Free Notice (Other) - District Court of California - California

Case 5:07-cv-05068-PVT

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Filed 02/27/2008

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BART M. BOTTA, State Bar No. 167051 MARION I. QUESENBERY, State Bar No. 072308 RYNN & JANOWSKY, LLP 4100 Newport Place Drive, Suite 700 Newport Beach, CA 92660-2423 Telephone: (949) 752-2911 [email protected] Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT 9 FOR THE NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION 10
LAW OFFICES RYNN & JANOWSKY 4100 NEWPORT PLACE DRIVE SUITE 700 NEWPORT BEACH, CALIFORNIA 92660-2423 (949) 752-2911 FAX (949) 752-0953

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TAYLOR FARMS CALIFORNIA, INC., a corporation; PISMO-OCEANO VEGETABLE EXCHANGE, a corporation; ROBERT S. ANDREWS, individually and doing business as ROBERT S. ANDREWS FARMS, a sole proprietorship,

CASE NO. C07-05068-PVT

PLAINTIFFS' REQUEST FOR COURT TO ALLOW TELEPHONIC APPEARANCE AT CASE MANAGEMENT CONFERENCE DATE: March 4, 2008 TIME: 2:00 p.m. COURTROOM: 5

Plaintiffs,

v.

REGIONAL SOURCE PRODUCE, INC., a corporation; THOMAS H. BUBNIS, an individual; KIM MARES, an individual, Defendants.

Plaintiffs TAYLOR FARMS CALIFORNIA, INC., a corporation; PISMOOCEANO VEGETABLE EXCHANGE, a corporation; ROBERT S. ANDREWS, individually and doing business as ROBERT S. ANDREWS FARMS, a sole
PLAINTIFFS' REQUEST FOR TELEPHONIC APPEARANCE­ C07-05068-PVT 1

Case 5:07-cv-05068-PVT

Document 13

Filed 02/27/2008

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LAW OFFICES RYNN & JANOWSKY 4100 NEWPORT PLACE DRIVE SUITE 700 NEWPORT BEACH, CALIFORNIA 92660-2423 (949) 752-2911 FAX (949) 752-0953

proprietorship ("Plaintiffs"), by and through their undersigned counsel of record, hereby respectfully request that Plaintiffs be permitted to appear at the Case Management Conference telephonically. In support thereof, Plaintiffs state as follows: (i) WHEREAS, a Case Management Conference is set for March 4, 2008, at

2:00 p.m. in Courtroom 5. (ii) WHEREAS, the corporate Defendant, REGIONAL SOURCE PRODUCE,

INC., has closed its business and has failed to file an answer or any other response to the complaint filed and served on it, and therefore, Plaintiffs are filing simultaneously with this Request a Request for entry of default; (iii) WHEREAS, the two individually named Defendants, THOMAS H.

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BUBNIS and KIM MARES are both proceeding in this case pro se; (iv) WHEREAS, counsel for Plaintiffs is located in Newport Beach, and

allowing Plaintiffs to appear telephonically at the Case Management Conference will help keep costs at a minimum and will not prejudice any party. (v) Consequently, Plaintiffs respectfully request that the Court order for good

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cause shown that Plaintiffs be permitted to appear at the Case Management Conference by telephonic appearance.

Date: February 27, 2008

RYNN & JANOWSKY, LLP

By:

/s/ Bart M. Botta Bart M. Botta Attorneys for Plaintiffs

PLAINTIFFS' REQUEST FOR TELEPHONIC APPEARANCE­ C07-05068-PVT 2