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ATTORNEY
Glenn
ORPARTY
P.
WITHOUT
Zwang,
ATTORNEY
State
(Name,
state
Bar
bar number,
No.
andaddress):
112295
ce =
.BARTKO, ZANKEL, TARRANT & MILLER
A Professional Law Corporation F
900
San
Front
Francisco,
Street, Suite
California
300
94111
ALAMEDA COuNTY
TELEPHONE NO.: (415) 956-1900 Faxno: (415) 956-1152
ATTORNEY FOR(Name: EX. Rick Buell, II, Esq.
Name orcourt’ Alameda County Superior Court
sTREETADDRESS: 1225 Fallon Street
MAILING
ADDRESS:
cityanpzipcoobe: Oakland, CA 94612
BRANCHNAME: Rene C. Davidson Courthouse
CASENAME: Gwen R. Sykes v. Douglas Sykes; and Does 1 CASENUMBER:
to 20, et al. - RG 03106646
HEARINGDATE: June 1, 2004
NOTICE OF MOTION AND MOTION oer: te 2700 pm
TO BE RELIEVED AS COUNSEL — CIVIL are action eu, July 15, 2003
TRiaLbATE: October 1, 2004
TO (name and address ofclient): Gwen R. Sykes, Bay Area Consortium For Quality Health Care,
1440 Broadway, Suite 209, Oakland CA 94612.
1. PLEASE TAKE NOTICE that(name of withdrawing attomey): E. Rick Buell, II, Esq.
moves under CaliforniaCode ofCivilProcedure section 284(2) and CaliforniaRules of Court,rule 376, foran order permitting the
attorney tobe relieved as attorney ofrecord inthis actionor proceeding.
| A hearing on this motion to be relievedas counsel will
be held asfollows:
|
a. Date: June 1, 2004 Time: 2:00 p.m. Dept.: 31 Room:
b. The address of thecourt: X_| same as noted above other (specify):
3. This motion is supported by the accompanying declaration,the papers and records filedinthis actionor proceeding, and
the followingadditionaldocuments or evidence (specify):
\
(This motion does not need tobe accompanied by a memorandum of pointsand authorities.
Cal. Rules of Court, rule376(b).)
4. The clientpresentlyrepresented by the attorneyis
a. |X _|
an individual. g. |__Ja trustee.
b. [_]a corporation. h. [|__]a personal representative.
c. [__]apartnership. i. a probate fiduciary.
d. an unincorporated association. j. (_] a guardian ad litem.
e. [|__]|aguardian. k. [__] other (specify):
f. {_]aconservator.
(Continuedon reverse)
FormJudicial
Adopted
for Mandatory
Council
Use
of California
NOTICE OF MOTION AND MOTION al CodeCal.of Rules
Civil
Procedure
, § 284;
of Court,
rule
376
MC-051[New
July1, 2000] TO BE RELIEVED AS COUNSEL — CIVIL Soluts aS
, ©} @
CASENAME: Sykes v. Sykes, et al CASE NUMBER:
RG 03106646
NOTICE TO CLIENT
Ifthis motion tobe relieved as counsel is granted, your present attorney will no longer be representing you. You
may not in most cases represent yourself if youare one of the parties on the following list:
e A guardian e A personal representative e A guardian ad litem
« Aconservator e A probate fiduciary e An.unincorporated association
e Atrustee e Acorporation
If youare one of these parties, YOU SHOULD IMMEDIATELY SEEK LEGAL ADVICE REGARDING LEGAL
REPRESENTATION. Failure to retainan attorney may lead to an order striking the pleadings orto the entry of a
default judgment.
5. \fithis
motion is granted and a clientisrepresenting himselfor herself,the clientwillbe solelyresponsible for thecase.
NOTICE TO CLIENT WHO WILL BE UNREPRESENTED
If thismotion to be relieved as counsel is granted, you willnot have an attorney representing you. You may wish to
seek legalassistance. Ifyou do not have a new attorney to represent you in this action or proceeding, and you are
legally permitted to do so, you willbe representing yourself. It
will be your responsibility to comply with allcourt
rules and applicable laws. Ifyou failto do so, or fail
to appear at hearings, action may be taken against you. You may
lose your case.
