This case was last updated from Los Angeles County Superior Courts on 05/27/2019 at 03:30:32 (UTC).

ANDREAS KRATKY ET AL VS DOWNTOWN PRIME LLC ET AL

Case Summary

On 11/08/2017 ANDREAS KRATKY filed a Contract - Other Contract lawsuit against DOWNTOWN PRIME LLC. This case was filed in Los Angeles County Superior Courts, Stanley Mosk Courthouse located in Los Angeles, California. The Judge overseeing this case is RANDOLPH M. HAMMOCK. The case status is Pending - Other Pending.

Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    ****2898

  • Filing Date:

    11/08/2017

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Contract - Other Contract

  • Court:

    Los Angeles County Superior Courts

  • Courthouse:

    Stanley Mosk Courthouse

  • County, State:

    Los Angeles, California

Judge Details

Presiding Judge

RANDOLPH M. HAMMOCK

 

Party Details

Plaintiffs and Petitioners

HWANG JURI

KING JENNA

BRAMZON DANIEL J. ESQ.

AUSTIN BILLIE

LAVALLA BRANT

JIGAU CHRISTIAN

DARAKJY JACQUELINE

KRATKY ANDREAS

LOPEZ JOSE

RYDH DANIEL

MORAN MATA

Defendants and Respondents

DOWNTOWN PRIME LLC

BARADARIAN DAVID

DOES 1-10 INCLUSIVE

YADIDSION PEDRAM

BABAZADEH MOSES

Attorney/Law Firm Details

Plaintiff Attorney

BRAMZON DANIEL J.

Defendant Attorney

LARSON JOHN B.

 

Court Documents

Unknown

2/13/2018: Unknown

Unknown

2/22/2018: Unknown

NOTICE OF RULING

2/23/2018: NOTICE OF RULING

CASE MANAGEMENT ORDER

5/31/2018: CASE MANAGEMENT ORDER

PLAINTIFFS' REQUEST FOR JUDICIAL NOTICE

6/19/2018: PLAINTIFFS' REQUEST FOR JUDICIAL NOTICE

MOTION TO COMPEL INSPECTION AND ENTRY ONTO LANDS;REQUEST FOR SANCTIONS

9/11/2018: MOTION TO COMPEL INSPECTION AND ENTRY ONTO LANDS;REQUEST FOR SANCTIONS

Minute Order

9/11/2018: Minute Order

Opposition

1/16/2019: Opposition

Request for Judicial Notice

1/25/2019: Request for Judicial Notice

Request for Judicial Notice

1/25/2019: Request for Judicial Notice

Minute Order

3/25/2019: Minute Order

DEFENDANTS DOWNTOWN PRIME, LLC, MOSES BABAZADEH, DAVID BARADARIAN AND PEDRAM YADIDSION'S NOTICE OF MOTION AND MOTION TO STRIKE PORTIONS OF PLAINTIFFS' COMPLAINT; ETC.

12/22/2017: DEFENDANTS DOWNTOWN PRIME, LLC, MOSES BABAZADEH, DAVID BARADARIAN AND PEDRAM YADIDSION'S NOTICE OF MOTION AND MOTION TO STRIKE PORTIONS OF PLAINTIFFS' COMPLAINT; ETC.

Unknown

11/8/2017: Unknown

Unknown

11/8/2017: Unknown

Unknown

11/8/2017: Unknown

Unknown

11/8/2017: Unknown

COMPLAINT FOR: 1. FRAUD; ETC

11/8/2017: COMPLAINT FOR: 1. FRAUD; ETC

Unknown

11/8/2017: Unknown

48 More Documents Available

 

Docket Entries

  • 05/20/2019
  • at 09:30 AM in Department 47, Randolph M. Hammock, Presiding; Jury Trial - Not Held - Continued - Party's Motion

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  • 05/14/2019
  • at 08:30 AM in Department 47, Randolph M. Hammock, Presiding; Final Status Conference - Not Held - Continued - Party's Motion

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  • 04/12/2019
  • at 08:30 AM in Department 47, Randolph M. Hammock, Presiding; Post-Mediation Status Conference - Not Held - Rescheduled by Court

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  • 04/03/2019
  • Order (Proposed Order re Ex Parte Application); Filed by Downtown Prime, LLC (Defendant); Moses Babazadeh (Defendant); David Baradarian (Defendant) et al.

