Joanna Cruz v. City of Los Angeles, et al.

failed to file a memorandum of costs, or any supporting documentation for these costs. (Opp. p. 10:1-4.) The Court disagrees. While an initial memorandum of costs acts as "prima facie evidence" of a plaintiff's costs, it is not the exlusive method for verifying costs incurred. Here, Plaintiff provided the sworn declaration of Yasha Ahoubim, who attests to the authenticity of the list of costs attached to the motion. (Ahoubim Decl. P. 8; see also, Ex. A.) Having reviewed these verified costs requests, the Court sees nothing facially objectionable about any of them.

Given that Defendant raised no specific objections to these costs, Court sees no reason to reduce them. (Opp. pp. 9:15-10:4.) For these reasons, the Court declines to strike any of Plaintiff's $3,389.76 in costs. E. Summary In summary, the Court declines to apply a 1.5 lodestar multiplier to this case. Additionally, the Court reduces the hourly rate of Plaintiff's attorney to $350. Next, the Court reduces the total hours billed by Plaintiff from 54.4 to 37.6 hours. Based on Plaintiff's adjusted hours and hourly rates, the Court recalculates Plaintiff's reasonable attorney fees at $13,160.00.

Finally, the Court grants Plaintiff's request for $3,389.76 in costs. In total, the Court GRANTS Plaintiff's Motion for Attorney Fees in the modified amount of $16,549.76.

Conclusion

The Court GRANTS Plaintiff's Motion for Attorney Fees, in the modified amount of $16,549.76. IT IS SO ORDERED, Plaintiff TO GIVE NOTICE. August 28, 2026 _____________________ _____ Judge of the Superior Court

COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - NORTHWEST DISTRICT JOANNA CRUZ, Plaintiff, vs. CITY OF LOS ANGELES, COUNTY OF LOS ANGELES, AND DOES 1TO 25, INCLUSIVE, Defendants. | | CASE NO: 25VECV05747 [TENTATIVE]

ORDER RE: MOTION TO BE RELIEVED AS COUNSEL Dept. W 8:30 a.m. August 28, 2026 | | | | [TENTATIVE] ORDER: The Court GRANTS the Law Offices of Sharona Eslamboly Hakim and Sharona Eslamboly Hakim, Esq.'s Motion to be Relieved as Counsel.

Background

This is a city sidewalk slip and fall case. Plaintiff Joanna Cruz alleges that on September 16, 2024, she was seriously injured when she tripped and fell on the sidewalk, maintained by Defendants The City of Los Angeles, and The County of Los Angeles. On October 8, 2025, Plaintiff brought suit against Defendants alleging general negligence and premises liability. Now, Plaintiff's representative, the Law Offices of Sharona Eslamboly Hakim and Sharona Eslamboly Hakim, Esq. (herein "counsel"), moves to be relieved as Plaintiff's counsel.

Discussion

Counsel moves to be relieved as Plaintiff's counsel. The requirements for a Motion to be Relieved as Counsel are outlined in CRC 3.1362. Moving counsel must: (1) submit form MC-051 - notice of the motion to the client, (2) submit form MC-052 - a declaration explaining why they could not acquire client's consent to withdraw, (3) submit form MC-053 - a copy of the proposed order, and (4) serve these documents and notice of the motion to both the client and all other parties in the case. (Cal. Rules of Court, rule 3.1362(a)-(e).)

Additionally, relief cannot be granted if it is reasonably foreseeable that the client would suffer prejudice as a result of the withdrawal. (Mossanen v. Monfared (2000) 77 Cal.App.4th 1402, 1409.) First, counsel has submitted Form MC-051 and has served Plaintiff with notice of this motion. (Motion to be Relieved, MC-051.) Second, counsel has submitted Form MC-052, stating that: "Plaintiff's counsel is unable to communicate with client such that Plaintiff's counsel can no longer represent the plaintiff.

Plaintiff has not responded to letters sent and all numbers and back up numbers are disconnected." (Declaration in Support, P. 2.) Third, counsel submitted a copy of the proposed order via Form MC-053. (Proposed Order, MC-053.) Fourth, counsel served these documents onto all parties in this case. (MC-051, Proof of Service, 7/9/26.) Thus, counsel has met all the procedural requirements under CRC 3.1362.

Finally, the Court must determine whether it is reasonably foreseeable that the client will suffer prejudice as a result of this withdrawal. Here, there are no motions scheduled in this case. The most imminent hearing is a post-mediation status conference scheduled for October 5, 2027. Thus, is it not reasonably foreseeable that Plaintiff could be prejudiced by this withdrawal. For these reasons, the Court GRANTS counsel's Motion to be Relieved as Counsel.

Conclusion

The Court GRANTS the Law Offices of Sharona Eslamboly Hakim and Sharona Eslamboly Hakim, Esq.'s Motion to be Relieved as Counsel. IT IS SO ORDERED, Plaintiff TO GIVE NOTICE. August 28, 2026 _____________________ _____ Judge of the Superior Court | Home -->)" -->