Free Motion to Continue - District Court of California - California

Case 3:08-cv-00439-L-RBB

Document 11

Filed 04/21/2008

Page 1 of 2

1 THOMAS F. FRIEDBERG, ESQ. (#110439) LAW OFFICES OF FRIEDBERG & BUNGE 2 610 WEST ASH STREET, SUITE 1400 P.O. BOX 6814 3 SAN DIEGO, CA 92166-0814 TEL : (619) 557-0101 4 FAX: (619) 557-0560 "[email protected]" 5 Attorneys for Plaintiff 6 7 8 9 10 11 BEN GILES, 12 13 v. 14 JUSTIN PAUL THOMPSON, WATER TOYS, INC., ISLAND BOAT RENTALS, KDME, 15 INC., and DOES I through L, inclusive, 16 17 18 19 This is an action for damages under general maritime law arising out of a personal water Defendants. Action Filed : March 10, 2008 Plaintiff, UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA CASE NO. 08CV0439 L RBB JOINT MOTION TO CONTINUE EARLY NEUTRAL EVALUATION CONFERENCE DATE : April 30, 2008 TIME : 10:00 a.m. LOCATION : Chambers, Hon. Ruben B. Brooks

20 craft accident that occurred on San Diego Mission Bay on April 3, 2005. The present action was 21 filed on March 10, 2008. All parties have been served to date. Defendant, KDME, INC., filed 22 an answer to the complaint on or about March 28, 2008. No other answers have been filed. 23 The Court has scheduled an Early Neutral Evaluation Conference for April 30, 2008, at

24 10:0 a.m. Plaintiff's counsel is scheduled to start trial in the case of Thomas O'Shea and Zachary 25 Vance vs. County of San Diego, et al., GIC 876296 in Department C-75 of the San Diego 26 Superior Court on April 25, 2008. The case will last at between 4 to 6 trial days and, if it goes 27 out, will conflict with the Early Neutral Evaluation Conference. Plaintiff's counsel is scheduled 28 to be out of San Diego County between May 8 through May 16, 2008.
Ben Giles JOINT MOTION TO CONTINUE EARLY NEUTRAL EVALUATION CONFERENCE - PAGE 1

Case 3:08-cv-00439-L-RBB

Document 11

Filed 04/21/2008

Page 2 of 2

1

Plaintiff's counsel contacted the Court and was advised that the last date for the Early

2 Neutral Evaluation Conference to be held without Court Order was May 12, 2008. The next 3 available date was May 19, 2008, at either 8:30 a.m. or 1:30 p.m., but either an ex parte 4 application or a Joint Motion would need to be filed. Plaintiff's counsel contacted Thomas 5 Feerick, the attorney for KDME, Inc., who agreed to a continuance of the Early Neutral 6 Evaluation Conference to May 19, 2008, at 1:30 p.m. 7 8 NOW THEREFORE: IT IS HEREBY STIPULATED AND AGREED that based on the calendar conflict of

9 plaintiff's counsel, the Early Neutral Evaluation Conference in the above matter may be continued 10 to May 19, 2008, at 1:30 p.m. 11 12 DATED: April 17, 2008 13 14 15 16 17 DATED: April 17, 2008 18 19 20 21 22 23 24 25 26 27 28 By: S/THOMAS F. FEERICK THOMAS F. FEERICK, ESQ. Attorney for Defendant, KDME, INC. FEERICK & ASSOCIATES By: S/THOMAS F. FRIEDBERG THOMAS F. FRIEDBERG, ESQ. Attorney for Plaintiff, BEN GILES LAW OFFICES OF FRIEDBERG & BUNGE

Ben Giles

JOINT MOTION TO CONTINUE EARLY NEUTRAL EVALUATION CONFERENCE - PAGE 2