Rocky Mountain Bank -v- Google, Inc.

Filing 845

Rocky Mountain Bank -v- Google, Inc.

Doc. 845

Case 3:08-cv-03697-JSW

Document 8

Filed 11/03/2008

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Marion I. Quesenbery, Cal. SBN 072308 RYNN & JANOWSKY, LLP P.O. Box 20799 Oakland, CA 94620 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Attorneys for Plaintiffs Fresh Start Advantage, Inc. and Fresh Kist Produce, LLC UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION FRESH START ADVANTAGE, INC., a corporation; and FRESH KIST PRODUCE, LLC, a limited liability company, Plaintiffs, CASE NO. C 08-03697 JSW CASE MANAGEMENT CONFERENCE STATEMENT ­ REQUEST TO CONTINUE CMC
AND ORDER THEREON

JOHN D. TAMAGNI, an individual, and ROBERT ELLIOTT, an individual, Defendants.

CMC Date: November 7, 2008 CMC Time: 1:30 p.m. CMC Place: Ctrm. 2, 17th Floor San Francisco

Plaintiffs Fresh Start Advantage, Inc. and Fresh Kist Produce, 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 retained new counsel who requested that Plaintiffs stipulate to the lifting of the default that was previously filed. Plaintiffs have agreed to do so, and Plaintiffs' counsel will forward the

stipulation to Defendants' new counsel today for signature. It will be filed shortly.

CMC Statement & Request to Continue CMC ­ Case No. C 08-03697 JSW ­ Page 1
Dockets.Justia.com

Case 3:08-cv-03697-JSW

Document 8

Filed 11/03/2008

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Although Plaintiffs counsel and Defendants' 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 time to respond to the Complaint and the parties to discuss and file a Case Management Conference Statement. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Date: November 3, 2008 RYNN & JANOWSKY, LLP

By:

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

IT IS SO ORDERED. The Case Management Conference is continued to

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January 9, 2009 1:30 ___________________2008, at __________ p.m., in Courtroom 2, 17th Floor, San Francisco.

6 Date: November __, 2008 ____________________________________ U.S. DISTRICT COURT JUDGE

CMC Statement & Request to Continue CMC ­ Case No. C 08-03697 JSW ­ Page 2