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Pacific Information Resources, Inc. v. Simple Communications

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


February 19, 2008

PACIFIC INFORMATION RESOURCES, INC., A CORPORATION, PLAINTIFF,
v.
SIMPLE COMMUNICATIONS, AN ALABAMA CORPORATION; WILLIAM TRAVIS SULLIVAN, INDIVIDUALLY, AND DOES 1 THROUGH 100, INCLUSIVE, DEFENDANTS.

The opinion of the court was delivered by: Honorable Maxine M. Chesney

Courtroom 7

Complaint Filed: August 9, 2007

Discovery Cut-Off: N/A

Trial: N/A

Status Conference: February 8, 2008

ORDER APPROVING PLAINTIFF'S REQUEST TO CONTINUE DATE FOR FILING MOTION FOR DEFAULT JUDGMENT AGAINST WILLIAM TRAVIS SULLIVAN AND SIMPLE WHOSE IDENTITIES ARE COMMUNICATIONS UNKNOWN,

TO THIS HONORABLE COURT AND ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN:

Plaintiff Pacific Information Resources, Inc. ("Plaintiff") hereby requests a continuance the Court to file its Default Judgment Application on February 22, 2008, instead of on February 15, 2008. Plaintiff makes this request on the basis of good cause, extreme hardship, and circumstances quite beyond its control. Plaintiff's counsel, Novo Law Group, P.C., is a small firm, and only has one full time legal assistant/secretary/paralegal, Renee Nordyke. She is principally responsible for the preparation of our documents, including making edits and revisions to documents and finalizing them for filing with the court. See Declaration of Renee Nordyke, filed concurrently herewith, at pages 1-2.

Mr. Trope, the Managing Shareholder, has typing skills and computer skills, but not at a level of an experienced legal secretary/assistant with 20 years of experience, as Ms. Nordyke.

See Id.

Ms. Nordyke has been "out of commission" all this week recovering from dental surgery and complications which arose from the surgery. Id. at page 2. Thus Novo Law Group has been severely handicapped in completing this filing as well as others. Ms. Nordyke was expected to miss 1/2 day of work, not the entire week, and part of next week as well. Id.

On Monday, February 11, 2008, Ms. Nordyke went to the dentist for follow-up and finishing of one of two root canals. Id. At this time she also had the dentist complete the preparation for the crowns. She was at the dentist office from 8:45 a.m. to approximately 1:00 p.m. There was a complication with one of her teeth and the gum around the tooth had to be clipped in order to prepare it for a crown. Id.

On Tuesday, February 12, 2008, Ms. Nordyke awoke with gums so swollen that she could not properly swallow. In addition, she was in severe pain. After contacting the dentist, she started taking antibiotics to fight the resulting infection, as well as Vicadin, an extremely strong narcotic for pain. She has been on both antibiotics and Vicadin all this week. Id.

While taking this medication, Ms. Nordyke has not been able to perform her usual duties for drafting, preparing or filing documents. Id.

There will be no prejudice to any party who has direct or related interest in this case, including those parties who are Defendants in the related case noted herein.

Plaintiff humbly requests this extension in order to properly comply with all statutory and local criteria for granting the Default Judgment Application.

Respectfully submitted,

DATED: February 15, 2008

NOVO LAW GROUP, P.C. BY: /s/Konrad L. Trope, Esq. California State Bar No. 133214 Novo Law Group, P.C. 4631 Teller Avenue, Ste 140 Newport Beach, California 92660 Telephone: (949) 222-0899 Facsimile: (949) 222-0983 E-mail: ktrope@novolaw.com Attorneys for Plaintiff PACIFIC INFORMATION RESOURCES, INC.

Plaintiff Pacific Information Resources has hereby requested continuance to file its Defaults Judgment Application against Defendants William Travis Sullivan and Simple Communications to February 22, 2008.

Having considered the requested extension, good cause appearing, therefore, and no prejudice any parties appearing, IT IS HEREBY ORDERED that:

Plaintiff shall file its Application for Default Judgment not later than February 22, 2008.

Honorable MAXINE M. CHESNEY United States District Judge

20080219

© 1992-2008 VersusLaw Inc.



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