J & J Sports Productions, Inc. v. Bermudez

Filing 12

Order by Hon. Vince Chhabria granting 11 Ex Parte Application to Change the Case Management Conference Hearing Date.(knm, COURT STAFF) (Filed on 11/26/2014)

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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
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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J & J SPORTS PRODUCTIONS, INC.,

CASE NO. 3:14-cv-03925-VC

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Plaintiff,

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v.

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IGNACIO BERMUDEZ,

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

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Defendant.
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TO THE HONORABLE VINCE CHHABRIA, THE DEFENDANT AND HIS
ATTORNEY/S OF RECORD:
Plaintiff J & J Sports Productions, Inc., hereby applies ex parte for an order continuing the Case

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Management Conference presently set for Tuesday, December 2, 2014 at 10:00 AM. As set forth

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below Plaintiff respectfully requests that the Court continue the Case Management 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

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perfected service of the initiating suit papers upon the Defendant Ignacio Bermudez, individually and

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d/b/a El Campesino Market & Taqueria. 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
involving the case itself or the preparation of a Case Management Conference Statement.
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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
CASE MANAGEMENT CONFERENCE; AND ORDER (Proposed)
CASE NO. 3:14-cv-03925-VC

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 Case

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Management Conference, presently scheduled for Tuesday, December 2, 2014 at 10:00 AM.

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Respectfully submitted,

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Dated: November 20, 2014
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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
CASE MANAGEMENT CONFERENCE; AND ORDER (Proposed)
CASE NO. 3:14-cv-03925-VC

ORDER (Proposed)

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It is hereby ordered that the Case Management Conference in civil action number 3:14-cv-03925-

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VC styled J & J Sports Productions, Inc. v. Bermudez, is hereby continued from 10:00 AM, Tuesday,

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December 2, 2014 to January 20, 2015.

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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: November 26, 2014
THE HONORABLE VINCE CHHABRIA
United States District Court
Northern District of California

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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
CASE MANAGEMENT CONFERENCE; AND ORDER (Proposed)
CASE NO. 3:14-cv-03925-VC

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 November 20, 2014, I caused to serve the following documents entitled:

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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING CASE
MANAGEMENT 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:
Ignacio Bermudez (Defendant)
232 23rd Street
Richmond, CA 94804

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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

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assistant duly employed by our law firm).

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I declare under the penalty of perjury pursuant to the laws of the United States that the
foregoing is true and correct, and that this declaration was executed on November 20, 2014, at South
Pasadena, California.

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Dated: November 20, 2014

/s/ Vanessa Morales
VANESSA MORALES

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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
CASE MANAGEMENT CONFERENCE; AND ORDER (Proposed)
CASE NO. 3:14-cv-03925-VC