:
CASE NAME: Kishiyama v. Lighthouse Mortgage Co., Inc.,
y 6 eas =et al. CASENUMBER
SCV0039231
=o 03/21/201 % 3
DEPT. » &:
DECLARATION INSUPPORT OF seroma Wacko: ™
ATTORNEY'S MOTION TO BE RELIEVED AS .
COUNSEL—CIVIL DATEACTIONFILED:
03/09/201 v
TRIAL
DATE:4-22- I 9
1. Attorney and Represented Party. Attorney(name): J. David Nick
ispresentlycounsel ofrecord for(name of party):Lighthouse Mortgage Co:; Inc.
inthe above-captioned actionorproceeding.
2. Reasons forMotion. Attorney makes thismotionto be relieved
as counsel under Code of Civil
Procedure section284(2) instead
offiling
a consentunder section 284(1)forthe followingreasons (describe):
There has been an irreparable breakdown of the working relationship between counsel and client.The
specific facts which give rise to this motion are confidential and required to be kept confidential pursuant
to Business and Professions Code §6068(e), rule 3-100(A), California Rules of Professional Conduct, and
by the attorney-client privilege (Evid. C., §§950 etseq.). In the event that thiscourt desires further
information to ascertain the good faith basis for this motion and for withdrawal, itis respectfully
requested that the court have an in camera hearing outside of thepresence of all other parties so that the
specific facts demonstrating good cause forthis 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))
[_] Continued on Attachment 2.
3. Service
a. Attorney has
(1)EI personallyserved theclientwithcopies ofthemotion papers filed
with thisdeclaration.
A copy of theproofof service
will
be filed
with thecourt atleast5 days beforethe hearing.
(2) served theclientby mailatthe client's
lastknown address withcopies ofthe motion papers servedwith thisdeclaration.
b.If theclient
has been served by mailat theclient's
lastknown address, attorneyhas
(1) confirmedwithinthe past 30 days thattheaddress iscurrent
(a)L~] by mail,returnreceiptrequested.
(b)(_] by telephone.
(c)L__] by conversation
(d){(—_]by othermeans (specify):
(Continued
on reverse)
Page1 of 2
of
Counel
rogudiget Cait DECLARATION INSUPPORT OF SatesOnaeae
ME-O82
Rew.January
1.2007) ATTORNEY'S MOTION TO BE RELIEVED AS wow courtnfe
co. gov
COUNSEL—CIVIL
MC-052
CASE NAME: CASENUMBER:
Kishiyama v. Lighthouse Mortgage Co., Inc.,ct al. SCV0039231
3. b. (2)[-_] been unabie to confirmthatthe address iscurrentortolocate amore currentaddress fortheclientaftermaking the
followingefforts:
(a)[__] mailingthemotion papers tothe client's
last
known address, returnreceiptrequested.
(b)(__] callingtheclient's
lastknown telephone number or numbers.
(c)[__] contacting persons familiar
withthe client
(specify):
(d) conducting a search(describe):
(e)_] other(specify):
c. Even if attorney
has been unable toserve the client
withthe moving papers, thecourtshould grantattorney’smotion tobe
relievedas counselof record(explain):
4. The nexthearingscheduled inthisactionorproceeding
a. isnot yetset.
b. VY) issetas follows(specifythe date,time,and place): 4-5-19 8:30A.M. Dept. TBD
c. [LW] concerns (describethe subjectmatterof thehearing): Sutter init Gntwenees
[_] Continued on Attachment 4.
5. The followingadditional
hearings and other proceedings (including
discoverymatters)are presentlyscheduled in thiscase (for
each,
describethe date,time,
place, andsubject matter):
4-12-19 8:30am. Dept. TBD Trial Confirmation.
[-] Continued on Attachment 5.
6. Trialinthisactionorproceeding
a. isnotyet set.
b. LZ) issetas follows(specifythe date,time,and place): 4-22-19 8:30a.m. Dept. TBD
7. Other. Othermatters thatthe courtshould considerindetermining whether tograntthismotion are thefollowing(explain):
under
| declare penaltyof perjuryunder thelaws of theStateof that
California theforegoing istrueand correct.
Date:02/19/2019
J. David Nick
(TYPEORPRINTNAME)
\
t
ON OF
(SIGNATURE DECLARANT)
8.Number ofpages attached: 0
INSUPPORT OF Page 2 of 2
1. 2007]
January
jRev.
