Judge: Michelle C. Kim, Case: 23STCV30546, Date: 2024-05-02 Tentative Ruling

Case Number: 23STCV30546    Hearing Date: May 2, 2024    Dept: 31

SUPERIOR COURT OF THE STATE OF CALIFORNIA  

FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT 

 

DAYSI RAMIREZ, 

Plaintiff(s), 

vs. 

 

CITY OF LOS ANGELES, ET AL., 

Defendant(s). 

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Case No.: 23STCV30546 

 

[TENTATIVE] ORDER DENYING WITHOUT PREJUDICE MOTION TO BE RELIEVED AS COUNSEL  

 

Dept. 31 

1:30 p.m. 

May 2, 2024 

 

 

Plaintiff Daysi Ramirez (“Plaintiff”) attorney of record, Raymond Ghennezian, Esq. (“Counsel”) moves to be relieved as counsel, contending relief is necessary because of a complete breakdown in attorney-client relationship. Counsel declares a dispute has arisen as to whether Counsel can proceed as attorney of record on this case, and that the issues in question are fundamental and crucial to the outcome of the case. Counsel declares Plaintiff has been unresponsive to the request for Plaintiff to agree to relieve Counsel on this matter.  

 

Counsel declares that Plaintiff was served by mail at the last known address, which was confirmed within the past 30 days by telephone. However, the motion is denied without prejudice for reasons of a defective proof of service. 

 

The proof of service provides that the moving papers were served on all parties by electronic service only. No electronic address was provided for Plaintiff in the service list. If Plaintiff was indeed served electronically in the same manner as Counsel had served defendants, then aside from the requirement that Plaintiff’s electronic address must be provided in the service list, Counsel must also furnish a declaration the electronic service address was confirmed as current pursuant to California Rules of Court, Rule 3.1362(d)(2). If Counsel served Plaintiff by mail only at his confirmed most current address, then the proof of service declaration must accurately reflect this.  

 

 Moving party is ordered to give notice. 

 

PLEASE TAKE NOTICE: 

  • Parties are encouraged to meet and confer after reading this tentative ruling to see if they can reach an agreement. 

  • If a party intends to submit on this tentative ruling,¿the party must send an email to the court at¿sscdept31@lacourt.org¿with the Subject line “SUBMIT” followed by the case number.¿ The body of the email must include the hearing date and time, counsel’s contact information, and the identity of the party submitting.¿¿ 

  • Unless¿all¿parties submit by email to this tentative ruling, the parties should arrange to appear remotely (encouraged) or in person for oral argument.¿ You should assume that others may appear at the hearing to argue.¿¿ 

  • If the parties neither submit nor appear at hearing, the Court may take the motion off calendar or adopt the tentative ruling as the order of the Court.¿ After the Court has issued a tentative ruling, the Court may prohibit the withdrawal of the subject motion without leave.¿ 

 

Dated this 1st day of May 2024 

 

  

 

 

Hon. Michelle C. Kim 

Judge of the Superior Court