J & J Sports Productions, Inc. v. Thao

Filing 6

ORDER signed by Senior Judge William B. Shubb on 3/2/2015 GRANTING 4 Plaintiff's Ex Parte Application continuing the Scheduling Conference to 4/27/2015 at 02:00 PM in Courtroom 5 (WBS) before Senior Judge William B. Shubb. A Joint Status Report shall be filed no later than April 13, 2015. (Kirksey Smith, K)

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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
SACRAMETNO DIVISION

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J & J SPORTS PRODUCTIONS, INC.,

CASE NO. 2:14-cv-02669-WBS-AC

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Plaintiff,

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v.

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MANG PHENG THAO,

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

Defendant.

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TO THE HONORABLE WILLIAM B. SHUBB, THE DEFENDANT AND HIS

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ATTORNEY/S OF RECORD:
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 16, 2015 at 2:00 PM. As set forth
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.
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The request for the brief continuance is necessitated by the fact that Plaintiff has not yet
perfected service of the initiating suit papers upon the Defendant Mang Pheng Thao, individually

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and d/b/a Sunrise 2 Sunset Grill. As a result, Plaintiff’s counsel has not conferred with the defendant

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

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case itself or the preparation of a Joint Status Report.

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In addition, Thomas P. Riley, Plaintiff’s counsel in this action, has calendaring conflicts on
Monday, March 16, 2015 as Mr. Riley is scheduled to appear before the Honorable David R.

PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
INITIAL SCHEDULING CONFERENCE; AND ORDER (Proposed)
CASE NO. 2:14-cv-02669-WBS-AC

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Strawbridge of the U.S.D.C. for the Eastern District of Pennsylvania, Philadelphia Division in the

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matter of J & J Sports Productions, Inc. v. Baldino, et al.,; Case No. 2:14-cv-02444-AB for a Follow-

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Up Status Telephone Conference re: Settlement matter and Scheduling a Settlement Conference at 4:30

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P.M. (EDT) that very same day (ECF# 25); and a Initial Scheduling Conference before Honorable

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William B. Shubb of the U.S.D.C. for the Eastern District of California, Sacramento Division in the

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matter of J & J Sports Productions, Inc. v. Hamad,; Case No. 2:14-cv-02728-WBS-DAD at 2:00 P.M.
that very same day (ECF# 3) as well.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court continue the Initial

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Scheduling Conference, presently scheduled for Monday, March 16, 2015 at 2:00 PM.
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Respectfully submitted,

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Dated: March 2, 2015

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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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ORDER

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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
INITIAL SCHEDULING CONFERENCE; AND ORDER (Proposed)
CASE NO. 2:14-cv-02669-WBS-AC

It is hereby ordered that the Initial Scheduling Conference in civil action number 2:14-cv-02669-

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WBS-AC styled J & J Sports Productions, Inc. v. Thao, is hereby continued from 2:00 PM, Monday,

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March 16, 2015 to April 27, 2015 at 2:00 p.m. A Joint Status Report shall be filed no later than April

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13, 2015, and shall include a response by the defendant.
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:
Dated: March 2, 2015

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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,
California. I am readily familiar with this law firm's practice for collection and processing of
correspondence/documents for mail in the ordinary course of business.
PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
INITIAL SCHEDULING CONFERENCE; AND ORDER (Proposed)
CASE NO. 2:14-cv-02669-WBS-AC

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On March 2, 2015, I caused to serve the following documents entitled:

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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE
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
prepaid and following ordinary business practices, said envelope was addressed to:

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Mang Pheng Thao (Defendant)
10113 Folsom Boulevard, Suites C-D
Rancho Cordova, CA 95670

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The fully sealed envelope with pre-paid postage was thereafter placed in our law firm’s
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outbound mail receptacle in order that this particular piece of mail could be taken to the United States
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Post Office in South Pasadena, California later this day by myself (or by another administrative
assistant duly employed by our law firm).
I declare under the penalty of perjury pursuant to the laws of the United States that the foregoing

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is true and correct, and that this declaration was executed on March 2, 2015, at South Pasadena,

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California.

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Dated: March 2, 2015

/s/ Vanessa Morales
VANESSA MORALES

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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
INITIAL SCHEDULING CONFERENCE; AND ORDER (Proposed)
CASE NO. 2:14-cv-02669-WBS-AC