MC-052 DECLARATION
ATTORNEY'S MOTION TO BE RELIEVED AS
COUNSEL—CIVIL
Document Filed Date
February 19, 2019
Case Filing Date
March 09, 2017
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MC-052 ATTORNEYORPARTYWITHOUTATTORNEY(Name. state bar number, and address): FORCOURT USEONLY J. David Nick (157687) Law Office of David Nick 7 op me pn 345 Franklin Street SUPERIOR o Bea Ea ff San Francisco, CA 94102 OUNTY aed CALIFORNIA FOX recepHoneno: 415-552-4444 FAXNO. aTrorneYFor(Nae) Defendant Lighthouse Mortgage Company, Inc. = EB 19 2019 nameof court: Placer County 4 Superior ; Court AKE > CHAT- CHATTE By streetaooress:]0820 Justice Center Drive EXEQUT VE OFFICES a waiineaooress: PO Box 619072 Roseville, CA 95661 fac aggoner, Gacck city ano zipcone: Roseville 95678 y BRANCHNAME: CASE NAME: Kishiyama v. Lighthouse Mortgage Co., Inc., y 6 eas =et al. CASENUMBER SCV0039231 =o 03/21/201 % 3 DEPT. » &: DECLARATION INSUPPORT OF seroma Wacko: ™ ATTORNEY'S MOTION TO BE RELIEVED AS . COUNSEL—CIVIL DATEACTIONFILED: 03/09/201 v TRIAL DATE:4-22- I 9 1. Attorney and Represented Party. Attorney(name): J. David Nick ispresentlycounsel ofrecord for(name of party):Lighthouse Mortgage Co:; Inc. inthe above-captioned actionorproceeding. 2. Reasons forMotion. Attorney makes thismotionto be relieved as counsel under Code of Civil Procedure section284(2) instead offiling a consentunder section 284(1)forthe followingreasons (describe): There has been an irreparable breakdown of the working relationship between counsel and client.The specific facts which give rise to this motion are confidential and required to be kept confidential pursuant to Business and Professions Code §6068(e), rule 3-100(A), California Rules of Professional Conduct, and by the attorney-client privilege (Evid. C., §§950 etseq.). In the event that thiscourt desires further information to ascertain the good faith basis for this motion and for withdrawal, itis respectfully requested that the court have an in camera hearing outside of thepresence of all other parties so that the specific facts demonstrating good cause forthis 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)) [_] Continued on Attachment 2. 3. Service a. Attorney has (1)EI personallyserved theclientwithcopies ofthemotion papers filed with thisdeclaration. A copy of theproofof service will be filed with thecourt atleast5 days beforethe hearing. (2) served theclientby mailatthe client's lastknown address withcopies ofthe motion papers servedwith thisdeclaration. b.If theclient has been served by mailat theclient's lastknown address, attorneyhas (1) confirmedwithinthe past 30 days thattheaddress iscurrent (a)L~] by mail,returnreceiptrequested. (b)(_] by telephone. (c)L__] by conversation (d){(—_]by othermeans (specify): (Continued on reverse) Page1 of 2 of Counel rogudiget Cait DECLARATION INSUPPORT OF SatesOnaeae ME-O82 Rew.January 1.2007) ATTORNEY'S MOTION TO BE RELIEVED AS wow courtnfe co. gov COUNSEL—CIVIL MC-052 CASE NAME: CASENUMBER: Kishiyama v. Lighthouse Mortgage Co., Inc.,ct al. SCV0039231 3. b. (2)[-_] been unabie to confirmthatthe address iscurrentortolocate amore currentaddress fortheclientaftermaking the followingefforts: (a)[__] mailingthemotion papers tothe client's last known address, returnreceiptrequested. (b)(__] callingtheclient's lastknown telephone number or numbers. (c)[__] contacting persons familiar withthe client (specify): (d) conducting a search(describe): (e)_] other(specify): c. Even if attorney has been unable toserve the client withthe moving papers, thecourtshould grantattorney’smotion tobe relievedas counselof record(explain): 4. The nexthearingscheduled inthisactionorproceeding a. isnot yetset. b. VY) issetas follows(specifythe date,time,and place): 4-5-19 8:30A.M. Dept. TBD c. [LW] concerns (describethe subjectmatterof thehearing): Sutter init Gntwenees [_] Continued on Attachment 4. 5. The followingadditional hearings and other proceedings (including discoverymatters)are presentlyscheduled in thiscase (for each, describethe date,time, place, andsubject matter): 4-12-19 8:30am. Dept. TBD Trial Confirmation. [-] Continued on Attachment 5. 6. Trialinthisactionorproceeding a. isnotyet set. b. LZ) issetas follows(specifythe date,time,and place): 4-22-19 8:30a.m. Dept. TBD 7. Other. Othermatters thatthe courtshould considerindetermining whether tograntthismotion are thefollowing(explain): under | declare penaltyof perjuryunder thelaws of theStateof that California theforegoing istrueand correct. Date:02/19/2019 J. David Nick (TYPEORPRINTNAME) \ t ON OF (SIGNATURE DECLARANT) 8.Number ofpages attached: 0 INSUPPORT OF Page 2 of 2 1. 2007] January jRev. MC-052 DECLARATION ATTORNEY'S MOTION TO BE RELIEVED AS COUNSEL—CIVIL