J&J Sports Production, Inc v. Vizcarra

Filing 16

STIPULATION AND ORDER 15 to Continue Case Management Conference: Case Management Conference set for 3/15/2013 10:30 AM in Courtroom 6, 4th Floor, San Jose. Signed by Judge Ronald M. Whyte on 2/21/13. (jg, COURT STAFF) (Filed on 2/21/2013)

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1 2 3 4 5 6 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: 626-799-9797 Fax: 626-799-9795 TPRLAW@att.net Attorneys for Plaintiff J&J Sports Productions, Inc. 7 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION 8 9 10 J & J SPORTS PRODUCTION, INC, Case No. 5:12-cv-05770-RMW 11 PLAINTIFF J&J SPORTS PRODUCTION, INC. AND DEFENDANT ONOFRE VIZCARRA’S STIPULATION TO CONTINUE THE CASE MANAGEMENT CONFERENCE; ORDER () Plaintiff, 12 13 v. 14 ONOFRE VIZCARRA, 15 Defendant. DATE: Friday, February 22, 2013 16 TIME: 10:30 A.M. 17 18 19 TO THE HONORABLE RONALD M. WHYTE, THE PARTIES, AND THEIR ATTORNEY/S OF RECORD: 20 1. By and through their counsel, Plaintiff J & J Sports Productions, Inc. and Defendant 21 Onofre Vizcarra, hereby agree, stipulate, and respectfully request that this Honorable Court continue 22 23 24 the Case Management Conference in this action, presently set for Friday, February 22, 2013 at 10:30 AM. 2. This request is necessitated by the fact that Mr. Thomas Riley, Plaintiff’s lead trial 25 counsel is ordered to personally appear for mediation in the matter of J & J Sports Productions, Inc. v. 26 Thomas, et al., Case No. 2:12-cv-03040-WDK-FMO in the United States District Court for the Central 27 District of California, Western Division in Los Angeles at 11:00 AM (PST) that very same day. 28 Page 1 3. 1 Moreover, Plaintiff’s counsel is also scheduled to appear for a Case Management 2 Conference before the Honorable Maxine M. Chesney, in the matter of J & J Sports Productions, 3 Inc. v. Beyene, Case No. 3:12-cv-05782-MMC in the San Francisco Division of the U.S.D.C, 4 Northern District of California, at 10:30 AM (PST) and a Case Management Conference before the 5 Honorable Jeffrey S. White, in the matter of J & J Sports Productions, Inc. v. Sarkissian, et al., Case 6 No. 3:10-cv-01895-JSW in the San Francisco Division of the U.S.D.C, Northern District of California, 7 at 1:30 PM (PST) respectively on that very same day as well.1 4. In addition, on Friday, February 1, 2013, Plaintiff’s lead trial counsel was recently 8 9 10 (February 1, 2013) released from Keck Hospital of the University of Southern California after being readmitted to address complications of right knee replacement surgery that was originally performed by Doctor Lawrence D. Dorr, M.D. on January 8, 2013. By all indications, Plaintiff’s counsel will be 11 incapable of extended car or train travel until the very end of February 2013. 12 6. 13 Defense counsel Matthew Pare is agreeable to the new date of the Court’s convenience in lieu of the February 22, 2013 date presenting the scheduling conflict for Plaintiff’s counsel. 14 15 WHEREFORE, The Parties respectfully request that this Honorable Court continue the 16 upcoming Case Management Conference presently scheduled for Friday, February 22, 2013 to a new 17 date of the Court’s convenience. 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 1 Plaintiff’s counsel intends on filing a Stipulation to Continue the Case Management Conference in these instant actions. Page 2 Respectfully submitted, 1 2 3 4 Dated: February 20, 2013 /s/ Thomas P. Riley LAW OFFICES OF THOMAS P. RILEY By: Thomas P. Riley Attorneys for Plaintiff J & J Sports Productions, Inc.. Dated: February 20, 2013 /s/ Matthew A. Pare LAW OFFICE OF MATTHEW PARE, APC By: Matthew Allen Pare Attorneys for Defendant Onofre Vizcarra 5 6 7 8 9 10 11 12 13 14 /// 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 23 /// /// /// 24 /// 25 /// 26 /// 27 /// 28 Page 3 ORDER () 1 2 IT IS HEREBY ORDERED that the Case Management Conference in civil action 5:12-cv- 3 4 05770-RMW styled J & J Sports Productions, Inc. v. Vizcarra, is hereby continued from Friday, February 22, 2013 to a new date of the Court’s convenience. 5 6 7 8 IT IS SO ORDERED: 9 10 11 14 _ THE HONORABLE RONALD M. WHYTE United States District Court Northern District of California /// 15 /// 12 13 16 17 Dated: /// /// /// 18 /// 19 /// 20 /// 21 22 /// /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 Page 4

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