On December 17, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Fracolli, Stephanie A.,
Lynch, Kenneth,
and
County Of San Joaquin, Department Of Child Support Services,
First California Mortgage Company, A California Corporation,
Lynch, Kenneth,
for civil
in the District Court of San Joaquin County.
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ATTORNEY OR PARTY W Esq (B (Name, ts oRg8)” and address): FOR GOURT USE ONLY
Dennis L. Hay, Esq. (Bar # 13988 :
[- Law Office of Dennis L. Hay, Esq. FILED ;
18780 East Highway 88 (Mailing: P.O. Box 745) SUPERIOR COURT .
Clements, CA 95227 Loon
‘etepHoneNO.(209) 759-3222 raxno: (209) 759-3105 200 ROY 13 PH -2: 83
ATTORNEY FOR Nemo} Kenneth Lynch, Defendant
NAME OF COURT: SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN
streetaporess; 180 East Weber Avenue
mauincanoress: 180 East Weber Avenue, Suite 200
cryanoze cone: Stockton 95202
srancHname. Stockton. “FAIS, 1 25 fe Xov
CASE NAME: | CASE NUMBER:
Fracolli v. Lynch STK-CV-URP-2018-15686
HEARING DATE:
NOTICE OF MOTION AND MOTION veer: 10D TIME:
TO BE RELIEVED AS @EFORE HON: The Honorable Barbara A. Kronlund, Juds
COUNSEL—CIVIL pare action Fiteo: December 24, 2018
tra oats: July 13, 2020
TO (name and address of client): Kenneth Lynch
2600 Ponte Mira Way, Tracy, California 95376
1. PLEASE TAKE NOTICE that (name of withdrawing lattomey): : Dennis L. Hay, Esq.
moves under California Code of Civil Procedure section 284(2) and California utes of Court, rule 3.1362, for an order permitting
the attomey to be relieved as attorney of record in this action or proceeding.
2. Ahearing on this motion to be relieved as counsel la be held as follows:
a. Date: DEC n9 770 Time: B00 Au Dept.: 10D Room:
|
b. The address of the court: same as noted above [__] other (specify):
3. This motion is supported by the accompanying dec] jaration, the papers and records filed in this action or proceeding, and
the following additional documents or evidence (specify):
Declaration of Dennis L. Hay, Esq.
!
(This motion does not need to be accompanied by a memorandum of points and authorities. Cal. Rules of Court, rule 3.1362.)
4. The client presently represented by the attomey ie
(7) an individual. g. [_] atrustee.
[__] a corporation. h. [__] a personal representative.
([] a partnership. i. [__] a probate fiduciary.
{__] an unincorporated association. i. [J a guardian ad fitem.
[J a guardian. k. [_] other (specify):
[5 aconservator.
spaose
(Continued on reverse)
Page 1 of 2
Ferm adored NOTICE OF MOTION AND MOTION God ot Chil Procadur 8288
toe. TO BE RELIEVED AS COUNSEL—CIVIL oes enurd.cagov
LexisNexis® Automated California Judicial Council FormsMC-051
CASE NAME: CASE NUMBER:
[~ Fracolli v. Lynch STK-CV-URP-2018-15686
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 Tepresentative + 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. Fallure to retain an attorney may lead to an order striking the pleadings or to the entry of a
default judgment. |
T
5. 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 attomey 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.
6. If this motion is granted, the client must keep the om 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: November 9, 2020
Dennis L. Hay, Esq. ry Ck,
(TYPE OR PRINT NAME) (SIGNATURE OF ATTORNEY)
Attorney for (name): Kenneth Lynch
I
i
t
MC-O5t [Rev. January 1, 2007] NOTICE OF MOTION AND MOTION Page 2ot2
TO BE RELIEVED AS COUNSEL—CIVIL
LexisNexis® Automated California Judicial Council Forms
Document Filed Date
November 13, 2020
Case Filing Date
December 17, 2018
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wo-ast 2 ATTORNEY OR PARTY W Esq (B (Name, ts oRg8)” and address): FOR GOURT USE ONLY Dennis L. Hay, Esq. (Bar # 13988 : [- Law Office of Dennis L. Hay, Esq. FILED ; 18780 East Highway 88 (Mailing: P.O. Box 745) SUPERIOR COURT . Clements, CA 95227 Loon ‘etepHoneNO.(209) 759-3222 raxno: (209) 759-3105 200 ROY 13 PH -2: 83 ATTORNEY FOR Nemo} Kenneth Lynch, Defendant NAME OF COURT: SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN streetaporess; 180 East Weber Avenue mauincanoress: 180 East Weber Avenue, Suite 200 cryanoze cone: Stockton 95202 srancHname. Stockton. “FAIS, 1 25 fe Xov CASE NAME: | CASE NUMBER: Fracolli v. Lynch STK-CV-URP-2018-15686 HEARING DATE: NOTICE OF MOTION AND MOTION veer: 10D TIME: TO BE RELIEVED AS @EFORE HON: The Honorable Barbara A. Kronlund, Juds COUNSEL—CIVIL pare action Fiteo: December 24, 2018 tra oats: July 13, 2020 TO (name and address of client): Kenneth Lynch 2600 Ponte Mira Way, Tracy, California 95376 1. PLEASE TAKE NOTICE that (name of withdrawing lattomey): : Dennis L. Hay, Esq. moves under California Code of Civil Procedure section 284(2) and California utes of Court, rule 3.1362, for an order permitting the attomey to be relieved as attorney of record in this action or proceeding. 2. Ahearing on this motion to be relieved as counsel la be held as follows: a. Date: DEC n9 770 Time: B00 Au Dept.: 10D Room: | b. The address of the court: same as noted above [__] other (specify): 3. This motion is supported by the accompanying dec] jaration, the papers and records filed in this action or proceeding, and the following additional documents or evidence (specify): Declaration of Dennis L. Hay, Esq. ! (This motion does not need to be accompanied by a memorandum of points and authorities. Cal. Rules of Court, rule 3.1362.) 4. The client presently represented by the attomey ie (7) an individual. g. [_] atrustee. [__] a corporation. h. [__] a personal representative. ([] a partnership. i. [__] a probate fiduciary. {__] an unincorporated association. i. [J a guardian ad fitem. [J a guardian. k. [_] other (specify): [5 aconservator. spaose (Continued on reverse) Page 1 of 2 Ferm adored NOTICE OF MOTION AND MOTION God ot Chil Procadur 8288 toe. TO BE RELIEVED AS COUNSEL—CIVIL oes enurd.cagov LexisNexis® Automated California Judicial Council FormsMC-051 CASE NAME: CASE NUMBER: [~ Fracolli v. Lynch STK-CV-URP-2018-15686 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 Tepresentative + 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. Fallure to retain an attorney may lead to an order striking the pleadings or to the entry of a default judgment. | T 5. 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 attomey 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. 6. If this motion is granted, the client must keep the om 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: November 9, 2020 Dennis L. Hay, Esq. ry Ck, (TYPE OR PRINT NAME) (SIGNATURE OF ATTORNEY) Attorney for (name): Kenneth Lynch I i t MC-O5t [Rev. January 1, 2007] NOTICE OF MOTION AND MOTION Page 2ot2 TO BE RELIEVED AS COUNSEL—CIVIL LexisNexis® Automated California Judicial Council Forms