J & J Sports Productions, Inc. v. Maravilla

Filing 6

ORDER signed by Senior Judge William B. Shubb on 2/28/13 CONTINUING Initial Scheduling Conference to 5/28/2013 at 02:00 PM in Courtroom 5 (WBS) before Senior Judge William B. Shubb. Joint Status Report due no later than 5/14/13. (Manzer, C)

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Thomas P. Riley, SBN 194706
LAW OFFICES OF THOMAS P. RILEY, P.C.
First Library Square
1114 Fremont Avenue
South Pasadena, CA 91030-3227
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff
J & J Sports Productions, Inc.
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

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J & J SPORTS PRODUCTIONS, INC.,

CASE NO. 2:12-cv-02899-WBS-EFB

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Plaintiff,

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v.

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BLANCA E. MARAVILLA,

PLAINTIFF’S EX PARTE
APPLICATION FOR AN ORDER
CONTINUING INITIAL SCHEDULING
CONFERENCE; AND ORDER
(Proposed)

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Defendant.
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TO THE HONORABLE MICHAEL J. SENG, THE DEFENDANT/S AND THEIR
ATTORNEY/S OF RECORD:

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Plaintiff J & J Sports Productions, Inc., hereby applies ex parte for an order continuing the

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Initial Scheduling Conference presently set for Monday, March 18, 2013 at 2:00 PM. As set forth

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below Plaintiff respectfully requests that the Court continue the Initial Scheduling Conference to a new

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date approximately Thirty (30) to Forty-Five (45) days forward.
The request for the brief continuance is necessitated by the fact that Plaintiff has not yet

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perfected service of the initiating suit papers upon the Defendant Blanca E. Maravilla, individually

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and d/b/a Las Palmas Mexican Restaurant. As a result, Plaintiff’s counsel has not conferred with the

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defendant concerning the claims, discovery, settlement, ADR or any of the other pertinent issues

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involving the case itself or the preparation of a Joint Scheduling Report.
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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
INITIAL SCHEDULING CONFERENCE; AND ORDER (Proposed)
CASE NO. 2:12-cv-02899-EBS-EFB

Plaintiff recently identified an alternative address that it believes will be successful to serve

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its initiating suit papers, upon the Defendant.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court continue the Initial

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Scheduling Conference, presently scheduled for Monday, March 18, 2013 at 2:00 PM.

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Respectfully submitted,

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Dated: February 28, 2013
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/s/ Thomas P. Riley
LAW OFFICES OF THOMAS P. RILEY, P.C.
By: Thomas P. Riley
Attorneys for Plaintiff
J & J Sports Productions, Inc.

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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
INITIAL SCHEDULING CONFERENCE; AND ORDER (Proposed)
CASE NO. 2:12-cv-02899-EBS-EFB

ORDER

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It is hereby ordered that the Initial Scheduling Conference in civil action number 2:12-cv-02899-

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WBS-EFB styled J & J Sports Productions, Inc. v. Maravilla, is hereby continued from 2:00 PM,

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Monday, March 18, 2013 to May 28, 2013 at 2:00 p.m. A Joint Status report shall be filed no later

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than May 14, 2013.
Plaintiff shall serve a copy of this Order on the Defendant and thereafter file a Certification of

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Service of this Order with the Clerk of the Court.

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IT IS SO ORDERED:
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DATED: February 28, 2013
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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
INITIAL SCHEDULING CONFERENCE; AND ORDER (Proposed)
CASE NO. 2:12-cv-02899-EBS-EFB

PROOF OF SERVICE (SERVICE BY MAIL)

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I declare that:

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I am employed in the County of Los Angeles, California. I am over the age of eighteen years

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and not a party to the within cause; my business address is 1114 Fremont Avenue, South Pasadena,

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California. I am readily familiar with this law firm's practice for collection and processing of

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correspondence/documents for mail in the ordinary course of business.

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On February 28, 2013, I served:

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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
INITIAL SCHEDULING CONFERENCE; AND ORDER (Proposed)

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On all parties in said cause by enclosing a true copy thereof in a sealed envelope with postage
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prepaid and following ordinary business practices, said envelope was duly mailed and addressed to:

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Blanca E. Maravilla (Defendant)
1021 N. Main Street
Manteca, CA 95337

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I declare under the penalty of perjury pursuant to the laws of the United States that the
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foregoing is true and correct, and that this declaration was executed on February 28, 2013, at South
Pasadena, California.

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Dated: February 28, 2013

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/s/ Maria Baird
MARIA BAIRD

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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
INITIAL SCHEDULING CONFERENCE; AND ORDER (Proposed)
CASE NO. 2:12-cv-02899-EBS-EFB