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  • 04/02/2019
  • at 08:30 AM in Department 47, Randolph M. Hammock, Presiding; Hearing on Ex Parte Application (to continue trial (c/f 3-25 in Dept. 49)) - Held

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  • 04/02/2019
  • Minute Order ( (Hearing on Ex Parte Application to continue trial (c/f 3-25 ...)); Filed by Clerk

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  • 03/25/2019
  • at 08:30 AM in Department 47, Randolph M. Hammock, Presiding; Hearing on Ex Parte Application ( to continue trial) - Not Held - Continued - Court's Motion

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  • 03/25/2019
  • at 08:30 AM in Department 49; Ex-Parte Proceedings

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  • 03/25/2019
  • Minute Order ( (Ex-Parte Proceedings to Continue Trial)); Filed by Clerk

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  • 03/22/2019
  • Ex Parte Application (to Continue Trial); Filed by Downtown Prime, LLC (Defendant); Moses Babazadeh (Defendant); David Baradarian (Defendant) et al.

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88 More Docket Entries
  • 11/08/2017
  • SUMMONS

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  • 11/08/2017
  • ORDER ON COURT FEE WAIVER

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  • 11/08/2017
  • ORDER ON COURT FEE WAIVER

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  • 11/08/2017
  • COMPLAINT FOR: 1. FRAUD; ETC

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  • 11/08/2017
  • ORDER ON COURT FEE WAIVER

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  • 11/08/2017
  • ORDER ON COURT FEE WAIVER

    Read MoreRead Less
  • 11/08/2017
  • ORDER ON COURT FEE WAIVER

    Read MoreRead Less
  • 11/08/2017
  • ORDER ON COURT FEE WAIVER

    Read MoreRead Less
  • 11/08/2017
  • ORDER ON COURT FEE WAIVER

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  • 11/08/2017
  • Complaint; Filed by Andreas Kratky (Plaintiff); Billie Austin (Plaintiff); Jacqueline Darakjy (Plaintiff) et al.

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Tentative Rulings

Case Number: BC682898    Hearing Date: February 19, 2020    Dept: 47

Andreas Kratky, et al. v. Downtown Prime LLC, et al.

 

MOTION TO ENFORCE THE SETTLEMENT AGREEMENT AND ENTER JUDGMENT UPON THE SETTLEMENT AGREEMENT PURSUANT TO CCP § 664.6

MOVING PARTY: Defendants Downtown Prime, LLC; Moses Babazadeh; David Baradarian; and Pedram Yadidsion

RESPONDING PARTY(S): Plaintiff Jenna King

STATEMENT OF MATERIAL FACTS AND/OR PROCEEDINGS

Plaintiffs alleged that Defendants illegally converted an industrial unit to apartment units rented out to Plaintiffs.

Defendants move to enforce the parties’ settlement agreement and for judgment to be entered on the settlement agreement.

TENTATIVE RULING:

Defendants Downtown Prime, LLC, Moses Babazadeh, David Baradarian, and Pedram Yadidsion’s motion to enforce the settlement agreement and enter judgment upon the settlement agreement pursuant to CCP § 664.6 is GRANTED. The case is ordered dismissed with prejudice.

DISCUSSION:

Motion To Enforce Settlement Agreement and Enter Judgment on Settlement Agreement

Defendants move for an order enforcing the terms of their settlement agreement with Plaintiff Jenna King and/or for the Court to enter judgment pursuant to the terms of the settlement and for attorney’s fees and costs of $2,122.50 incurred in enforcing this agreement. Defendants bring this motion under CCP § 664.6, which provides:

If the parties to pending litigation stipulate, in a writing signed by the parties outside the presence of the court or orally before the court, for settlement of the case, or part thereof, the court, upon motion, may enter judgment pursuant to the terms of the settlement. If requested by the parties, the court may retain jurisdiction over the parties to enforce the settlement until performance in full of the terms of the settlement.

(CCP § 664.6 (bold emphasis and underlining added).)

A recent published opinion emphasizes that a settlement agreement in which the parties agree that the Court will retain jurisdiction to enforce the settlement must be signed by the parties (not just their counsel) and filed with the Court before the action is dismissed. (MesaRHF Partners, L.P. v. City of Los Angeles (2019) 33 Cal.App.5th 913, 917-918.)

