Free Case Management Statement - District Court of California - California

Case 3:07-cv-04946-JSW

Document 92

Filed 09/05/2008

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CHRISTOPHER COOKE, CA Bar #142342 STEPHEN S. WU, CA Bar # 205091 COOKE KOBRICK & WU LLP 177 Bovet Road, Suite 600 San Mateo, CA 94402 Email: [email protected] [email protected] Tel: (650) 638-2370 Fax: (650) 341-1395 Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION MEI-FANG LISA ZHANG, BAY AREA AFFORDABLE HOUSING, LLC, XUEHUAN GAO, YANG-CHUN ZHANG, CAROL JIAN DENG, and HAO LIANG, ) ) ) ) ) ) ) Plaintiffs, ) ) vs. ) ) WEI-MAN RAYMOND TSE, RUN PING ) ) ZHOU a.k.a. FLORA ZHOU, THERESA WONG, JAMES YU, BILL SHU WAI MA, ) ) MOLLY LAU, VICTOR SO, JIAN XIAO, ) CHRIST INVESTMENT SERVICE INC., CIS ) SERVICE, INC., PACIFIC BEST GROUP ) ) LTD. a.k.a. PACIFIC BEST COMPANY LTD., and SOUTH CHINA INVESTMENT ) ) INC., ) Defendants. ) Case No.: C-07-04946 JSW (Related to C-05-02641 JSW) PLAINTIFFS' CASE MANAGEMENT STATEMENT

Pursuant to Local Rule 16-9, Plaintiffs submit this Case Management Statement.

-1PLAINTIFFS' CASE MANAGEMENT STATEMENT/ Case No.: C-07-04946 JSW

Case 3:07-cv-04946-JSW

Document 92

Filed 09/05/2008

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PRELIMINARY STATEMENT REGARDING SEPARATE CASE MANAGEMENT STATEMENT Local Rule 16-9(a) provides, "If one or more of the parties is not represented by counsel, the parties may file separate case management statements." In this case, none of the Defendants is represented by counsel. Accordingly, pursuant to Local Rule 16-9(a), Plaintiffs submit this statement as a separate Case Management Statement. Defendant Run Ping Zhou filed a separate Case Management Statement

STATUS OF CASE AND MOTION FOR DEFAULT JUDGMENT Plaintiffs intend to file a motion for default judgment in this case against the Defendants, now that service is complete and the Clerk has entered defaults. Until September 3, 2008, however, two Defendants were not subject to defaults: Molly Lau and Run Ping Zhou.

Nonetheless, on September 3, 2008, Plaintiffs filed a Notice of Voluntary Dismissal of Defendant Molly Lau, thereby ending the case against her. Plaintiffs' counsel has also sent Defendant Run Ping Zhou a stipulation of dismissal for her to sign and return for filing, after discussing with her the possibility of dismissing her from the case. Plaintiffs anticipate receiving the stipulation back from Defendant Zhou soon. Once Plaintiffs' counsel has received and filed the stipulation of dismissal, then all nondefaulting Defendants would be dismissed, and all of the remaining Defendants in the case would be in default. After that dismissal, Plaintiffs will file their motion for default judgment.

Respectfully Submitted, COOKE, KOBRICK, & WU LLP Dated: September 5, 2008 /s/ By: STEPHEN S. WU Attorneys for Plaintiffs

-2PLAINTIFFS' CASE MANAGEMENT STATEMENT/ Case No.: C-07-04946 JSW

Case 3:07-cv-04946-JSW

Document 92

Filed 09/05/2008

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CERTIFICATE OF SERVICE I, Stephen S. Wu, declare: I am a resident of the State of California and over the age of eighteen years, and not a party to the within action. I am an attorney in the law firm of Cooke Kobrick & Wu LLP, 177 Bovet Road, Suite 600, San Mateo, CA 94402. On September 5, 2008, I served Defendant Run Ping Zhou with this PLAINTIFFS' CASE MANAGEMENT STATEMENT by placing a true copy thereof, first class postage prepaid, in the United States mail, for delivery to the following Defendants at the following addresses: Ms. Run Ping Zhou 3567 Kimberly Road Cameron Park, CA 95682 I declare under penalty of perjury under the laws of the United States and of the State of California that the foregoing is true and correct. Dated: September 5, 2008 /s/ STEPHEN S. WU

-3PLAINTIFFS' CASE MANAGEMENT STATEMENT/ Case No.: C-07-04946 JSW