J & J Sports Productions, Inc. v. Ortega

Filing 14

ORDER granting 13 Ex Parte Application for an Order Continuing the Case Management Conference. Case Management Conference continued to 1/20/2015 02:00 PM in Courtroom 2, 17th Floor, San Francisco. Case Management Statement due by 1/13/2015. Signed by Judge William H. Orrick on 12/01/2014. (jmdS, COURT STAFF) (Filed on 12/1/2014)

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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-03949-WHO

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Plaintiff,

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v.

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ANTONIO SANCHEZ ORTEGA a/k/a
ANTONIO ORTEGA, et al.,

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

Defendants.

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TO THE HONORABLE WILLIAM H. ORRICK, 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 Case

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Management Conference presently set for Tuesday, December 9, 2014 at 2:00 PM. As set forth below

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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 Antonio Sanchez Ortega a/k/a

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Antonio Ortega, individually and d/b/a Plaza Garibaldi. As a result, Plaintiff’s counsel has not

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conferred with the defendant concerning the claims, discovery, settlement, ADR or any of the other

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pertinent issues involving the case itself or the preparation of a Joint Case Management Conference

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Statement.

PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
CASE MANAGEMENT CONFERENCE; AND ORDER
CASE NO. 3:14-cv-03949-WHO

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 a calendaring conflict on

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Tuesday, December 9, 2014 as Mr. Riley is ordered to personally appear before the Honorable Paul L.

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Abrams of the U.S.D.C. for the Central District of California, Western Division in the matter of J & J

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Sports Productions, Inc. v. Senehi, et al.,; Case No. 2:12-cv-07846-PLA for a status conference at 10:00
AM that very same day (ECF# 57).
WHEREFORE, Plaintiff respectfully requests that this Honorable Court continue the Case
Management Conference, presently scheduled for Tuesday, December 9, 2014 at 2:00 PM.

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Respectfully submitted,

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Dated: November 26, 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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ORDER
PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
CASE MANAGEMENT CONFERENCE; AND ORDER
CASE NO. 3:14-cv-03949-WHO

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It is hereby ordered that the Case Management Conference in civil action number 3:14-cv-03949-

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WHO styled J & J Sports Productions, Inc. v. Ortega, is hereby continued from 2:00 PM, Tuesday,

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December 9, 2014 to 2:00 p.m. on Tuesday, January 20, 2015.
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: December 1, 2014

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THE HONORABLE WILLIAM H. ORRICK
United States District Court
Northern District of California
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PROOF OF SERVICE (SERVICE BY MAIL)

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I declare that:

PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
CASE MANAGEMENT CONFERENCE; AND ORDER
CASE NO. 3:14-cv-03949-WHO

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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 26, 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)
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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Antonio Sanchez Ortega a/k/a Antonio Ortega
250 23rd Street
Richmond, CA 94804

(Defendant)

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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

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is true and correct, and that this declaration was executed on November 26, 2014, at South Pasadena,

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California.

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Dated: November 26, 2014

/s/ Vanessa Morales
VANESSA MORALES

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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
CASE MANAGEMENT CONFERENCE; AND ORDER
CASE NO. 3:14-cv-03949-WHO