Declaration on Motion to Withdraw Counsel — In re Bank of America California Unemployment Benefits Litigation

Summary

A 2-page declaration by Daniel L. Warshaw of Pearson, Simon & Warshaw, LLP, filed as Document 61-1 in In re Bank of America California Unemployment Benefits Litigation, Case No. 21-MD-02992-LAB-MSB, in the Southern District of California. Warshaw, the attorney principally responsible for the matter for plaintiffs Jonathan Smith and Alex Yuan, supports a motion to withdraw attorney Sophie Roz Sedaghat as their counsel. He states that as of June 30, 2021, Sedaghat is no longer associated with the firm. Under Local Rule 83.3(f)(3)(a), counsel for the defendant and the two plaintiffs have been served with the motion and declaration. He signed it at Sherman Oaks, California, on the 30th day of July, 2021.

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959261.1

Case No. 21-MD-02992-LAB-MSB
DECLARATION OF DANIEL L. WARSHAW IN SUPPORT OF MOTION TO WITHDRAW APPEARANCE OF
COUNSEL SOPHIE ROZ SEDAGHAT

PEARSON, SIMON & WARSHAW, LLP
15165 VENTURA BOULEVARD, SUITE 400
SHERMAN OAKS, CALIFORNIA 91403
DANIEL L. WARSHAW (Bar No. 185365)
   dwarshaw@pswlaw.com
BOBBY POUYA (Bar No. 245527)
   bpouya@pswlaw.com
PEARSON, SIMON & WARSHAW, LLP
15165 Ventura Boulevard, Suite 400
Sherman Oaks, CA 91403
Telephone: (818) 788-8300
Facsimile: (818) 788-8104

Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
SAN DIEGO DIVISION

IN RE; BANK OF AMERICA
CALIFORNIA UNEMPLOYMENT
BENEFITS LITIGATION

 CASE NO. 21-MD-02992-LAB-MSB

CLASS ACTION

DECLARATION OF DANIEL L.
WARSHAW IN SUPPORT OF
MOTION TO WITHDRAW
APPEARANCE OF COUNSEL
SOPHIE ROZ SEDAGHAT

Case 3:21-md-02992-GPC-MSB     Document 61-1     Filed 07/30/21     PageID.157     Page 1
of 2

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959261.1

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Case No. 21-MD-02992-LAB-MSB
DECLARATION OF DANIEL L. WARSHAW IN SUPPORT OF MOTION TO WITHDRAW APPEARANCE OF
COUNSEL SOPHIE ROZ SEDAGHAT

PEARSON, SIMON & WARSHAW, LLP
15165 VENTURA BOULEVARD, SUITE 400
SHERMAN OAKS, CALIFORNIA 91403
Daniel L. Warshaw declares:
1.
I am an attorney duly admitted to practice before this Court.  I am a
partner in the firm of Pearson, Simon & Warshaw, LLP, attorneys of record for
Plaintiffs Jonathan Smith and Alex Yuan.
2.
I am the attorney principally responsible for the handling of this matter.
I am personally familiar with the facts set forth in this declaration.  If called as a
witness I could and would competently testify to the matters stated herein.
3.
I submit this declaration in support of Motion to Withdraw Attorney
Sophie Roz Sedaghat  as counsel for Plaintiffs Jonathan Smith and Alex Yuan.
4.
As of June 30, 2021, Ms. Sedaghat is no longer associated with the law
firm of Pearson, Simon & Warshaw, LLP.
5.
Per Rule 83.3(f)(3)(a) of the Local Rules of the United States District
Court for the Southern District of California, Counsel for Defendant and Plaintiffs
Jonathan Smith and Alex Yuan has been served with the motion to withdraw and
declaration.
I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct.
Executed on this 30th day of July, 2021, at Sherman Oaks, California.

/s/ Daniel L. Warshaw

Daniel L. Warshaw

Case 3:21-md-02992-GPC-MSB     Document 61-1     Filed 07/30/21     PageID.158     Page 2
of 2

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