Raman v. Kuldeep, et al.

(34) Tentative Ruling

Re: Raman v. Kuldeep, et al. Superior Court Case No. 25CECG00571

Hearing Date: May 7, 2026 (Dept. 403)

Motion: Motion to be Relieved as Counsel

Tentative Ruling:

The court intends to deny counsel for defendants Arora Express, Inc. and Arora Trans, Inc.’s motions to be relieved as counsel, without prejudice. (Cal. Rules of Court, rule 3.1362(d).)

Explanation:

Counsel’s declaration in support of both motions indicates the client corporations received notice of the motion to withdraw by personal service of the moving papers. (Declaration, Item 3a(1).) There is a proof of service demonstrating the Mohit Arora was personally served on March 14, 2026 on behalf of Arora Express, Inc.,, however there is no indication on the proof of service as to the relationship of this person to the corporation purportedly served. As such, the proof of service is defective.

Similarly, there is no proof of service to support the attestation that Arora Trans, Inc. was personally served. There is a declaration of non-service indicating the person intended to be served on behalf of the corporation was out of the country in India and a later filed proof of service by substitute service on an unnamed person. This is not personal service as described in the declaration in support of the motion.

In addition to inadequate notice of the motion to the clients, the motions do not confirm the clients’ last know addresses as each was purportedly confirmed by personally serving the client. The proofs of service indicate service at an address on Grantland Avenue but the Orders filed for each motion provide a “current” address on Beechwood Avenue.

Moreover, counsel has not provided sufficient evidence that all parties having appeared in the action were served with notice of the motions before the hearing. Under Rule of Court, rule 3.1362(d), “The notice of motion and motion, the declaration, and the proposed order must be served on the client and on all other parties who have appeared in the case. The notice may be by personal service, electronic service, or mail.” (Cal. Rules of Court, rule 3.1362(d).) The motions at bench have not been served on the other parties who have appeared in the action.