J & J Sports Productions, Inc. v. Gonzalez et al

Filing 14

Order by Hon. Vince Chhabria granting 13 Ex Parte Application to Continue the Case Management Conference.(knmS, COURT STAFF) (Filed on 11/24/2014)

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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-03932-VC

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Plaintiff,
v.
GERARDO GUERRERO GONZALEZ, et
al.,

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

Defendants.

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TO THE HONORABLE VINCE CHHABRIA, THE DEFENDANTS AND THEIR
ATTORNEY/S OF RECORD:
Plaintiff J & J Sports Productions, Inc., hereby applies ex parte for an order continuing the Case
Management Conference presently set for Tuesday, December 2, 2014 at 10:00 AM. As set forth
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 Defendants Gerardo Guerrero Gonzalez and
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Reynaldo Gonzalez, individually and d/b/a meson Azteca a/k/a Meson Asteca. As a result,
Plaintiff’s counsel has not conferred with the defendants concerning the claims, discovery,
settlement, ADR or any of the other pertinent issues involving the case itself or the preparation of a
Joint Case Management Conference Statement.

PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
CASE MANAGEMENT CONFERENCE; AND ORDER (Proposed)
CASE NO. 3:14-cv-03932-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 Defendants.
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-03932-VC

ORDER (Proposed)

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It is hereby ordered that the Case Management Conference in civil action number 3:14-cv-03932-

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VC styled J & J Sports Productions, Inc. v. Gonzalez, et al., is hereby continued from 10:00 AM,

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Tuesday, December 2, 2014 to January 13, 2015, at 10:00 a.m.
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Plaintiff shall serve a copy of this Order on the Defendants 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 24, 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-03932-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:
Gerardo Guerrero Gonzalez (Defendant)
2237 Morello Avenue
Pleasant Hill, CA 94523
Reynaldo Gonzalez (Defendant)
2237 Morello Avenue
Pleasant Hill, CA 94523

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The fully sealed envelope with pre-paid postage was thereafter placed in our law firm’s
outbound mail receptacle in order that this particular piece of mail could be taken to the United States
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

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foregoing is true and correct, and that this declaration was executed on November 20, 2014, at South
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Pasadena, California.
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Dated: November 20, 2014

/s/ Vanessa Morales
VANESSA MORALES

PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
CASE MANAGEMENT CONFERENCE; AND ORDER (Proposed)
CASE NO. 3:14-cv-03932-VC