River Ranch Fresh Foods, LLC et al v. Premium Fresh Farms, LLC et al

Filing 15

ORDER re 14 Request to Continue Case Management Conference. CMC set for 1/20/09 at 2:00 p.m. Signed by Judge Patricia V. Trumbull on 11/12/08. (pvtlc1) (Filed on 11/12/2008)

1 2 3 4 5 6 7 8 9
LAW OFFICES RYNN & JANOWSKY, LLP 4100 NEWPORT PLACE DRIVE SUITE 700 NEWPORT BEACH, CALIFORNIA 92660 [phone] FAX [phone]

MARION I. QUESENBERY, SBN 072308 R. JASON READ, SBN 117561 RYNN & JANOWSKY, LLP 4100 Newport Place Drive, Suite 700 Newport Beach, CA 92660-2423 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] E-mail: [e-mail] Attorneys for Plaintiffs RIVER RANCH FRESH FOODS, LLC, et al. IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION RIVER RANCH FRESH FOODS, LLC, et al., Plaintiffs, v. PREMIUM FRESH FARMS, LLC, et al., Defendants. CMC Date: November 18, 2008 CMC Time: 2:00 p.m. CMC Place: Ctrm. 5, 4th Floor San Jose CASE NO. C 08-01688 PVT
ORDER ON

10 11 12 13 14 15 16 17 18 19 20 21 22 Plaintiffs River Ranch Fresh Foods, LLC, Vessey and Company, Inc., Lancer Marketing, and Field Fresh Farms, LLC respectfully request that the Case Management Conference and the associated dates be continued for an additional 45 to 60 days. Although Plaintiffs had intended to file a Motion for Default Judgment, Defendants John Tamagni ("Tamagni") and Robert Elliott ("Elliott") retained new counsel who requested that Plaintiffs stipulate to the lifting of the default that was previously filed. Plaintiffs

CASE MANAGEMENT CONFERENCE STATEMENT ­ REQUEST TO CONTINUE CMC

CMC Statement & Request to Continue CMC, Case No. C08-01688 ­ Page 1

1 2 3 4 5 6 7 8 9
LAW OFFICES RYNN & JANOWSKY, LLP 4100 NEWPORT PLACE DRIVE SUITE 700 NEWPORT BEACH, CALIFORNIA 92660 [phone] FAX [phone]

agreed to do so, and a Stipulation Lifting Default [as to Tamagni and Elliott only] & Proposed Order was filed today. Although Plaintiffs counsel and Defendants Tamagni & Elliott's new attorney have discussed settlement of this action, it does not appear that any agreement will be reached at this time. Consequently, Plaintiffs respectfully request that the Case

Management Conference be continued for 45 to 60 days to allow Defendants Tamagni and Elliott time to respond to the Complaint and to discuss and file a Case Management Conference Statement. Also, within the next two weeks, Defendants will file a Request for Default Judgment as to the remaining Defendants. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Date: November 10, 2008 RYNN & JANOWSKY, LLP

10 11 12 13 14 15 16 17 18 19 20 21 22

By:

/s/ Marion I. Quesenbery MARION I. QUESENBERY Attorneys for Plaintiffs

IT IS SO ORDERED. The Case Management Conference is continued to
5, 4th Jose

___________________, at __________ p.m., in Courtroom 2, 17th Floor, San Francisco. January 20, 2009 2:00

12 Date: November __, 2008

____________________________________ U.S. MAGISTRATE JUDGE

CMC Statement & Request to Continue CMC, Case No. C08-01688 ­ Page 2