Judge: Mark A. Young, Case: 23SMCV04004, Date: 2024-04-30 Tentative Ruling

Case Number: 23SMCV04004    Hearing Date: April 30, 2024    Dept: M

CASE NAME:           Smith v. Koay

CASE NO.:                23SMCV04004

MOTION:                  Motion to be Relieved

HEARING DATE:   4/30/2024

 

Legal Standard

 

The court may order that an attorney be changed or substituted at any time before or after judgment or final determination upon request by either client or attorney and after notice from one to the other. (CCP § 284(2).) The attorney seeking to withdraw must take “reasonable steps to avoid reasonably foreseeable prejudice to the rights of the client, including giving due notice to the client, allowing time for employment of other counsel.” (Cal. Rules of Prof. Conduct, 3-700(A)(2). See, e.g., Vann v. Shilleh (1975) [holding withdrawal prejudicial where attorney withdraw from the representation of defendant on the Friday before trial began the following Monday].) “The determination whether to grant or deny a motion to withdraw as counsel lies within the sound discretion of the trial court.” (Manfredi & Levine v. Superior Court (1998) 66 Cal.App.4th 1128, 1133.) 

 

An application to be relieved as counsel must be made on Judicial Counsel Form MC-051 (Notice of Motion and Motion), MC-052 (Declaration), and MC-053 (Proposed Order). (CRC 3.1362(a), (c), (e).) The requisite forms must be served “on the client and on all parties that have appeared in the case.” (CRC, 3.1362(d).) When a client is served by mail, the attorney’s declaration must indicate that the client’s address was confirmed within the last 30 days and how it was confirmed. (Id.) If the attorney is unable to confirm the client’s current address, the declaration must state the reasonable efforts made within the last 30 days to obtain the client’s current address. (Id.)

 

Additionally, the declaration “must state in general terms and without compromising the confidentiality of the attorney client relationship why” a motion is brought instead of filing a substitution of attorney. (CRC, 3.1362(c).)

 

Analysis

 

Counsel Kourosh Pishnamaz of LAW & PISH move to be relieved as counsel of record for Plaintiff Jayla Smith.  Counsel provides all the mandatory forms. Counsel states that an irreparable breakdown of the attorney-client relationship has occurred.  Counsel served their client by mail at the client’s last known address, which was confirmed within the past 30 days by telephone.

 

The declaration does not note the hearings that are on calendar, such as the May 23, 2024, OSC Re: Failure to Prosecute & Failure to Appear, and the discovery motions set for May 29, 2024 and May 30, 2024. In light of these upcoming and potentially dispositive hearings, immediate withdrawal would be prejudicial to the client. Accordingly, the court will rule on the motion to be relieved after the OSC hearings. The Court continues the instant hearing to May 23, 2024, at 8:30 a.m. Counsel is ordered to provide notice.