Sekel

I. FACTS AND PROCEDURAL BACKGROUND

According to plaintiff’s allegations,2 he retained defendant in July 2006 to

represent him in a civil hearing in Superior Court of Georgia, County of Fulton, to

oppose issuance of a restraining order against him. At the time, plaintiff was a resident of

Georgia. Defendant contends, and plaintiff has not disputed, that she was and is a

resident of Georgia, licensed to practice law in Georgia (and not California).

The Georgia court issued a restraining order against plaintiff. Defendant did not

file an appeal of that ruling on plaintiff’s behalf. According to defendant, she declined to

do so because plaintiff failed to pay the balance of attorney fees owed, and stopped

payment on a check for her initial retainer.

On June 21, 2010, plaintiff filed two complaints against defendant in California

Superior Court, County of Riverside—one on a form complaint for actions in contract,

the other on a form complaint for personal injury, property action, or wrongful death.3 In

Case 5402, plaintiff sought $7,000,000 in damages; in Case 5404, he sought only

$4,000,000. But the two complaints are based on substantially the same allegations:

2 A…