J&J Sports Productions, Inc v. Nguyen et al

Filing 15

STIPULATION AND ORDER CONTINUING CASE MANAGEMENT CONFERENCE (approving 13 ). The Case Management Conference set for 8/5/2011 is CONTINUED to 9/23/2011 at 10:30 AM in Courtroom 3, 5th Floor, San Jose. Signed by Judge Jeremy Fogel on 8/4/2011. (jflc2, COURT STAFF) (Filed on 8/4/2011)

1
2
3
4
5

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.

**E-Filed 8/4/2011**

6
7
8
9
10
11
12
13

Nicholas Roscha, SBN 181501
Christopher N. Odne, SBN 241175
ANDERSEN, ROSCHA & ODNE, LLP
1320 Willow Pass Road, Ste. 500
Concord, CA 94520
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Defendants
Duy Trong Nguyen, Au Thi Le,
and Lighthouse Cafe, Inc.

14

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

15
16
17
18

J & J SPORTS PRODUCTIONS, INC.,
Plaintiff,

19

v.
20
21
22

DUY TRONG NGUYEN, et al.,

CASE NO. 5:11-CV-1157-JF
STIPULATION FOR AN ORDER
CONTINUING CASE MANAGEMENT
CONFERENCE; AND ORDER -------------(Proposed)
FOR: HON. JEREMY FOGEL

Defendants.

23
24

TO THE HONORABLE JEREMY FOGEL:

25

By and through their counsel, Plaintiff J & J Sports Productions, Inc., and Defendants Duy

26

Trong Nguyen and Au Thi Le, individually and d/b/a Lighthouse Cafe a/k/a Lighthouse Cafe &

27

Restaurant, and Lighthouse Cafe, Inc., an unknown business entity d/b/a Lighthouse Cafe a/k/a

28

Lighthouse Cafe & Restaurant hereby agree, stipulate, and respectfully request that this Honorable

Page 1

1

Court continue the Case Management Conference presently set for August 5, 2011 at 10:30 AM.
The request for the brief continuance is necessitated by the fact that counsel for the Parties have

2
3

been engaged in settlement discussions and request additional time to conclude same.

4

WHEREFORE, IT IS HEREBY STIPULATED BY AND RESPECTFULLY REQUESTED

5

BY THE PARTIES that the Court reschedule Case Management Conference, presently scheduled for

6

August 5, 2011 at 10:30 AM to a new date approximately Thirty (30) to Forty-Five (45) days forward.

7
8
9

Respectfully Submitted,

10
11
12

Dated: July 28, 2011

/s/ Thomas P. Riley
LAW OFFICES OF THOMAS P. RILEY
By: Thomas P. Riley
Attorneys for Plaintiff
J & J Sports Productions, Inc.

Dated: July 28, 2011

/s/ Christopher N. Odne
ANDERSEN, ROSCHA & ODNE, LLP
By: Christopher N. Odne
Attorneys for Defendants
Duy Trong Nguyen, Au Thi Le, and
Lighthouse Cafe, Inc.

13
14
15
16
17
18
19
20
21
22

///

23

///

24

///

25

///

26

///

27

///

28

///

Page 2

-------------ORDER (Proposed)

1

It is hereby ordered that the Case Management Conference in civil action number 5:11-cv-

2
3

01157-JF styled J & J Sports Productions, Inc. v. Duy Trong Nguyen, et al., is hereby continued from

4

10:30 AM, August 5, 2011 to September 23, 2011, at 10:30 a.m.

.

5
6
7
8

IT IS SO ORDERED:

9
10

Dated:

11
12
13
14
15

The Honorable Jeremy Fogel
United States District Court
Northern District of California
///
///

16

///

17

///

18

///

19

///

20

///

21

///

22

///

23

///

24

///

25

///

26

///

27

///

28

///

Page 3

8/4/2011

PROOF OF SERVICE (SERVICE BY E-MAIL)

1
2
3

I declare that:

4

I am employed in the County of Los Angeles, California. I am over the age of eighteen years
5

and not a party to the within cause; my business address is 1114 Fremont Avenue, South Pasadena,
6

California 91030. I am readily familiar with this law firm's practice for collection and processing of
7

correspondence/documents for mail in the ordinary course of business.

8
9

On July 28, 2011, I served:

10
11

STIPULATION FOR AN ORDER CONTINUING CASE MANAGEMENT
CONFERENCE; AND ORDER (Proposed)

12
13
14

On all parties in said cause by electronic mailing same to the Defendants’ counsel at the
following email address(es):

15
16
17
18
19
20

Nicholas Roscha, Esquire
Christopher N. Odne, Esquire
ANDERSEN, ROSCHA & ODNE, LLP
1320 Willow Pass Road, Ste. 500
Concord, CA 94520
Email: [e-mail]
[e-mail]

Attorneys for Defendants
Duy Trong Nguyen, Au Thi Le, and
Lighthouse Cafe, Inc.

21
22

I declare under the penalty of perjury pursuant to the laws of the United States that the

23

foregoing is true and correct and that this declaration was executed on July 28, 2011, at South

24

Pasadena, California.

25
26

Dated: July 28, 2011

/s/ Maria Baird
MARIA BAIRD

27
28

Page 4