J & J Sports Productions, Inc. v. Urias

Filing 8

ORDER Granting 7 Ex Parte Application Continuing the Case Management Conference. Case Management Statement due by 1/9/2015. Case Management Conference set for 1/16/2015 10:00 AM in Courtroom 1, 17th Floor, San Francisco. Signed by Judge Samuel Conti on 11/25/2014. (tmi, 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-03941-SC

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Plaintiff,

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v.

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MELVA A. GAMEZ URIAS a/k/a MELVA
A. GAMEZ,

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

Defendant.

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TO THE HONORABLE SAMUEL CONTI, THE DEFENDANT AND HER

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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 Friday, December 5, 2014 at 10:00 AM. As set forth below
Plaintiff respectfully requests that the Court continue the Case Management Conference to a new date

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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 Melva A. Gamez Urias a/k/a Melva
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A. Gamez, individually and d/b/a El Mexicano Bar. As a result, Plaintiff’s counsel has not conferred
with the defendant 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.
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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
CASE MANAGEMENT CONFERENCE; AND ORDER (Proposed)
CASE NO. 3:14-cv-3941-SC

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.
In addition, Thomas P. Riley, Plaintiff’s counsel in this action, has calendaring conflicts on

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Friday, December 5, 2014 as Mr. Riley is scheduled to personally appear before Mediator Gail

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Killefer, ADR Program Director of the U.S.D.C. for the Central District of California, Western

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Division in the matters of J & J Sports Productions, Inc. v. Lim, et al.,; Case No. 2:13-cv-8949-WDK-

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PLA for a mediation at 9:00 AM that very same day (ECF# 12); and for a telephonic settlement

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disposition conference in J & J Sports Productions, Inc. v. Buenrostro, et al.,; Case No. 3:13-cv-02104CAB-KSC at 10:00 A.M. that same day (ECF# 20); and for a case management conference in J & J
Sports Productions, Inc. v. Pepperell, et al.,; Case No. 3:14-cv-03923-MMC at 10:30 A.M. that same
day (ECF# 11)1; and for a mediation in J&J Sports Productions, Inc. v. Jaculito Lopez, Inc.; Case No.

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2:13-cv-08877-WDK-PLA at 11:00 AM that same day (ECF# 16); and for a mediation in J & J Sports
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Productions, Inc. v. Gebreyesus, et al.,; Case No. 2:13-cv-09087-WDK-PLA at 12:00 PM that same
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day (ECF# 15); and for a mediation in J&J Sports Productions, Inc. v. Vasquez, et al.,; Case No. 5:1314
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cv-00807-WDK-PLA at 1:00 PM that same day (ECF# 22); and for a mediation in J & J Sports
Productions, Inc. v. Jimenez,; Case No. 2:13-cv-08860-WDK-PLA at 2:00 PM that same day (ECF#
14) as well.

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WHEREFORE, Plaintiff respectfully requests that this Honorable Court continue the Case
Management Conference, presently scheduled for Friday, December 5, 2014 at 10:00 AM.

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Respectfully submitted,

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Dated: November 25, 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 counsel will be requesting a rescheduling of this particular matter in view of the seven (7) other proceedings
(as set forth above) on calendar that same day.
PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
CASE MANAGEMENT CONFERENCE; AND ORDER (Proposed)
CASE NO. 3:14-cv-3941-SC

ORDER (Proposed)

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It is hereby ordered that the Case Management Conference in civil action number 3:14-cv-03941-

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SC styled J & J Sports Productions, Inc. v. Urias, is hereby continued from 10:00 AM, Friday,

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December 5, 2014 to Friday, January 16, 2015, at 10:00 AM.

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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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S
NO

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THE HONORABLE SAMUEL CONTI
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-3941-SC

Dated: 11/25/2014

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 25, 2014, I caused to serve the following documents entitled:

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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE
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:

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Melva A. Gamez Urias a/k/a Melva A. Gamez (Defendant)
1835 23rd Street
San Pablo, CA 94806

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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 is true and correct, and that this declaration was executed on November 25, 2014, at South

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Pasadena, California.
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Dated: November 25, 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-3941-SC