Free Motion for Miscellaneous Relief - District Court of California - California

Case 3:08-cv-01223-JAH-RBB

Document 7

Filed 08/13/2008

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Nicholas J. Bontrager, Esq. (SBN 252114) Krohn & Moss, Ltd. 5055 Wilshire Blvd, Suite 300 Los Angeles, CA 90036 T: (323) 988-2400; F: (866) 802-0021 Attorneys for Plaintiff, UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA SAN DIEGO DIVISION STEPHANIE KOCH Plaintiff, vs. GC SERVICES, LP Defendant. ) ) ) ) ) ) ) ) ) ) Case No.: 3:08-cv-01223-JAH-RBB EX PARTE APPLICATION FOR PLAINTIFF'S EXCUSED ABSENCE FROM EARLY NUETRAL EVALUATION CONFERENCE

APPLICATION COMES NOW the Plaintiff, STEPHANIE KOCH, by and through her attorneys, KROHN & MOSS, LTD., and respectfully requests that this court hereby grant her ex parte application for excused absence from the Early Neutral Evaluation Conference set for August 29, 2008 at 8:30 a.m. and enter the attached proposed order allowing her to appear though her legal counsel. The application is based upon the following facts:

1. Plaintiff is a natural person who resides in the City of Carter Lake, State of Iowa. 2. On July 7, 2008 Plaintiff filed her Verified Complaint in the present matter.

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Case 3:08-cv-01223-JAH-RBB

Document 7

Filed 08/13/2008

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3. Plaintiff filed said complaint in the present district in accordance with 28 U.S.C. 1391(b)(1) as Defendant maintains a business office in the City of San Diego, State of California. 4. On or about July 31, 2008, this court ordered an Early Neutral Evaluation Conference to be held on August 29, 2008 at 8:30 a.m. 5. Plaintiff's attorneys, KROHN & MOSS, LTD., maintain a business office within the state of California and will be present at the above mentioned conference. 6. Plaintiff's personal appearance at the conference would be burdensome as she would have to take unpaid time from work and expend a substantial sum of money to secure travel to appear.

Based upon the foregoing, Plaintiff respectfully requests this court to grant her application for an excused absence from the conference set for August 29, 2008 at 8:30 a.m. and enter an order allowing Plaintiff to appear through her legal counsel.

RESPECTFULLY SUBMITTED, DATED: August 13, 2008 KROHN & MOSS, LTD.

By: /s/ Nicholas J. Bontrager Nicholas J. Bontrager Attorney for Plaintiff

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