The opinion of the court was delivered by: The Honorable Charles R. Breyer U United States District Court
STIPULATION FOR AN ORDER CONTINUING CASE MANAGEMENT CONFERENCE; AND ORDER (Proposed) FOR: HON. CHARLES R.BREYER TO THE HONORABLE CHARLES R. BREYER:
By and through their counsel, Plaintiff J & J Sports Productions,
Inc., and Defendants Isabel
Laura Buzko and Cristobal Zepeda, individually
and d/b/a Vito's Ristorante & Pizzeria a/k/a Vito's
Pizzeria and Italian Restaurant hereby agree,
stipulate, and respectfully request that this Honorable
Court continue the Case Management Conference
presently set for November 4, 2011 at 8:30 AM.
Defendants Isabel Laura Buzko and Cristobal Zepeda have filed a Stipulation to Further Extend Time to Answer the Plaintiff's Complaint until November 14, 2011 (please see Docket Entry 19). As a result the Plaintiff is not aware of the Defendants' position concerning the claims, discovery, settlement, ADR or any of the other pertinent issues involving the case itself or the preparation of a Case Management Conference Statement.
WHEREFORE, IT IS HEREBY STIPULATED BY AND RESPECTFULLY REQUESTED
BY THE PARTIES that the Court reschedule Case Management Conference, presently scheduled for November 4, 2011 at 8:30 AM to a new date approximately Thirty (30) to Forty-Five (45) days forward.
Respectfully Submitted, Dated: November 1, 2011 /s/ Thomas P. Riley LAW OFFICES OF THOMAS P. RILEY By: Thomas P. Riley Attorneys for Plaintiff J & J Sports Productions, Inc. Dated: October 31, 2011 /s/ Nicholas Roscha ROSCHA & ODNE LLP By: Nicholas Roscha Attorneys for Defendants Isabel Laura Buzko and Cristobal Zepeda
It is hereby ordered that the Case Management Conference in civil action number 3:11-cv- 02126-CRB styled J & J Sports Productions, Inc. v. Isabel Laura Buzko, et al., is hereby continued from 8:30 AM, November 4, 2011 to January 6, 2012 at 8:30 a.m.
PROOF OF SERVICE (SERVICE BY E-MAIL)
I am employed in the County of Los Angeles, California. I am over the age of eighteen years and not a party to the within cause; my business address is 1114 Fremont Avenue, South Pasadena, California 91030. I am readily familiar with this law firm's practice for collection and processing of correspondence/documents for mail in the ordinary course of business.
On October ___, 2011, I served:
On all parties in said cause by electronic mailing same to the Defendants' counsel at the following email address(es):
Mr. Nicholas Roscha, Esquire Attorneys for Defendants ROSCHA, & ODNE LLPIsabel Laura Buzko 1320 Willow Pass Road, Ste. 500 and Cristobal Zepeda Concord, CA 94520 ...