Libyan Jamahiriya Broadcasting Corporation v. Fadel

Filing 19

Ex Parte Application re 14 Clerks Notice to Continue CMC filed by Libyan Jamahiriya Broadcasting Corporation. (Attachments: # 1 Proposed Order)(Ishimoto, Jennifer) (Filed on 2/24/2011)

1 JOHN R. FUISZ (pro hac vice)
THE FUISZ LAW FIRM
2 1455 Pennsylvania Avenue, NW
Suite 400
3 Washington, DC 20004
Telephone: [phone]
4 E-mail: [e-mail]
5 JENNIFER L. ISHIMOTO (SBN 211845)
BANIE & ISHIMOTO LLP
6 2225 East Bayshore Road, Suite 200
Palo Alto, CA 94303
7 Telephone: [phone]
Facsimile: [phone]
8 E-mail: [e-mail]
9 Attorneys for Plaintiff
Libyan Jamahiriya Broadcasting Corporation
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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Libyan Jamahiriya Broadcasting
Corporation,

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Plaintiff,

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vs.

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Maher Adly Fadel,

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Defendant.

Civil Action No. 3:10-CV-05432-WHA
PLAINTIFF LIBRYAN JAMAHIRIYA
BROADCASTING CORPORATION’S EX
PARTE APPLICATION TO CONTINUE THE
CASE MANAGEMENT CONFERENCE
Date: March 3, 2011
Time: 11 a.m.

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BANIE & ISHIMOTO
LLP

-1PLAINTIFF’S EX PARTE APPILCATION TO CONTINUE CMC
CIVIL ACTION NO. CV10-05432

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Plaintiff Libyan Jamahiriya Broadcasting Corporation (“LJBC”) submits this Ex Parte

2 Application to Continue the Case Management Conference.
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EX PARTE APPLICATION TO CONTINUE CASE MANAGEMENT CONFERENCE
Given the current circumstances in Libya, counsel for Plaintiff LJBC is unable to reach its

5 client at the present time. Thus, Plaintiff LJBC asks that the Initial Case Management
6 Conference, currently scheduled for March 3, 2011, be continued until April 14, 2011. In
7 addition, as outlined in its CMC Statement, Plaintiff originally did serve the Defendant in this
8 case via email. However, Plaintiff LJBC’s attempt to serve the Defendant via Federal Express
9 was returned as undeliverable. Given the Plaintiff LJBC believes that the Defendant is located in
10 Egypt, LJBC has had difficulty further locating the Defendant in this case. Given the political
11 issues and the resulting instability in Egypt, Plaintiff LJBC has had difficulty obtaining further
12 information about the Defendant’s location to further attempt service.
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Plaintiff has received no contact from the Defendant. No answer has been filed to date

14 and thus, Plaintiff believes there is no prejudice to continuing the current case management
15 conference.
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Plaintiff LJBC respectfully asks the Court to continue the current case management

17 conference, scheduled for March 3, 2011 to April 14, 2011.
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19 Dated: February 24, 2011
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Banie & Ishimoto LLP

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_/s/Jennifer Ishimoto__________________
Jennifer Ishimoto (SBN 211845)

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Attorneys for Plaintiff
Libyan Jamahiriya Broadcasting Corporation

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BANIE & ISHIMOTO
LLP

-2PLAINTIFF’S EX PARTE APPILCATION TO CONTINUE CMC
CIVIL ACTION NO. CV10-05432