J & J Sports Productions, Inc. v. Cervantes

Filing 13

ORDER granting 11 Ex Parte Application for an Order Continuing the Initial Case Management Conference. Case Management Statement due by 2/13/2015. Initial Case Management Conference set for 2/20/2015 11:00 AM in Courtroom 5, 2nd Floor, Oakland. Signed by Judge JEFFREY S. WHITE on 1/5/15. (jjoS, COURT STAFF) (Filed on 1/5/2015)

Case4:14-cv-03954-JSW Document11 Filed12/31/14 Page1 of 4

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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
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff
J & J Sports Productions, Inc.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

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J & J SPORTS PRODUCTIONS, INC.,

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Plaintiff,

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vs.
JESUS SEGURA CERVANTES a/k/a
JESUS SEGURA,

CASE NO. 4:14-cv-03954-JSW
PLAINTIFF’S EX PARTE
APPLICATION FOR AN ORDER
CONTINUING THE INITIAL CASE
MANAGEMENT CONFERENCE; AND
ORDER (Proposed)

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Defendant.

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TO THE HONORABLE JEFFREY S. WHITE, THE DEFENDANT, AND HIS
ATTORNEY/S OF RECORD:
Plaintiff J & J Sports Productions, Inc. hereby applies ex parte for an order continuing the
Initial Case Management Conference in this action, presently set for Friday, January 9, 2015 at 11:00
A.M. to a new date approximately thirty (30) to forty-five (45) days forward. This request is

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necessitated by the fact that Plaintiff’s counsel has recently perfected service on defendant Jesus Segura
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Cervantes a/k/a Jesus Segura. A true and correct copy of the Proof of Service have been filed with this
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Honorable Court, as docket entry 10.
As such, as of this writing, Plaintiff has yet to receive an answer or any other responsive
pleading from the defendant. 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.

PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
THE INITIAL CASE MANAGEMENT CONFERENCE; AND ORDER (Proposed)
CASE NO. 4:14-cv-03954-JSW
PAGE 1

Case4:14-cv-03954-JSW Document11 Filed12/31/14 Page2 of 4

WHEREFORE, Plaintiff respectfully requests that this Honorable Court continue the Initial

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Case Management Conference presently scheduled for Friday, January 9, 2015 to a new date

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approximately thirty (30) to forty-five (45) days forward.

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Respectfully submitted,

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Dated: December 31, 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
THE INITIAL CASE MANAGEMENT CONFERENCE; AND ORDER (Proposed)
CASE NO. 4:14-cv-03954-JSW
PAGE 2

Case4:14-cv-03954-JSW Document11 Filed12/31/14 Page3 of 4

ORDER (Proposed)

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It is hereby ordered that the Initial Case Management Conference in civil action number 4:14-cv-

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03954-JSW styled J & J Sports Productions, Inc. v. Cervantes, is hereby continued from Friday,

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January 9, 2015 at 11:00 A.M. to a new date of F ebruary 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: January 05, 2015
THE HONORABLE JEFFREY S. WHITE
United States District Court
Northern District of California
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PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
THE INITIAL CASE MANAGEMENT CONFERENCE; AND ORDER (Proposed)
CASE NO. 4:14-cv-03954-JSW
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Case4:14-cv-03954-JSW Document11 Filed12/31/14 Page4 of 4

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 91030. 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 December 31, 2014, I caused to serve the following documents entitled:

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

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On all parties in said cause by enclosing a true copy thereof in a sealed envelope with postage
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prepaid and following ordinary business practices, said envelope was addressed to:
Jesus Segura Cervantes a/k/a Jesus Segura (Defendant)
1049 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).
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 December 31, 2014, at South
Pasadena, California.

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Dated: December 31, 2014

/s/ Vanessa Morales
VANESSA MORALES

PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER CONTINUING
THE INITIAL CASE MANAGEMENT CONFERENCE; AND ORDER (Proposed)
CASE NO. 4:14-cv-03954-JSW
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