Free Motion to Continue - District Court of California - California

Case 3:08-cv-00777-JM-CAB

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Filed 08/28/2008

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KIRSTIN E. MULLER (SBN 186373) kmulleri)cdhklaw.corn KIMBERLY G. BRENER (SBN 244531) kbrener()cdhklaw. corn CURIALE DELLAVERSON HIRSCHFELD & KRAEMER, LLP 2425 Olyrppic Boulevard Suite 550 East Tower Santa Monica, CA 90404 Telephone: (310) 255-0705 Facsimile: (310) 255-0986 Attorneys for Defendants BIZJEY INTERNATIONAL SALES & SUPPORT, INC. (erroneously also served and sued as BizJet International) and LUFTHANSA TECHNIK TULSA CORPORATION (çrroneoujy served and sued as Lufthansa Technick Tulsa Corporation) UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA STEPN J. LERCEL, JR., Plaintiff, vs. BIZJET iNTERNATIONAL, a business Entity form unknown, BIZJET INTE'RNATIONAL SALES & SUPPORT, INC., a Cornoration LUFTHANSA TECHNICIK TULS'A CORPORATION, a Corporation and DOES 1 through 10, inclusive, Defendants. Case No. 08 CV 0777 JM CAB JOINT MOTION FOR RESCHEDULING OF EARLY NEUTRAL EVALUATION CONFERENCE

In accordance with Local Rules 7.2 and 16.1(f), Plaintiff Stephen J. Lercel, Jr. and Defendants BizJet International Sales & Support, Inc. (erroneously also served and sued as BizJet International) and Lufthansa Technik Tulsa Corporation (erroneously served and sued as Lufthansa Technick Tulsa Corporation), hereby stipulate as follows:

CASE NO. 08 CV 0777 JM CAB

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WI-JEREAS, this matter is currently scheduled to come before the Court on September 8, 2008 at 10 a.m. for an Early Neutral Evaluation Conference; and WHEREAS, lead counsel for Defendants is unavailable due to a previously scheduled vacation that falls on the same date as the Early Neutral Evaluation Conference; and WHEREAS, the parties have conferred and both are available to attend the Early Neutral Evaluation on September 15, 2008 or September 23, 2008. The parties hereby STIPULATE and respectfully request that the Court reschedule the Early Neutral Evaluation, currently scheduled for September 8, 2008 at 10 a.m. to either September 15, 2008 or September 23, 2008 at 10 a.m. SO STIPULATED: LAW OFFICES OF THOMAS M. DIACHENKO, APC Dated: August 2008 By:_______________________________ Thomas M. Diachenko Attorney for Plaintiff Stephen J. Lercel, Jr. Dated: August 2008 By:______________________________ Jason A. Rodenbo, Esq. Attorney for Plaintiff Stephen J. Lercel, Jr. CURIALE DELLAVERSON HIRSC ELD & KRAEMER, LLP Dated: August 2008 irstin E. Mul er Kimberly G. Brener Attorneys for Defendants BIZJET INTERNATIONAL SALES & SUPPORT, INC. (erroneously also served and sued as BizJet International) and LUFTHANSA TECHNIK TULSA CORPORATION (erroneously served and sued as Lufthansa Technick Tulsa Corporation)
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cv 0777 JM CAB

flue

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08

09:17a

Jason

Rodenbo

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5953150

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WHEREAS, this matter is currently scheduled to come before the Court on September 8, 2008 at 10 a.m. for an Early Neutral Evaluation Conference; and WHBR.EAS, lead counsel for Defendants is unavailable due to a previously scheduled vacation that falls on the same date as the Early Neutral Evaluation Conference; and WHEREAS, the parties have conferred and both are available to attend the Early Neutral Evaluation on September 15, 2008 or September 23, 2008. The parties hereby STIPULATE and respectfully request that the Court reschedule the Early Neutral Evaluation, currently scheduled for September 8, 2008 at 10 a.m. to either September 15, 2008 or September 23, 2008 at 10a.m. 50 STIPULATED: LAW OFFICES OF THOMAS M. DIACHENKO, APC Dated: August By:_________________________ Thomas M. Diachenko Attorney for Plaintiff Stephen 3. Lercel, Jr. Dated: August
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`7, 2008

By: Plaintiff Stephen 3. Lercel, Jr. CURIALE DELLAVERSON HTRSCHFELD & KRAEMER, LLP

Dated: August

2008

By:_______________________________ Kirstin E. Muller Kimberly G. Brener Attorneys for Defendants BIZJET INTERNATIONAL SALES & SUPPORT, iNC. (erroneously also served and sued as Biz3et International) and LUFTHANSA TECHNIK TULSA CORPORATION (erroneous]y served and sued as Lufthansa Technick Tulsa Corporation)
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CASE NO.08 CV 0777 JM CAB

Received

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10:55am

From--519 5953150

Ta--CURIALE DELLAVERSON

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WHEREAS, this matter is currently scheduled to come before the Court on

September 8, 2008 at 10 a.m. for an Early Neutral Evaluation Conference; and WHEREAS, lead counsel for Defendants is unavailable due to a previously scheduled vacation that falls on the same date as the Early Neutral Evaluation Conference; and WHEREAS, the parties have conferred and both are available to attend the Early Neutral Evaluation on September 15, 2008 or September 23, 2008. The parties hereby STIPULATE and res3ectfully request that the Court reschedule the Early Neutral Evaluation, currently scheduled for September 8, 2008 at 10 am. to either September 15, 2008 or September 23, 2008 at 10 a.m.
SO STIPULATED:

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,2008 Attorneybr Plaintiff Stephen J. Lercel, Jr.

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Dated; August

2008

By/

/ Jason A. Rodenbo, Esq.

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Attorney for Plaintiff Stephen J. Lercel, Jr. CURIALE DELLAVERSON HIRSCHFELD & KRAEMER, LLP Dated; August 2008 By:____________________________ Kirstin E. Muller Kimberly G. Brener Attorneys for Defendants BIZJEV INTERNATIONAL SALES & SUPPORT, INC. (erroneously also served and sued as BizJet International) and LUFTHANSA TECHNIK TULSA CORPORATION (erroneously served and sued as Lufthansa Technick Tulsa Corporation)

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CERTIFICATE OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am a citizen of the United States and a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is 2425 Olympic Boulevard, Suite 550 East Tower, Santa Monica, California 90404. On August 28, 2008, I served the following document(s) by the method indicated below: JOINT MOTION FOR RESCHEDULING OF EARLY NEUTRAL EVALUATION CONFERENCE

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by placing the document(s) listed above in a sealed envelope(s) with postage thereon fully prepaid, in the United States mail at Santa Monica, California addressed as set forth below. I am readily familiar with the firm's practice of collection and processing correspondence for mailing. Under that practice it would be deposited in the U.S. Postal Service on that same day with postage thereon fully prepaid 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 placing the document(s) listed above in a sealed envelope(s) and consigning it to an express mail service for guaranteed delivery on the next business day following the date of consignment to the address(es) set forth below. Jason A. Rodenbo, Esq. 402 West Broadway, Suite 400 SanDiego, CA 92101 Telephone: (619) 321-6950 Facsimile: (619) 535-3150

Thomas M. Diachenko, Esq. Law Offices of Thomas M. Diachenko, APC 1010 Second Avenue, Suite 1300 San Diego, CA 92101 Telephone: (619)699-5870 Facsimile: (619) 699-5871

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct, and that I am employed by an officer of a member of the bar ot this Court at whose direction the service was made. Executed on August 28, 2008 at Santa Monica, California.

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