Here, the settlement agreement is signed by the parties[1] and states that the “court reserves jurisdiction to enforce the terms and conditions of the settlement and any arbitration award pursuant to Code of Civil Procedure 664.6 and 1281 et seq., upon noticed motion of any party, or after Judge Stone has issued the award.” (Declaration of Gloria G. Medel, Exh. 1 (“Settlement Agreement”) ¶ 13.) This agreement has been filed with the Court before dismissal; accordingly, the Court retains jurisdiction to enforce the settlement. (MesaRHF Partners, supra, 33 Cal.App.5th at 918 [“In this case, the parties could have easily invoked section 664.6 by filing a stipulation and proposed order . . . signed by the parties noting the settlement and requesting that the trial court retain jurisdiction under section 664.6.”].)

Defendant has proffered evidence of a written Settlement Agreement under which all of the Plaintiffs agreed, among other things, to (1) execute a long-form settlement agreement, (2) sign a stipulated judgment for possession of Defendant’s property, (3) move out of the property within 120 days of execution of the long-form agreement, and (4) participate in binding arbitration before Judge Stone. (Medel Decl., Exh. 1.) Nine of the named Plaintiffs have attempted to comply with the terms of the settlement according to Defendant, but Plaintiff Jenna King has not. (Id. ¶ 8.)

Plaintiff argues that the agreement is unenforceable because she did not sign the settlement agreement or did not know that she was signing it and her prior lawyers did not explain the document to her. (Oppo., at p.2.) However, Plaintiff has not come forward with any evidence that her signature on the document was forged. Plaintiff’s primary argument as to her signature appears to be that she thought she was signing something else – a MediCal medical release form. (Declaration of Jenna King ¶ 5.) However, it is undisputed that Plaintiff King attended the mediation before Judge Stone in June 2019, at a time when she and the other Plaintiffs were represented by BASTA, Inc. (Medel Decl. ¶ 2 & Exh. 4.) Plaintiff’s disagreement with her then-counsel’s handling of the settlement does not negate her agreement to it, absent evidence to the contrary. Plaintiff and her son contend that she did not sign the agreement but do not present credible evidence establishing that the signature on the agreement is not hers.

Plaintiff also argues that the agreement is unenforceable as to her because she granted a durable power of attorney to her son in February 2019, before the settlement agreement was signed. (Oppo., at p. 7; Durable Power of Attorney filed 10/11/19.) The durable power of attorney does not negate Plaintiff’s ability to execute an agreement on her own behalf, however. By its terms, it states that her son Brandon King “may act separately” on her behalf. (Durable Power of Attorney filed 10/11/19.) It does not indicate that Plaintiff is without capacity to act on her own.

The general rule is that when a person with the capacity of reading and understanding an instrument signs it, he is, in the absence of fraud and imposition, bound by its contents, and is estopped from saying that its explicit provisions are contrary to his intentions or understanding.

(Larsen v. Johannes (1970) 7 Cal.App.3d 491, 501.)

Finally, Plaintiff argues that the agreement is unenforceable because it does not set forth the allocation of the settlement amount among the Plaintiffs. Plaintiff relies on Gauss v. GAF Corp. (2002) 103 Cal.App.4th 1110 to support this argument. That case is distinguishable, however. In Gauss, having already found the agreement unenforceable for another reason, the Court also determined that it was unenforceable because it did not specify “the amount GAF was obligated to pay.” (Id. at 1123.) The Court had to “reach beyond the settlement letters and rely on subsequent letters” to determine how much GAF was obligated to pay. (Ibid.) In this case, in contrast, there is no ambiguity regarding the amount Defendants are required to pay to the Plaintiffs. Defendants are to pay Plaintiffs “the total of sum of $1,000,000.” (Medel Decl., Exh. 1, ¶ 2.) The agreement also states that Plaintiffs’ counsel “may release $20,000.00 per plaintiff” once the funds are received to assist with relocation expenses, but that “Plaintiffs’ counsel must not release the balance of the funds to any plaintiff prior to that plaintiff vacating the unit/premises and returning the keys to plaintiffs’ counsel.” (Id. ¶ 3.) That the agreement does not specify the allocation of the funds among the Plaintiffs does not render it unenforceable.

