Free Motion to Continue - District Court of California - California

Case 3:08-cv-01352-EDL

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Filed 06/13/2008

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RONALD V. UY, SBN 177157 LAW OFFICE OF RONALD V. UY 1212 Broadway, Suite 706 Oakland, CA 94612 Telephone: (510) 835-3730 Facsimile: (650) 835-3731 Attorney for Plaintiff

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA JULIE MACARAIG, Plaintiff, vs MATTHEW CHARLES STEGMAN, UNITED STATES OF AMERICA, BRIAN VINCENT PACE Defendants ) Case No. C08-01352 EDL ) ) REQUEST TO CASE MANAGEMENT ) CONFERENCE ) ) ) ) ) ) ) ) ) ) ) )

Plaintiff, Julie Macaraig, through her attorney of record, Ronald V. Uy, hereby request that the Case Management Conference currently scheduled for hearing on June 17, 2008 at 10:00 a.m. be continued for thirty (30) to forty-five (45) days. The defendant, United States of America has recently been served by certified mail but has not yet responded and the remaining two defendants, Matthew Charles Stegman have not yet been served with the Summons and Complaint, although attempts at service are being made. Currently, process servers are attempting to serve Defendants Stegman and Brian Vincent Pace but have not accomplished service. I anticipate that service on the remaining two defendants will be accomplished within the next five to ten days and that if the Case Management Conference is

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Case 3:08-cv-01352-EDL

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continued for a period of forty-five days, all party defendants should have filed their answer to the pending complaint.

Respectfully Submitted:

Dated: June 12, 2008

__S/ RONALD V.UY____________ RONALD V.UY Attorney for Plaintiff

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PROOF OF SERVICE
I, TARIK S. SOUDANI, declare I am employed in the county of Alameda, State of California. I am over the age of 18. On June 10, 2008, I served the foregoing document(s) described as REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE AND PROPOSED ORDER Upon the following persons:

Joseph P. Russonello United States Attorney Civil Processing Unit 450 Golden Gate Avenue San Francisco, CA 94102 GENERAL COUNSEL G.S.A. 18TH & F Street, N.W. Room 4139 Washington, DC 20405

Michael Mukasey United States Attorney 950 Pennsylvania Avenue, N.W Washington, D.C. 20530

( XX ) (By U.S. Mail) I caused such envelope with postage thereon fully prepaid to be placed in the United States mail at Encinitas, California. I declare that I am employed in the office of a member of the bar of this court at whose direction this service was made. I declare under penalty of perjury under the laws of the State of California that the above is true and correct and that this declaration was executed on June12, 2008, at Oakland, California.

_____s/ Tarik S. Soudani_____________________

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