Free Case Management Statement - District Court of California - California

Case 3:07-cv-05095-SI

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Filed 01/07/2008

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1 NEELAM CHANDNA (CSB 192972) HIRSCH ADELL (CSB 34208), and 2 J. DAVID SACKMAN (CSB 106703), Members of REICH, ADELL & CVITAN 3 A Professional Law Corporation 3550 Wilshire Blvd., Suite 2000 4 Los Angeles, California 90010 Telephone: (213) 386-3860 5 Facsimile: (213) 386-5583 E-Mail: [email protected]; [email protected] 6 Attorneys for PLAINTIFFS TRUSTEES OF THE BAKERY & CONFECTIONERY 7 WESTERN CONFERENCE DENTAL FUND 8 9 10 11 12 TRUSTEES OF THE BAKERY & ] CASE NO. C07 5095 SI CONFECTIONERY WESTERN CONFERENCE ] 13 DENTAL FUND, ] REVISED CASE MANAGEMENT ] CONFERENCE STATEMENT BY 14 ] PLAINTIFFS ] Plaintiffs, 15 ] [Fed.R.Civ.P. 16(b); Local ] Rule 16-10] v. 16 ] ] Current Date and Time of Case 17 NELDAM'S DANISH BAKERY, INC. ] Management Conference: ] Jan. 18, 2008 at 2:00 p.m. 18 ] U.S. District Court Defendant. ] 450 Golden Gate Avenue 19 San Francisco, CA 94102-3483 20 21 22 23 24 25 26 / / / 27 / / / 28 -1Request that Case Management Conference Be Taken Off Calendar; that Plaintiffs Appear Telephonically; Or that Such Conference Occur When Motion for Default Judgment is Heard UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

Case 3:07-cv-05095-SI

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Filed 01/07/2008

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I. Request that Case Management Conference Be Taken Off Calendar that Plaintiffs Appear Telephonically; or that Such Conference Be Continued Because Defendant NELDAM'S DANISH BAKERY, INC. has failed to

4 make any appearance whatsoever in this matter, Plaintiffs TRUSTEES 5 OF THE BAKERY & CONFECTIONERY WESTERN CONFERENCE DENTAL FUND are 6 filing a Motion for Default Judgment. 7 appeared in this case, Plaintiffs request that the Case Management 8 Conference, currently set for January 18, 2008 at 2:00 p.m. be 9 taken off calendar, so that Plaintiffs do not have to incur the 10 attorneys fees and costs of traveling from Southern to Northern 11 California. 12 13 Alternatively, Plaintiffs request that: (1) they be permitted 14 to appear by telephone for the Case Management Conference on 15 January 18, 2008 at 2:00 p.m; (2) or that this Case Management 16 Conference be continued to a later time (currently not known) when 17 the Motion for Default Judgment is heard by the Court. 18 and time will be known once the Motion for Default Judgment is on 19 calendar. 20 21 II. 22 23 Default by the Clerk was entered against Defendant on 24 November 29, 2007. 25 default judgment against Defendant. 26 Motion for Default Judgment cotemporaneously with this Request to 27 appear by telephone for the Case Management Conference on January 28 -2Plaintiffs are filing a On January 4, 2008, the Court denied entry of Procedural History of this Case Such date Since Defendant has not

Case 3:07-cv-05095-SI

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Filed 01/07/2008

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1 18, 2008 at 2:00 p.m; (2) or that this Case Management Conference 2 be continued to a later time (currently not known) when the Motion 3 for Default Judgment is heard by the Court. 4 5 6 Respectfully Submitted, 7 8 9 10 11 Dated: ___________________ 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -3/s/ NEELAM CHANDNA Attorneys for Plaintiffs NEELAM CHANDNA, HIRSCH ADELL, and J. DAVID SACKMAN, Members of REICH, ADELL & CVITAN A Professional Law Corporation

Case 3:07-cv-05095-SI

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Filed 01/07/2008

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PROOF OF SERVICE

3 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 4 5 I am employed in the County of Los Angeles, State of California. I am over the age of 18 years and not a party to the 6 within action; my business address is 3550 Wilshire Blvd., Suite 2000, Los Angeles, California 90010. 7 On January 7, 2008, I served the foregoing document described 8 as REVISED CASE MANAGEMENT CONFERENCE STATEMENT BY PLAINTIFFS on the interested parties(s) by placing. 9 10 the original X a true copy thereof

11 enclosed in a sealed envelope and addressed as set forth: 12 13 14 x 15 16 17 18 19 20 21 22 x 23 24 Executed on January 7, 2008, at Los Angeles, California. 25 26 27 28 -4/s/ Maria Hoang (Federal Court) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. NELDAM'S DANISH BAKERY 3401 Telegraph Avenue Oakland, CA 94609 (By Mail) As follows: I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice it would be deposited with U.S. postal service on that same day with postage thereon fully prepaid at Los Angeles, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. (By Fax) The facsimile machine I used complied with California Rules of Court 2003(3) and no error was reported by the machine. Pursuant to rule 2005(i), I caused the machine to print a transmission record of the transmission.