6. If this
motion is granted,the clientmust keep the court informed ofthe client'scurrentaddress.
NOTICE TO CLIENT WHO WILL BE UNREPRESENTED
Ifthis 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 willnot be able to send you
notices ofactions that may affect you, including actions that may adversely affect your interests or result inyour
losing the case.
Date: May b. 2004
Glenn P. Zwang
(TYPEOR PRINT
NAME)
LA (SIGNATURE OF
ATTORNEY)
Attornéy
for fhame):E.{| Rick Buel I, Esq.
MC-051[NewJuly
1, 2000} NOTICE OF MOTION AND MOTION Pagetwo
TO BE RELIEVED AS COUNSEL — CIVIL
PROOF OF SERVICE BY MAIL
I,Paul H. Brown, the undersigned, hereby certify and declare:
1. 1 am over the age of 18 years and am not a party to the within cause.
2. I am employed in the office of a member of the bar of this Court, at whose
direction this service was made.
3. My business address is900 Front Street, Suite 300, San Francisco, California
D
94111. |
NN
4, I am familiar with my employer's mail collection and processing practices;
OS
know that said mail is collected-and deposited with the United States Postal Service on the same
o
10 day itis deposited in the interoffice mail; and know that postage thereon is fully prepaid.
11 5. Following said practice, on May 6, 2004, Iserved a true copy of the attached
12 documents titled exactly (1) Notice of Motion and Motion to be Relieved as Counsel -- Civil (2)
13 Declaration in Support of Attorney’s Motion to be Relieved as Counsel -- Civil (3) Order
14 Granting Attorney’s Motion to be Relieved as Counsel - Civil by placing the same in an
15 addressed, sealed envelope and depositing it in the regularly maintained interoffice mail addressed
16 to the following:
17 Steven B. Piser, Esq. Ms. Gwen R. Sykes
Law Offices of Steven B. Piser c/o Bay Area Consortium for
18 499 -- 14th Street, Suite 210 Quality Health Care
Oakland, CA 94612 1440 Broadway Street, Suite 209
19 Oakland, CA 94612
20 I declare under penalty of perjury that the foregoing is true and correct and that this
21 declaration was executed on May 6, 2004 at San Francisco, California.
22
23
24
40 Wa Paul H. Brown
25
26
27
28
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ATTORNEY Glenn ORPARTY P. WITHOUT Zwang, ATTORNEY State (Name, state Bar bar number, No. andaddress): 112295 ce = .BARTKO, ZANKEL, TARRANT & MILLER A Professional Law Corporation F 900 San Front Francisco, Street, Suite California 300 94111 ALAMEDA COuNTY TELEPHONE NO.: (415) 956-1900 Faxno: (415) 956-1152 ATTORNEY FOR(Name: EX. Rick Buell, II, Esq. Name orcourt’ Alameda County Superior Court sTREETADDRESS: 1225 Fallon Street MAILING ADDRESS: cityanpzipcoobe: Oakland, CA 94612 BRANCHNAME: Rene C. Davidson Courthouse CASENAME: Gwen R. Sykes v. Douglas Sykes; and Does 1 CASENUMBER: to 20, et al. - RG 03106646 HEARINGDATE: June 1, 2004 NOTICE OF MOTION AND MOTION oer: te 2700 pm TO BE RELIEVED AS COUNSEL — CIVIL are action eu, July 15, 2003 TRiaLbATE: October 1, 2004 TO (name and address ofclient): Gwen R. Sykes, Bay Area Consortium For Quality Health Care, 1440 Broadway, Suite 209, Oakland CA 94612. 1. PLEASE TAKE NOTICE that(name of withdrawing attomey): E. Rick Buell, II, Esq. moves under CaliforniaCode ofCivilProcedure section 284(2) and CaliforniaRules of Court,rule 376, foran order permitting the attorney tobe relieved as attorney ofrecord inthis actionor proceeding. | A hearing on this motion to be relievedas counsel will be held asfollows: | a. Date: June 1, 2004 Time: 2:00 p.m. Dept.: 31 Room: b. The address of thecourt: X_| same as noted above other (specify): 3. This motion is supported by the accompanying declaration,the papers and records filedinthis actionor proceeding, and the followingadditionaldocuments or evidence (specify): \ (This motion does not need tobe accompanied by a memorandum of pointsand authorities. Cal. Rules of Court, rule376(b).) 