Flores v. VP Security Services, Inc.

LINE # CASE # CASE TITLE RULING LINE 1 21CV376477 Rodriguez-Lopez v. Toray Advanced Motion: Final Approval Composites, Inc. (Class Action) Granted May 15, 2026

Parties need not appear LINE 2 21CV379924 Flores v. VP Security Services, Inc. Motion: Withdraw as (PAGA) attorney is GRANTED

Click on line 2 for tentative ruling LINE 3 23CV424953 Schenk v. Smith's GTS, Inc. (Class Motion: Preliminary Action/PAGA) Approval is GRANTED

Click on line 3 for tentative ruling LINE 4 24CV434602 Urzua v. Lyten, Inc. (Class Hearing: Motion for Action/PAGA) Approval is GRANTED

Click on line 4 for tentative ruling LINE 5 25CV467513 Bucks County Employees' Retirement Motion: Consolidate is System et al vs Timothy Cook et al DENIED

Click on line 5 for tentative ruling lines 5,7 and 8 LINE 6 25CV468388 Delmy Landverde vs Lusamerica Hearing: Motion to Compel Foods, Inc., a California corporation Arbitration is GRANTED

Click on line 6 for tentative ruling LINE 7 25CV472876 Kevin Anguka vs Timothy Cook et al Motion: Consolidate

Click on line 5 LINE 8 25CV473618 City of Hialeah Employees' Motion: Consolidate Retirement System et al vs Timothy Cook et al Click on line 5 LINE 9 LINE 10 LINE 11 LINE 12 LINE 13

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Case Name: Flores v. VP Security Services, Inc. Case No.: 21CV379924

This is a representative action under the Private Attorneys General Act (“PAGA”). Plaintiff Jessica Flores alleges defendant VP Security Services, Inc. committed various wage and hour violations.

Before the Court is the motion to be relieved as counsel by Plaintiff’s counsel William L. Marder (“Marder”) and Dennis S. Hyun (“Hyun”) (collectively, “Counsel”), which is unopposed. For reasons discussed below, Counsel’s motion is GRANTED.

I. MOTION TO BE RELIEVED AS COUNSEL

A.

Legal Standard

Motions to be relieved as counsel are technical and governed by Rules of Court, rule 3.1362 (“Rule 3.1362”). Notice and motion must be directed to the client on Judicial Council Form MC-051. No memorandum is required. (Rule 3.1362(a) & (b)). Counsel must provide a declaration on Judicial Council Form MC-052 stating “in general terms and without compromising the confidentiality of the attorney-client relationship why a motion under Code of Civil Procedure section 284(2) is brought instead of filing a consent under Code of Civil Procedure section 284(1).” (Rule 3.1362(c)).

The notice of motion and motion, the declaration, and the proposed order must be served on the client and all parties “by personal service, electronic service, or mail.” (Rule 3.1362(d)).

(1) If the notice is served on the client by mail under Code of Civil Procedure section 1013, it must be accompanied by a declaration stating facts showing that either:

(A) The service address is the current residence or business address of the client; or

(B) The service address is the last known residence or business address of the client and the attorney has been unable to locate a more current address after making reasonable efforts to do so within 30 days before the filing of the motion to be relieved.

(Rule 3.1362(d).)

The proposed order relieving counsel must be prepared on the Order Granting Attorney’s Motion to Be Relieved as Counsel—Civil (form MC-053) and must be lodged with the court with the moving papers. The order must specify all hearing dates scheduled in the action or proceeding, including the date of trial, if known. If no hearing date is presently scheduled, the court may set one and

specify the date in the order. After the order is signed, a copy of the signed order must be served on the client and on all parties that have appeared in the case. The court may delay the effective date of the order relieving counsel until proof of service of a copy of the signed order on the client has been filed with the court.

(Rule 3.1362(e).)

B.

Discussion

Here, Counsel submitted their respective declarations, which state that Plaintiff has ceased all communications with them despite repeated attempts to follow up with her. (Marder Dec., ¶ 2; Hyun Decl., ¶ 2.)

Counsel stated they served Plaintiff by mail at her last known address with copies of the motion papers served with the declarations. (Marder Decl., ¶ 3(a); Hyun Decl., ¶ 3(a).) The Court previously continued the hearing on the instant motion to allow Counsel the opportunity to submit a supplemental declaration providing additional details about their efforts to contact Plaintiff. On May 4, 2026, Hyun accordingly submitted a supplemental declaration (“Hyun Supp. Decl.”). He states, on August 22, 2025, Counsel conducted a skip-trace and obtained several new telephone numbers and an address in North Dakota. (Hyun Supp.

Decl., ¶ 3.) Counsel sent a messenger to the North Dakota address, however, the occupants refused to open the door or speak to the messenger. (Ibid.) Counsel sent a messenger to Plaintiff’s last known address in Hayward, California, but was informed by the occupants that Plaintiff did not reside there. (Ibid.) Staff for Counsel called all the telephone numbers obtained from the skip trace and only telephone number that was answered belonged to Plaintiff’s mother. (Ibid.) On September 10, 2025, Plaintiff responded to one of the emails by Counsel and informed them that she preferred to communicate via email but she informed Counsel that she no longer wanted to pursue this case and instructed Counsel to stop contacting her. (Ibid.)

On April 30, 2026, Counsel ran an additional skip trace and the same telephone numbers and addresses were obtained. (Ibid.) On the same day, Counsel sent another email to Plaintiff. (Ibid.) On May 1, 2026, Counsel called Plaintiff’s last known telephone number and as of the date of Hyun’s declaration, they had not received a response. The Court finds Counsel sufficiently details their efforts to contact Plaintiff.

Counsel provides a proposed order on the correct judicial counsel form (MC-053). The proposed order states the next hearing was on December 18, 2025, for a further case management conference. This date was continued to April 30, 2026, and it is now set for May 21, 2026, to be heard on the same day as the instant motion. The Court’s docket does not reflect any other scheduled hearings.

Based on the foregoing, Counsel’s motion is GRANTED.

II. CONCLUSION

The motion to be relieved as counsel is GRANTED.

The Court will prepare the order.

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