Free Motion to Continue - District Court of California - California

Case 5:07-cv-02710-JF

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Filed 08/21/2007

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JAMES DAL BON CA BAR #157942 DAL BON AND WANG 12 SOUTH FIRST STREET #613 SAN JOSE, CA 95113 TEL (408) 292-1040 FAX (408) 292-1045 ATTORNEY FOR PLAINTIFFS

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA ) CASE NO: C07-02710 JF ) 1) MOTION TO MOVE CASE ) AUGUSTIN MARTINEZ, JULIO JIMENEZ, ) MANAGEMENT CONFERENCE ) GUADALUPE SOTO, AND ANGEL ) ) LOMELI, ) ) PLAINTIFFS, ) ) VS. ) ) AC LUMBER, SURINDER CHAWLA AND ) ) AMAR S. CHAWLA, AND DOES 1-10 ) DEFENDANTS NATURE OF CASE This is an action on behalf of AUGUSTIN MARTINEZ, JULIOPlaintiffs move to continue the Case Management conference for the following reasons: 1) The present Case Management Conference is set for August 31, 2007. 2) On May 22, 2007 Plaintiffs served the complaint on the Defendants in this case.

COMPLAINT - 1

Case 5:07-cv-02710-JF

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3) The Plaintiff has attempted to serve the Defendant at his place of business. The Defendant has apparently moved his place of business. See Exhibit 1 The plaintiff's counsel has attempted to find the Defendant's home address over the internet and failed. The plaintiff's counsel has been forced to hire a private investigator to find the defendant. 4) Plaintiff respectfully requests that the Case Management Conference be moved to October 5, 2007 in order to give the Plaintiff's attorney more time to find the Defendant an serve them

Dated August 21, 2007 Respectfully Submitted ___s/jdb_______________________ James Dal Bon Attorney for the Plaintiff DECLARATION OF JAMES DAL BON 1) I declare under the penalty of perjury by the laws of the State of California that the following is true and correct: 2) The Proofs of Service attached to this Motion and marked Exhibit 1 are true copies of the Proofs our process server signed in this case. August 21, 2007 ____s_/jdb_________ James Dal Bon

COMPLAINT - 2

Case 5:07-cv-02710-JF

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Attorney for Plaintiff

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Case 5:07-cv-02710-JF

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Dated:

IT IS SO ORDERED,

_________________________ Honorable United States Court District Judge Jeremy Fogel

COMPLAINT - 4