Since the last hearing of 12/31/19 on this motion, the Court has received and has carefully reviewed and considered the Declaration of Eric Post. Any and all concerns this Court may have had in connection to Ms. King’s signature on the settlement document have been effectively alleviated by this declaration. This Court finds that Ms. King knowingly and voluntarily signed the document at issue, with full knowledge of its consequences. Additionally, despite her somewhat erratic behavior before this Court at prior hearings, this Court finds that she was of sound mind and she was legally competent when she signed the settlement agreement. It appears that she now has a simple case of “buyer’s remorse.”

As such, the motion to enforce the settlement agreement is GRANTED. The case is ordered dismissed with prejudice.

Defendant’s request for attorney’s fees incurred in enforcing the settlement agreement is DENIED. Defendant does not cite any provision in the Settlement Agreement whereby the parties seeking to enforce the settlement agreement may recover attorney’s fees incurred in enforcing the settlement agreement. Defendant points to Paragraph 13 of the Settlement Agreement, but that paragraph states only that fees and costs will be available to the “prevailing party.” (Id. ¶ 13.) That does not authorize fees incurred in enforcing the agreement, and the agreement states elsewhere that “[e]ach party shall bear his/her/their own costs and attorney’s fees, except as provided herein.” (Id. ¶ 7.)

Moving party to give notice, unless waived.

IT IS SO ORDERED.

Dated: February 19, 2020 ___________________________________

Randolph M. Hammock

Judge of the Superior Court

Any party may submit on the tentative ruling by contacting the courtroom via email at Smcdept47@lacourt.org


[1] Plaintiff’s contention that she did not sign the agreement or did not know what she was signing is discussed below.

Case Number: BC682898    Hearing Date: December 31, 2019    Dept: 47

Andreas Kratky, et al. v. Downtown Prime LLC, et al.

 

MOTION TO ENFORCE THE SETTLEMENT AGREEMENT AND ENTER JUDGMENT UPON THE SETTLEMENT AGREEMENT PURSUANT TO CCP § 664.6

MOVING PARTY: Defendants Downtown Prime, LLC; Moses Babazadeh; David Baradarian; and Pedram Yadidsion

RESPONDING PARTY(S): Plaintiff Jenna King

STATEMENT OF MATERIAL FACTS AND/OR PROCEEDINGS

Plaintiffs alleged that Defendants illegally converted an industrial unit to apartment units rented out to Plaintiffs.

Defendants move to enforce the parties’ settlement agreement and for judgment to be entered on the settlement agreement.

TENTATIVE RULING:

Defendants Downtown Prime, LLC, Moses Babazadeh, David Baradarian, and Pedram Yadidsion’s motion to enforce the settlement agreement and enter judgment upon the settlement agreement pursuant to CCP § 664.6 is GRANTED. The case is ordered dismissed with prejudice.

DISCUSSION:

Motion To Enforce Settlement Agreement and Enter Judgment on Settlement Agreement

Defendants move for an order enforcing the terms of their settlement agreement with Plaintiff Jenna King and/or for the Court to enter judgment pursuant to the terms of the settlement and for attorney’s fees and costs of $2,122.50 incurred in enforcing this agreement. Defendants bring this motion under CCP § 664.6, which provides:

If the parties to pending litigation stipulate, in a writing signed by the parties outside the presence of the court or orally before the court, for settlement of the case, or part thereof, the court, upon motion, may enter judgment pursuant to the terms of the settlement. If requested by the parties, the court may retain jurisdiction over the parties to enforce the settlement until performance in full of the terms of the settlement.

(CCP § 664.6 (bold emphasis and underlining added).)

A recent published opinion emphasizes that a settlement agreement in which the parties agree that the Court will retain jurisdiction to enforce the settlement must be signed by the parties (not just their counsel) and filed with the Court before the action is dismissed. (MesaRHF Partners, L.P. v. City of Los Angeles (2019) 33 Cal.App.5th 913, 917-918.)

Here, the settlement agreement is signed by the parties[1] and states that the “court reserves jurisdiction to enforce the terms and conditions of the settlement and any arbitration award pursuant to Code of Civil Procedure 664.6 and 1281 et seq., upon noticed motion of any party, or after Judge Stone has issued the award.” (Declaration of Gloria G. Medel, Exh. 1 (“Settlement Agreement”) ¶ 13.) This agreement has been filed with the Court before dismissal; accordingly, the Court retains jurisdiction to enforce the settlement. (MesaRHF Partners, supra, 33 Cal.App.5th at 918 [“In this case, the parties could have easily invoked section 664.6 by filing a stipulation and proposed order . . . signed by the parties noting the settlement and requesting that the trial court retain jurisdiction under section 664.6.”].)

