SANCHEZ vs FORD MOTOR COMPANY, A DELAWARE CORPORATION, et al.

24CV016458: SANCHEZ vs FORD MOTOR COMPANY, A DELAWARE CORPORATION, et al. 07/27/2026 Hearing on Motion to be Relieved as Counsel in Department 8C

https://saccourt.ca.gov/home/showpublisheddocument/227/639084034465370000.

A Stipulation and Appointment of Official Reporter Pro Tempore (CV/E-206) is required to be signed by each party, the private court reporter, and the Judge prior to the hearing, if not using a reporter from the Court’s Approved Official Reporter Pro Tempore list.

Once the form is signed it must be filed with the clerk. If a litigant has been granted a fee waiver and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211) and it must be filed with the clerk at least 10 days prior to the hearing or at the time the proceeding is scheduled if less than 10 days away. Once approved, the clerk will forward the form to the Court Reporter’s Office and an official reporter will be provided.

TENTATIVE RULING

***NOTICE: EFFECTIVE APRIL 13, 2026, THIS DEPARTMENT HAS MOVED TO THE TANI G. CANTIL-SAKAUYE COURTHOUSE LOCATED AT 500 G STREET SACRAMENTO, CA. ALL MOTIONS NOTICED FOR DEPARTMENT 28 WILL BE HEARD IN DEPARTMENT 8C OF THE NEW COURTHOUSE. ALL PAPERS FOR THIS DEPARTMENT MUST BE FILED AT THIS NEW LOCATION AND WILL NOT BE ACCEPTED AT THE HALL OF JUSTICE. ALL HEARINGS WILL TAKE PLACE AT THIS NEW LOCATION***

Counsel Matthew Treybig’s (“Counsel”) unopposed motion be relieved as counsel for Plaintiff Carlos Jose Sanchez (“Plaintiff”) is ruled upon as follows.

In his declaration in support of the motion, Counsel states that he last had contact with Plaintiff in October of 2024. Counsel goes on to describe the significant efforts he has made to contact Plaintiff since February of 2026, all of which have been unsuccessful. This includes retaining an investigator “who made multiple visits to Plaintiff[’]s last known residence on May 9, May 12, May 17, and May 19, 2026, all without success.” (Treybig Decl., § 2.) However, Counsel later declares that Plaintiff was served with this motion via mail, and that the mailing address was confirmed as current within the past 30 days “by mail, return receipt requested.” (Treybig Decl., § 3b(1)(a).)

The signed return receipt is not included with the moving papers. The proposed order filed with the motion also indicates that the address where the moving papers were mailed is Plaintiff’s “current” address. It is not clear whether the address visited by Counsel’s investigator in May of 2026 is the same address where the motion was served.

The Court is concerned that Counsel’s declaration contradicts itself by stating that Plaintiff’s

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV016458: SANCHEZ vs FORD MOTOR COMPANY, A DELAWARE CORPORATION, et al. 07/27/2026 Hearing on Motion to be Relieved as Counsel in Department 8C

address is current while also stating that attempts to physically locate Plaintiff at potentially the same address were unsuccessful. The rules and Judicial Council forms applicable to motions to be relieved as counsel clearly contemplate a distinction between a confirmed current address and a last known address. (See Cal. Rules of Court, rule 3.1362(d)(1); see also Judicial Council Form MC-053 – Order Granting Attorney’s Motion to be Relieved as Counsel—Civil, § 6 [“If current address is not known, service must be made according to Code of Civil Procedure section 1011 (b) and rule 3.252 of the California Rules of Court”].) This is important for determining where and how to serve Plaintiff with notice of further proceedings in this case once the motion is granted and he becomes unrepresented.

Accordingly, Counsel is directed to file with the Court a supplemental declaration that attaches the signed return receipt alluded to in section 3(b)(1)(a) of Counsel’s declaration to confirm Plaintiff’s current address. Alternatively, if Counsel is unable to produce the signed return receipt, Counsel is directed to file an amended proposed order that specifies at section 6 that Plaintiff’s address is his last known address.

Upon satisfaction of one of these conditions, the Court will sign the proposed order. If Counsel confirms Plaintiff’s address, then the order will take effect upon the filing of a proof of service of the signed order on Plaintiff. (Cal. Rules of Court, rule 3.1362(e).) Alternatively, if Counsel is unable to confirm the address and the signed order states that Plaintiff’s address is his last known address, then the order will take effect on the date it is signed and entered by the Court.