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Ronald v BofA Motion 3-28-2011 Unlocked]

Ronald v BofA Motion 3-28-2011 Unlocked]

Ratings: (0)|Views: 1,108 |Likes:
Published by Karl Denninger
Ronald .v. BOA Motion
Ronald .v. BOA Motion

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Published by: Karl Denninger on Mar 31, 2011
Copyright:Attribution Non-commercial

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01/04/2013

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1
3
4
5
6
'7
B
9
1011
L213
t4
15L6
1-'1
Kenin
M.
Spivak
(SBN
97996)
Theodore
Maloney
(SBN
125094)Dennis
M.
Russell
(SBN
118253)
SML LLP
450
North
Roxbury
Drive,
Suite
700
Beverly
Hills,
Califomia
90210
Tel:
310-691-5811
Fax:
310-691-5809E-mail
:
kspivak@SMllawgroup.com
tmaloney
@S
ML
lawgroup.
com
drussell@S
MLlawgroup.comChristopher Tomaszewski
(SBN255061)Bridget
Jones
(SBN256086)
APEX
LEGAL
GROUP
PC1801
Tribute
Road
Sacramento,
California
95
8
1
5
Tel:
(916)270-2022
Fax:
(916)
644-6227
E-mail:
chris@apexlegal.org
Attorneysfor
Moving
Parties
T}RIGIF{AfuFIIED
F{AR
e
I
?CIir
f*ils,EN{iHLES
EL]THRIL}R
COIJRT
SUPERIORCOURTOF
THESTATE
OF
CALIFORNIA
COUNTY
OF
LOS
ANGELES
PAUL RONALD
etc.,
et
a1.,
Plaintiffs,
VS.
BANK
OF
AMERICA
CORPORATION,
etc., et al.,
Case
No.
8C409444
[Assigned
for
all
purposes
to
Hon.
William
F.Highberger, Dept.
3071
NOTICE
OF
MOTION
AND
MOTION
TO
REMOVE
MITCHEL
J.
STEIN
AS
CO-LEAD
COUNSEL
FORPLAINTIFFS AND
AS
COUNSELFORSPECIFIED
PLAINTIFFS. TOCOMPEL STEIN TO TURN OVERENGAGEMENTAGREEMENTS
ANDFOR
AN ACCOUNTING;
MEMORANDUM
OF POINTS AND
AUTHORITIES;
DECLARATIONS
OF
CHRTSTOPHER
TOMASZEWSKI,KENIN M. SPIVAK. TED
MALONEY
MOTION
TO
REMOVE
MITCHELL
J.
STEIN
 
 
2MOTION TO REMOVE MITCHELL J. STEIN
12345678910111213141516171819202122232425262728
)))))))
AND BRIDGET JONES; EXHIBITS
Action Filed: March 12, 2009Date:Time:Department: 307Discovery Cut-Off: Not SetTrial Date: Not Set
TO THIS HONORABLE COURT AND TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN:PLEASE TAKE NOTICE
that on May 3, 2011, at 9:00 A.M. in Department 307 of theabove referenced court located at 600 South Commonwealth Avenue, Los Angeles, CA. 90005Plaintiffs, through their counsel, SML LLP, Apex Legal Group P.C., Kenin M. Spivak,Christopher Tomaszewski, Bridget Jones and Ted Maloney (collectively, “
Moving Parties
”)will move this Court for an Order seeking the following relief (the “
Requested Relief 
”):(a)
 
To relieve attorney Mitchell J. Stein (“
Stein
”) of his position as co-lead counsel onbehalf of Plaintiffs in this litigation;(b)
 
To relieve Stein and Erikson S. Davis (“
Davis
”) from rendering any further legalservices for clients who have retained or retain any or all of Jones, Tomaszewski,Apex Legal Group P.C. (“
Apex
”), Spivak, Spivak Law Group, or SML LLP(“
SML
”), except those plaintiffs who file and do not revoke a written objectionthereto within thirty (30) days after the entry of an order for the Requested Relief;(c)
 
To require Stein and Davis to produce to Moving Parties copies of: (1) allcorrespondence with the clients for whom Stein is relieved from providing services,(2) all correspondence with Defendants as to which Moving Parties were not copied,(3) all discovery propounded on Defendants or received from Defendants, (4)transcripts in hard copy and disc form for all individuals who have been deposed byStein or Davis in this action, and (5) all other information necessary or appropriate for a smooth transition, all within sixty (60) days after the entry of an order for theRequested Relief;(d)
 
To require Stein and Davis to deliver to Moving Parties accountings of their time in
 
 
3MOTION TO REMOVE MITCHELL J. STEIN
12345678910111213141516171819202122232425262728
the matter for use in any lodestar computations made at the time the lawyers in thismatter become entitled to any fees, all within sixty (60) days after an entry of an order for the Requested Relief;(e)
 
To require Stein and Davis to produce to Moving Parties or a third party designatedby this Court copies of all engagement agreements ever existing, whether proposed,sent, received, signed or unsigned and all modifications, amendments, supplementsand replacements with respect thereto, whether proposed, sent, received, signed or unsigned, by which either of them will or might render services and/or will or mightdirectly or indirectly receive financial benefits pertaining to all or any: (1) namedplaintiffs in this action, other than those plaintiffs who were disclosed and named onthe initial Complaint, First Amended Complaint or Second Amended Complaint, (2)potential plaintiffs in this
 
action and/or (3) potential plaintiffs in any other actionagainst all or any of the defendants in this
 
action, within ten (10) days after entry of an order for the Requested Relief;(f)
 
To require Stein and Davis to produce to Moving Parties copies of all literature or other materials, except only personalized discussions in which Stein or Davis providespecific legal advice (whether delivered electronically, by mail, or otherwise) used inor in connection with the solicitation of the proposed plaintiffs set forth in the exparte notice sent by Davis on February 9, 2011 and any other plaintiffs proposed to beadded by amendment to this action during 2011; and(g)
 
To require Stein and Davis to produce to Moving Parties an accounting of any and allfinancial benefits received or accrued directly or indirectly by either of them and/or any of the family members, partners, associates, nominees, representatives or designees of either or both of them, including, without limitation, benefits by way of the services of lawyers, paralegals, secretaries and other support services, offices,equipment and otherwise from, on behalf of, or appertaining to: (1) named plaintiffsin this action, (2) potential plaintiffs in this
 
action and (3) potential plaintiffs in anyother action against all or any of the defendants in this
 
action, all within sixty (60)

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