J & J Sports Productions, Inc. v. Cervantes

Filing 8

ORDER GRANTING 7 Ex Parte MOTION for an Order Continuing Case Management Conference. Joint Case Management Statement due by 1/2/2015. Initial Case Management Conference set for 1/9/2015 11:00 AM in Courtroom 5, 2nd Floor, Oakland. Signed by Judge JEFFREY S. WHITE on 12/3/14. (jjoS, COURT STAFF) (Filed on 12/3/2014)

Case4:14-cv-03954-JSW Document7 Filed12/01/14 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 91030-3227
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff
J & J Sports Productions, Inc.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

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J & J SPORTS PRODUCTIONS, INC.,

CASE NO. 4:14-cv-03954-JSW

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Plaintiff,

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v.

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JESUS SEGURA CERVANTES a/k/a
JESUS SEGURA,

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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 JEFFREY S. WHITE, 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 Friday, December 12, 2014 at 11:00 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 Jesus Segura Cervantes a/k/a Jesus
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Segura, individually and d/b/a La Selva Taqueria. 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. 4:14-cv-03954-JSW

Case4:14-cv-03954-JSW Document7 Filed12/01/14 Page2 of 4

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 Friday, December 12, 2014 at 11:00 AM.

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Respectfully submitted,

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Dated: December 1, 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. 4:14-cv-03954-JSW

Case4:14-cv-03954-JSW Document7 Filed12/01/14 Page3 of 4

ORDER (Proposed)

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It is hereby ordered that the Case Management Conference in civil action number 4:14-cv-03954-

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JSW styled J & J Sports Productions, Inc. v. Cervantes, is hereby continued from 11:00 AM, Friday,

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December 12, 2014 to

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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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January 9, 2015

Service of this Order with the Clerk of the Court.

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IT IS SO ORDERED:
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Dated: December 3, 2014
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
CASE MANAGEMENT CONFERENCE; AND ORDER (Proposed)
CASE NO. 4:14-cv-03954-JSW

Case4:14-cv-03954-JSW Document7 Filed12/01/14 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. 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 1, 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:
Jesus Segura Cervantes a/k/a Jesus Segura (Defendant)
1049 23rd Street
Richmond, CA 94804
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 1, 2014, at South
Pasadena, California.

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Dated: December 1, 2014

/s/ Vanessa Morales
VANESSA MORALES

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