Pacific Information Resources, Inc. v. Simple Communications et al

Filing 17

ORDER GRANTING PLAINTIFF'S REQUEST TO CONTINUE. Plaintiff shall file its application for default judgment not later than February 15, 2008. The Case Management Conference is continued from February 8, 2008 to May 2, 2008. Signed by Judge Maxine M. Chesney on February 4, 2008. (mmclc1, COURT STAFF) (Filed on 2/4/2008)

Pacific Information Resources, Inc. v. Simple Communications et al

Doc. 17

Case 3:07-cv-04131-MMC

Document 17

Filed 02/04/2008

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Konrad L. Trope, Esq. SBN 133214 Novo Law Group, P.C. 4631 Teller Avenue, Suite 140 Newport Beach, California 92660 [phone] (tel) [phone] (fax) Attorneys for Plaintiff Pacific Information Resources, Inc.

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Request to Continue Date for Filing Motion for Default Judgment Case No. CV-07-4131 TO THIS HONORABLE COURT AND ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN: Plaintiff Pacific Information Resources, Inc. ("Plaintiff") hereby requests a continuance of the Court to file its Default Judgment Application on February 15, 2008 instead of on February 1, 2008. Plaintiff makes this request on the basis of good cause: Pacific Information Resources, Inc., a California Corporation, ) ) ) Plaintiff, ) ) vs. ) ) SIMPLE COMMUNICATIONS, an Alabama ) corporation; WILLIAM TRAVIS SULLIVAN, ) individually, AND DOES 1 through 100, ) inclusive, WHOSE IDENTITIES ARE ) UNKNOWN, ) ) Defendants. ) ______________________________________ ) CASE NO. CV-07-4131 MMC [Before the Honorable Maxine M. Chesney, Courtroom 7] PLAINTIFF'S REQUEST TO CONTINUE DATE FOR FILING MOTION FOR DEFAULT JUDGMENT AGAINST WILLIAM TRAVIS SULLIVAN AND SIMPLE COMMUNICATIONS ; ORDER THEREON Complaint Filed: Discovery Cut-Off: Trial: Status Conference: August 9, 2007 N/A N/A February 8, 2008 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

pacific information resources\pleadings\sullivan and simple communications\req to cont date for def judg final as filed 01 31 08

Dockets.Justia.com

Case 3:07-cv-04131-MMC

Document 17

Filed 02/04/2008

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 matter.

1.

Plaintiff is filing two Motion for Summary Judgment Opposition Briefs tomorrow in this same court on the Main Action (Pacific Information Resources v Musselman, Case No. 06-2306 MMC;

2.

Plaintiff is filing two Motions for Summary Judgment next week in the Main Action (Pacific Information Resources v Musselman, Case No. 06-2306 MMC;

3.

Extrapolating the voluminous data necessary to support the Default Judgement which will be in excess of $3 million has taken much, much more time than anticipated; and

4.

One of Plaintiff's experts, Professor Ran Hadas, is teaching and researching at the University of Sydney in Australia until July, 2008. Thus, coordinating with Professor Hadas has been an extremely time consuming and logistical challenge.

Plaintiff assures the Court there will be no further requests for a continuance of this

There will be no prejudice to any party who has direct or related interest in this case, including those parties who are Defendants in the related case noted herein. Plaintiff humbly requests this final extension in order to properly comply with all statutory and local criteria for granting the Default Judgment Application. Respectfully submitted, DATED: January 31, 2008 NOVO LAW GROUP, P.C. BY: /s/Konrad L. Trope, Esq. California State Bar No. 133214 Novo Law Group, P.C. 4631 Teller Avenue, Ste 140 Newport Beach, California 92660 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Attorneys for Plaintiff PACIFIC INFORMATION RESOURCES, INC.

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pacific information resources\pleadings\sullivan and simple communications\req to cont date for def judg final as filed 01 31 08

2 Request to Continue Date for Filing Motion for Default Judgment Case No. CV-07-4131

Case 3:07-cv-04131-MMC

Document 17

Filed 02/04/2008

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[PROPOSED] ORDER Plaintiff Pacific Information Resources has hereby requested continuance to file its Defaults Judgment Application against Defendants William Travis Sullivan and Simple Communications to February 15, 2008. Having considered the requested extension, good cause appearing, therefore, and no prejudice any parties appearing, IT IS HEREBY ORDERED that: Plaintiff shall file its Application for Default Judgment not later than February 15, 2008 Further, the Case Management Conference is CONTINUED from February 8, 2008 to May 2, 2008. February 4, 2008 Dated: __________________ _____________________________ Honorable MAXINE M. CHESNEY United States District Judge

pacific information resources\pleadings\sullivan and simple communications\req to cont date for def judg final as filed 01 31 08

3 Request to Continue Date for Filing Motion for Default Judgment Case No. CV-07-4131