Defendant has proffered evidence of a written Settlement Agreement under which all of the Plaintiffs agreed, among other things, to (1) execute a long-form settlement agreement, (2) sign a stipulated judgment for possession of Defendant’s property, (3) move out of the property within 120 days of execution of the long-form agreement, and (4) participate in binding arbitration before Judge Stone. (Medel Decl., Exh. 1.) Nine of the named Plaintiffs have attempted to comply with the terms of the settlement according to Defendant, but Plaintiff Jenna King has not. (Id. ¶ 8.)

Plaintiff argues that the agreement is unenforceable because she did not sign the settlement agreement or did not know that she was signing it and her prior lawyers did not explain the document to her. (Oppo., at p.2.) However, Plaintiff has not come forward with any competent and persuasive evidence that her signature on the document was either forged and/or signed without her consent. Plaintiff’s primary argument as to her signature appears to be that she “thought she was signing something else” – a MediCal medical release form. (Declaration of Jenna King ¶ 5.) However, it is undisputed that Plaintiff King attended the mediation before Judge Stone in June 2019, at a time when she and the other Plaintiffs were represented by BASTA, Inc. (Medel Decl. ¶ 2 & Exh. 4.) Plaintiff’s disagreement with her then-counsel’s handling of the settlement does not negate her agreement to it, absent evidence to the contrary. Plaintiff and her son contend that she did not sign the agreement but do not present credible evidence establishing that the signature on the agreement is not hers.

Plaintiff also argues that the agreement is unenforceable as to her because she granted a durable power of attorney to her son in February 2019, before the settlement agreement was signed. (Oppo., at p. 7; Durable Power of Attorney filed 10/11/19.) The durable power of attorney does not negate Plaintiff’s ability to execute an agreement on her own behalf, however. By its terms, it states that her son Brandon King “may act separately” on her behalf. (Durable Power of Attorney filed 10/11/19.) It does not indicate that Plaintiff is without capacity to act on her own.

The general rule is that when a person with the capacity of reading and understanding an instrument signs it, he is, in the absence of fraud and imposition, bound by its contents, and is estopped from saying that its explicit provisions are contrary to his intentions or understanding.

(Larsen v. Johannes (1970) 7 Cal.App.3d 491, 501.)

Finally, Plaintiff argues that the agreement is unenforceable because it does not set forth the allocation of the settlement amount among the Plaintiffs. Plaintiff relies on Gauss v. GAF Corp. (2002) 103 Cal.App.4th 1110 to support this argument. That case is distinguishable, however. In Gauss, having already found the agreement unenforceable for another reason, the Court also determined that it was unenforceable because it did not specify “the amount GAF was obligated to pay.” (Id. at 1123.) The Court had to “reach beyond the settlement letters and rely on subsequent letters” to determine how much GAF was obligated to pay. (Ibid.) In this case, in contrast, there is no ambiguity regarding the amount Defendants are required to pay to the Plaintiffs. Defendants are to pay Plaintiffs “the total of sum of $1,000,000.” (Medel Decl., Exh. 1, ¶ 2.) The agreement also states that Plaintiffs’ counsel “may release $20,000.00 per plaintiff” once the funds are received to assist with relocation expenses, but that “Plaintiffs’ counsel must not release the balance of the funds to any plaintiff prior to that plaintiff vacating the unit/premises and returning the keys to plaintiffs’ counsel.” (Id. ¶ 3.) That the agreement does not specify the allocation of the funds among the Plaintiffs does not render it unenforceable.

As such, the motion to enforce the settlement agreement is GRANTED. The case is ordered dismissed with prejudice.

Defendant’s request for attorney’s fees incurred in enforcing the settlement agreement is DENIED. Defendant does not cite any provision in the Settlement Agreement whereby the parties seeking to enforce the settlement agreement may recover attorney’s fees incurred in enforcing the settlement agreement. Defendant points to Paragraph 13 of the Settlement Agreement, but that paragraph states only that fees and costs will be available to the “prevailing party.” (Id. ¶ 13.) That does not authorize fees incurred in enforcing the agreement, and the agreement states elsewhere that “[e]ach party shall bear his/her/their own costs and attorney’s fees, except as provided herein.” (Id. ¶ 7.)

Moving party to give notice, unless waived.

