1 COX, WOOTTON, GRIFFIN,
HANSEN & POULOS LLP
` 2 Gregory W. Poulos (SBN 131428)
Max L, Kelley (SBN 205943)
3 190 The Embarcadero
San Francisco, CA 94105
4 Telephone No.: 415-438-4600
Facsimile No.: 415-438-4601
` 5
LAW OFFICES OF RICHARD P. WAGNER -
6 Richard P. Wagner (SBN 166792)
` 700 Oceangate, Suite 700
7 Long Beach, CA 90802
Telephone: (562) 216-2946
8 Facsimile: (562) 216-2960
9 Attorneys for Plaintiff
10 DEL MAR SEAFOODS, INC. `
11
12 UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
13 SAN FRANCISCO DIVISION
14
15 DEL MAR SEAFOODS, INC. ) Case No.: CV 07-02952 WHA
)
Plaintif£ ) STIPULATED REQUEST FOR
16 ) ORDER CONTINUING HEARINGS
vs. ) RE ORAL ARGUMENT AND
17 ) RULING ’
BARRY COI-IEN, CI-IRIS COHEN (aka )
18 CI-IRISTENE COI-IEN), in persomxm and )
F/V POINT LOMA, Official Number )
19 515298, a 1968 steel-hulled, 126-gross ton, )
70.8- foot long fishing vessel, her engines, )
20 tackle, furniture, apparel, etc., in rem, and ) ‘
Does 1-10, I
21 )
Defendants. ) Oral Argument Hearing: June 5, 2008
22 I 3:15 pm.
) Ruling: June 6, 2008
23 I 7:30 am.
_ ) Courtroom 9, 19m Floor
24 And Related Counterclaims 3 {-{0,, Wjmam H_ Alsup
25
26 Pursuant to Local Rule 6-2, the parties jointly submit this Stipulated Request for an
Ni»iiiiti=§li§€
-1- Case No.: CV 07-02952 WIIA
STIPULATED REQUEST FOR ORDER CONTINUING HEARINGS ON ORAL ARGUMENT and RULING
Case 3:O7—cv—O2952—WHA Document 186 Filed 06/O4/2008 Page 2 of 3
l Fact and Conclusions of Law on Thursday, June 5, 2008, at 3:15 p.1n. and that the parties
2 return for the Court’s ruling the following morning, Friday, June 6, 2008, at 7:30 a.m. The
3 parties respectfully request that the Court grant this Stipuiated Request to change the date of
4 the hearing for oral argument to Monday, June 16, 2008, or the soonest day thereafter that is
5 convenient to the Court, and to change the date for the Court’s ruling to tbllow as is
6 convenient.
7 I. BASIS FOR STIPULATED REQUEST
8 Gregory Poulos, lead trial counsel for Plaintiff Del Mar Seafoods, Inc., is currently
9 out of the country and will not return until June 12, 2008. Mr. Poulos is currently in Athens,
10 Greece to co—chair the International Maritime Law Conference sponsored by the International
11 Bar Association which runs from June 8 through June 10, 2008. (The website for the
12 Conference is: http://www.ibanet.org/conferences/Mariti1ne%5FLaw/) Mr. Poulos had
13 committed to serving as co-chair and scheduled this trip approximately one year in advance,
_ 14 and the trip was pre-paid. See Declaration of Max L. Kelley ("Kelley Dec."), 11 2.
15 The first day Mr. Poulos would be available for oral argument would be June 13,
16 2008, however, Mr. Walsh will be out of town on that day. Id., 11 3.
17 II. PREVIOUS TIME MODIFICATIONS 2
18 There have been three: l
19 1. The Court granted Defendants’ Motion for Administrative Relief to Shorten
20 Time for Hearing Defendants’ Motion for Protective Order Limiting
2] Deposition of Christene Cohen on December 19, 2007;
22 2. The Court granted the parties’ Stipulated Request for Order Enlarging Time
23 for Hearing on Plaintiff s Motion for Summary Judgment, or Alternatively,
24 Partial Summary Judgment on March 5, 2008 because lead defense counsel
25 would be out of the country; and
26 3. The Court extended the time to file responses to each parties’ Proposed
'°£l¥l?rE;§§§‘&“?¥}?° 27 Findings of Facts and Conclusions of Law on May 23, 2008 because lead I
gkmigiiiggi 28 defense counsel would be out of town. l ·
~2— case No.: cv or-02052 wnA
STIPULATED REQUEST FOR ORDER CONTINUING HEARINGS ON ORAL ARGUMENT and RULING I
Case 3:O7—cv—O2952—WHA Document 186 Filed 06/O4/2008 Page 3 of 3
1 III. EFFECT ON CASE SCHEDULE _
2 The proposed change to the hearing dates will postpone the date ofthe Court’S ruling.
3 IV. CONCLUSION
4 Because Plaintiff’s lead trial counsel is out ofthe country on a pre—planned and pre~
5 paid business/professional engagement until June l2, 2008, and lead defense counsel will be
6 out of town on June 13, 2008, the parties respectfully request that the Court grant the
7 Stipulated Request to continue the hearing for oral argument until June 16, 2008 at tlre
8 earliest, with the hearing to issue the Court’s ruling to follow.
9
Dated: June 4, 2007 COX, WOOTTON, GRIFFIN,
10 HANSEN & ROULOS, LLP
Attorneys for Plaintiff
1 1 DEL MAR SEAFOODS, 1Nc.
I2
13 By: /
Max L. Kelley
14 Gregory W. Poulos
15
Dated: June 4, 2007 DAVIS WRIGHT TREMAINE LLP
16 Attorneys for Defendants, BARRY COHEN,
CHRIS COHEN, F/V POINT LOMA and the
17 F/V POINT LOMA FISHING COMPANY,
INC.
18 _
19 `
20 By: /5;
James P. Walsh
21 Gwen Fanger
22
23
24 _
25
COX, \VOO'l'l‘0N,
G;;·:t.t:I:IiSt 26
'°2,llll?@§§£*€.§E‘t}l‘“ 27 ‘
FAX-IIS-ISIS-l(~¤I
-3- Case No.: CV 07-02952 WHA
STIPULATED REQUEST FOR ORDER CONTINUING HEARINGS ON ORAL ARGUMENT and RULING
Case 3:07-cv-02952-WHA
Document 186
Filed 06/04/2008
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