Opinion
Case No. 1:12-CV-01843-LJO-MJS
02-08-2013
LAW OFFICES OF THOMAS P. RILEY Thomas P. Riley Attorneys for Plaintiff J & J Sports Productions, Inc.. PHILLIPS LAW Kathleen M. Phillips-Vieira Attorneys for Defendants Dolores B. Gomez and Gomez O. Everardo
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.
PLAINTIFF J & J SPORTS
PRODUCTIONS, INC. AND
DEFENDANTS DOLORES B. GOMEZ,
AND GOMEZ E. EVERARDO'S
STIPULATION TO CONTINUE THE
INITIAL SCHEDULING CONFERENCE
DATE: Thursday, February 14, 2013
TO THE HONORABLE MICHAEL J. SENG, THE PARTIES, AND THEIR ATTORNEY/S OF RECORD:
1. By and through their counsel, Plaintiff J & J Sports Productions, Inc. and Defendants Dolores B. Gomez and Gomez O. Everardo, hereby agree, stipulate, and respectfully request that this Honorable Court continue the Initial Scheduling Conference in this action, presently set for Thursday, February 14, 2013 at 9:30 AM.
2. This request is necessitated by the fact that Plaintiff's counsel must participate in a Case Management Conference before the Honorable Richard Seeborg, Northern District of California, San Francisco Division, in the matter of J&J Sports Productions, Inc v. Phair, et al; Case No. 3:12-cv-05781-RS at 10:00 A.M that very same day.
Plaintiff's counsel will be appearing by telephone at the Case Management Conference before the Honorable Richard Seeborg. Plaintiff's counsel will move the Court by way of ex-parte application to have Case Management Conference vacated as the defendants in that particular action have failed and refused to respond to plaintiff's complaint. On February 5,2013 plaintiff requested entry of default from the clerk of the Court and once default is entered the plaintiff will file an ex-parte application to have the Case Management Conference vacated.
3. In addition, on Friday, February 1, 2013, Plaintiff's lead trial counsel was just recently discharged from Keck Hospital of the University of Southern California after being re-admitted to address complications concerning right knee replacement surgery (originally performed by Dr. Lawrence D. Dorr, M.D. on January 8, 2013). By all indications, Plaintiff's counsel will be incapable of airline travel until the very end of February 2013.
4. Defense counsel Kathlen M. Phillps-Vieira is agreeable to the new date of the Court's convenience in lieu of the February 14, 2013 date presenting the scheduling conflict for Plaintiff's counsel.
WHEREFORE, The Parties respectfully request that this Honorable Court continue the upcoming Initial Scheduling Conference presently scheduled for Thursday, February 14, 2013 to a new date of the Court's convenience.
Respectfully submitted,
____________________
LAW OFFICES OF THOMAS P. RILEY
By: Thomas P. Riley
Attorneys for Plaintiff
J & J Sports Productions, Inc..
____________________
PHILLIPS LAW
By: Kathleen M. Phillips-Vieira
Attorneys for Defendants
Dolores B. Gomez
and Gomez O. Everardo
ORDER
IT IS HEREBY ORDERED that the Initial Scheduling Conference in civil action 1:12-cv-01843-LJO-JLT styled J & J Sports Productions, Inc. v. Gomez, et al., is hereby continued from Thursday, February 14, 2013 to March 14, 2013 at 9:30 a.m. before Magistrate Judge Michael J. Seng in Courtroom 6 (MJS). IT IS SO ORDERED.
Michael J. Seng
UNITED STATES MAGISTRATE JUDGE