IT IS SO ORDERED.

Dated: December 31, 2019 ___________________________________

Randolph M. Hammock

Judge of the Superior Court

Any party may submit on the tentative ruling by contacting the courtroom via email at Smcdept47@lacourt.org


[1] Plaintiff’s contention that she did not sign the agreement or did not know what she was signing is discussed below.

Case Number: BC682898    Hearing Date: November 12, 2019    Dept: 47

Andreas Kratky, et al. v. Downtown Prime LLC, et al.

 

MOTION TO BE RELIEVED AS COUNSEL

MOVING PARTY: BASTA, Inc. (including Daniel J. Bramzon and Eric Post), counsel for Plaintiff Jenna King

RESPONDING PARTY(S): No opposition filed.

STATEMENT OF MATERIAL FACTS AND/OR PROCEEDINGS

Plaintiffs alleged that Defendants illegally converted an industrial unit to apartment units rented out to Plaintiffs.

BASTA, Inc. (and its attorneys) are moving to be relieved as attorneys of record for Plaintiff Jenna King only.

TENTATIVE RULING:

BASTA, Inc. (including Daniel J. Bramzon and Eric Post)’s motion to be relieved as counsel is GRANTED. The order will be effective upon filing a Proof of Service with the Court demonstrating that the client was served with a copy of this ruling and a copy of the Order Granting Attorney's Motion to Be Relieved as Counsel – Civil (Form MC-053), completely filled out. Moving counsel is also to specify which of the three addresses listed in Paragraph 6 of MC-053 is the client’s current address, unless all of them are.

DISCUSSION:

Motion To Be Relieved As Counsel

Attorneys BASTA, Inc. (including Daniel J. Bramzon and Eric Post) move to be relieved as counsel for Plaintiff Jenna King.

The Court may issue an order allowing an attorney to withdraw from representation, after notice to the client. (CCP § 284(2).) California Rules of Court, Rule 3.1362 requires that the following Mandatory Judicial Council forms be filed for a motion to be relieved as counsel: Notice of Motion and Motion to Be Relieved as Counsel--Civil (form MC-051); Motion to Be Relieved as Counsel--Civil (form MC-052); and Order Granting Attorney's Motion to Be Relieved as Counsel--Civil (form MC-053). (See CRC Rule 3.1362(a), (c), (e).) These three forms must be served on the client and all other parties who have appeared in the case. (Rule 3.1362(d).)

Here, moving counsel filed all three required forms, and moving counsel’s proof of service indicates that all three forms were served on the parties.

In their declaration, moving counsel state that there has been a breakdown in the attorney-client relationship as a result of irreconcilable differences. (MC-052 ¶ 2.) In general, an attorney may withdraw with or without cause as long as the withdrawal would not result in undue prejudice to the client’s interest – i.e., counsel cannot withdraw at a critical point in the litigation, because that would prejudice client, but can withdraw otherwise. (Ramirez v. Sturdevant (1994) 21 Cal. App. 4th 904, 915.) The court has discretion to deny an attorney’s request to withdraw where the withdrawal would work an injustice or cause undue delay in the proceeding, but the court’s discretion in this area is one to be exercised reasonably. (Mandell v. Superior Court (1977) 67 Cal.App.3d 1, 4.)

Here, an OSC Re: Dismissal as a result of settlement of the case is scheduled for the day after this motion is to be heard. Because this order will not be effective until after moving counsel has filed certain documents as discussed below, and because the declaration listed the OSC hearing date but the proposed order did not, they will continue to represent Plaintiff in the hearing on November 13. After that, there are no additional hearings scheduled at this time, and therefore it does not appear that Plaintiff – who could choose to represent herself in pro per – would be prejudiced by allowing her attorney to withdraw after November 13.

Accordingly, the motion to be relieved as counsel is GRANTED. This order will be effective only upon filing a Proof of Service with the court demonstrating that the client was served with a copy of this ruling and a copy of the Order Granting Attorney's Motion to Be Relieved as Counsel – Civil (Form MC-053), completely filled out, including any additional hearings that may be scheduled. Moving counsel is also to specify which of the three addresses listed in Paragraph 6 of MC-053 is the client’s current address, unless all of them are.

Moving counsel to give notice, unless waived.

IT IS SO ORDERED.

Dated: November 12, 2019 ___________________________________

Randolph M. Hammock

Judge of the Superior Court