Free Ex Parte Application - District Court of California - California

Case 3:07-cv-04929-SI

Document 30

Filed 02/19/2008

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JAMES E. GANZER (CSB #99293) GANZER & WILLIAMS 1617 St. Mark=s Plaza, Suite A Post Office Box 7683 Stockton, California 95267 Telephone: (209) 476-1661 Facsimile: (209) 476-1674 Attorneys for Defendant Central Valley Construction Engineering, Inc.

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION UNITED STATES, For the Use of RENTAL SOLUTIONS, LLC, Plaintiff, v. CENTRAL VALLEY CONSTRUCTION, INC.; TPA-CKY JOINT VENTURE, CKY, INC., TAN PHUNG & ASSOCIATES, AMERICAN CONTRACTORS INDEMNITY COMPANY, and DOES 1 through 20, inclusive, Defendants. __________________________________ 1. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. C-07-4929 JL EX PARTE APPLICATION FOR PERMISSION TO APPEAR TELEPHONICALLY AT CASE MANAGEMENT CONFERENCE Date: February 25, 2008 Time: 3:00 p.m. Honorable Marilyn Hall Patel Courtroom 15, 18th Floor San Francisco, CA

I, James E. Ganzer, am counsel to defendant Central Valley Construction

Engineering, Inc. The matters stated in this declaration are of my own personal, firsthand knowledge, unless otherwise stated, and if called upon to testify, I could and would competently testify to all such matters. 2. I first learned about the Case Management Conference from Stan Blyth, counsel

to plaintiff Rental Solutions, on approximately February 13, 2008. I had been under the assumption that this case had been consolidated with the ECCO matter, Case No.
Ex Parte Application

Case 3:07-cv-04929-SI

Document 30

Filed 02/19/2008

Page 2 of 2

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C-07-1568 MJJ, but Mr. Blyth told me that the case had not yet been consolidated. 3. Since my office is in Stockton and travel to court for the hearing will take

approximately 2-2 ½ hours and travel back to Stockton after the hearing will take approximately 3-4 hours, I request I be permitted to appear at the Case Management Conference by telephone. I declare under penalty of perjury under the laws of the State of California, that the foregoing is true and correct and that this declaration was executed at Stockton, San Joaquin County, California, on February 19, 2008. DATED: February 19, 2008 JAMES E. GANZER GANZER & WILLIAMS

By: /s/ JAMES E. GANZER Attorney for Defendant Central Valley Construction Engineering, Inc. J73:cvc.rentalsol.exparte

Ex Parte Application