4. The clientpresentlyrepresented by the attorneyis a. |X _| an individual. g. |__Ja trustee. b. [_]a corporation. h. [|__]a personal representative. c. [__]apartnership. i. a probate fiduciary. d. an unincorporated association. j. (_] a guardian ad litem. e. [|__]|aguardian. k. [__] other (specify): f. {_]aconservator. (Continuedon reverse) FormJudicial Adopted for Mandatory Council Use of California NOTICE OF MOTION AND MOTION al CodeCal.of Rules Civil Procedure , § 284; of Court, rule 376 MC-051[New July1, 2000] TO BE RELIEVED AS COUNSEL — CIVIL Soluts aS , ©} @ CASENAME: Sykes v. Sykes, et al CASE NUMBER: RG 03106646 NOTICE TO CLIENT Ifthis motion tobe relieved as counsel is granted, your present attorney will no longer be representing you. You may not in most cases represent yourself if youare one of the parties on the following list: e A guardian e A personal representative e A guardian ad litem « Aconservator e A probate fiduciary e An.unincorporated association e Atrustee e Acorporation If youare one of these parties, YOU SHOULD IMMEDIATELY SEEK LEGAL ADVICE REGARDING LEGAL REPRESENTATION. Failure to retainan attorney may lead to an order striking the pleadings orto the entry of a default judgment. 5. \fithis motion is granted and a clientisrepresenting himselfor herself,the clientwillbe solelyresponsible for thecase. NOTICE TO CLIENT WHO WILL BE UNREPRESENTED If thismotion to be relieved as counsel is granted, you willnot have an attorney representing you. You may wish to seek legalassistance. Ifyou do not have a new attorney to represent you in this action or proceeding, and you are legally permitted to do so, you willbe representing yourself. It will be your responsibility to comply with allcourt rules and applicable laws. Ifyou failto do so, or fail to appear at hearings, action may be taken against you. You may lose your case. 6. If this motion is granted,the clientmust keep the court informed ofthe client'scurrentaddress. NOTICE TO CLIENT WHO WILL BE UNREPRESENTED Ifthis 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 willnot be able to send you notices ofactions that may affect you, including actions that may adversely affect your interests or result inyour losing the case. Date: May b. 2004 Glenn P. Zwang (TYPEOR PRINT NAME) LA (SIGNATURE OF ATTORNEY) Attornéy for fhame):E.{| Rick Buel I, Esq. MC-051[NewJuly 1, 2000} NOTICE OF MOTION AND MOTION Pagetwo TO BE RELIEVED AS COUNSEL — CIVIL PROOF OF SERVICE BY MAIL I,Paul H. Brown, the undersigned, hereby certify and declare: 1. 1 am over the age of 18 years and am not a party to the within cause. 2. I am employed in the office of a member of the bar of this Court, at whose direction this service was made. 3. My business address is900 Front Street, Suite 300, San Francisco, California D 94111. | NN 4, I am familiar with my employer's mail collection and processing practices; OS know that said mail is collected-and deposited with the United States Postal Service on the same o 10 day itis deposited in the interoffice mail; and know that postage thereon is fully prepaid. 11 5. Following said practice, on May 6, 2004, Iserved a true copy of the attached 12 documents titled exactly (1) Notice of Motion and Motion to be Relieved as Counsel -- Civil (2) 13 Declaration in Support of Attorney’s Motion to be Relieved as Counsel -- Civil (3) Order 14 Granting Attorney’s Motion to be Relieved as Counsel - Civil by placing the same in an 15 addressed, sealed envelope and depositing it in the regularly maintained interoffice mail addressed 16 to the following: 17 Steven B. Piser, Esq. Ms. Gwen R. Sykes Law Offices of Steven B. Piser c/o Bay Area Consortium for 18 499 -- 14th Street, Suite 210 Quality Health Care Oakland, CA 94612 1440 Broadway Street, Suite 209 19 Oakland, CA 94612 20 I declare under penalty of perjury that the foregoing is true and correct and that this 21 declaration was executed on May 6, 2004 at San Francisco, California. 22 23 24 40 Wa Paul H. Brown 25 26 27 28