Free Motion to Continue - District Court of California - California

Case 3:07-cv-05641-SI

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Filed 02/07/2008

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KENNETH E. KELLER (SBN 71450) [email protected] MICHAEL D. LISI (SBN 196974) [email protected] ANJALI K. KURANI (SBN 227075) [email protected] KRIEG, KELLER, SLOAN, REILLEY & ROMAN LLP 114 Sansome Street, 4th Floor San Francisco, California 94104-3839 Telephone: (415) 249-8330 Facsimile: (415) 249-8333 Attorneys for Plaintiff, Chanel, Inc.

THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA CHANEL, INC., a New York corporation, Plaintiff, v. SEOUNG HYUN KIM a/k/a BAILEY KIM and HARRISON Y. CHANG a/k/a HARRY CHANG, Individually and Jointly D/B/A SWISSWATCHFACTORY.COM d/b/a SWISS WATCH FACTORY d/b/a NEOLINE GROUP d/b/a [email protected] d/b/a NEOLINE INC. d/b/a SWISSWATCHCRAFT.COM d/b/a OHMYWATCH.COM and DOES 1 through 10 Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. C-07-5641-SI PLAINTIFF CHANEL, INC.'S REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER Date Filed: November 7, 2007 Original Date of CMC: February 15, 2008, 2:00 pm [Proposed] Date of CMC: March 28, 2008, 2:00 pm

WHEREAS, Plaintiff Chanel, Inc. ("Chanel") filed the complaint on November 7, 2007; WHEREAS, Chanel served Defendant Seoung Hyun Kim ("Defendant Kim") on January 11, 2008; WHEREAS, twenty (20) days has passed since Plaintiff properly effected service upon Defendant Kim and Defendant Kim has not answered or made any response to the Complaint; 1 ___________________________________________________________________________ CHANEL'S REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE Case No. C- C-07-5641

Case 3:07-cv-05641-SI

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Filed 02/07/2008

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WHEREAS, based on the lack of response, Chanel is preparing and will shortly file a Request for Entry of Default as to Defendant Kim; WHEREAS, Chanel is still attempting to effect service on Defendant Harrison Y. Chang ("Defendant Chang"); WHEREAS, the Case Management Conference is currently scheduled for February 15, 2008 at 2:00 p.m.; WHEREAS, because of this lack of response from Defendant Kim and the difficulty serving Defendant Chang as of this date, Chanel believes it has good cause to continue the Case Management Conference to permit entry of default as to Defendant Kim and to permit further efforts to serve Defendant Chang; THEREFORE, Chanel hereby requests that the Court continue the Case Management Conference until March 28, 2007 at 2:00 p.m. Dated: February 7, 2008 KRIEG, KELLER, SLOAN, REILLEY & ROMAN LLP

By: ____________/s/________________________ MCIHAEL D. LISI Attorneys for Plaintiff CHANEL, INC.

[PROPOSED] ORDER IT IS HEREBY ORDERED that the Initial Case Management Conference is continued until March 28, 2008 at 2:00 p.m.

Dated: February __, 2008

____________________________________ UNITED STATES DISTRICT JUDGE SUSAN ILLSTON

2 ___________________________________________________________________________ CHANEL'S REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE Case No. C- C-07-5641