Paulsen et al v. Local No. 856 of International Brotherhood of Teamsters et al

Filing 17

STIPULATION AND ORDER CONTINUING Initial Case Management Conference to 10/31/2008 10:00 AM. Signed by Judge Elizabeth D. Laporte on 9/23/08. (lmh, COURT STAFF) (Filed on 9/23/2008)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

ANDREW H. BAKER, SBN 104197 BEESON, TAYER & BODINE, APC 1404 Franklin Street, 5th Floor Oakland, CA 94612-3208 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Attorneys for Defendants Teamsters Local 856 & Joe Martinelli RICHARD W. GIBSON, Admitted Pro Hac Vice INTERNATIONAL BROTHERHOOD OF TEAMSTERS 25 Louisiana Avenue, NW Washington, D.C. 20001 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Attorney for Defendant IBT DAVID M. POORE, SBN 192541 SCOTT A. BROWN, SBN 177099 KAHN BROWN & POORE LLP 110 Kentucky Street Petaluma, CA 94952 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Attorneys for Plaintiffs UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA AT SAN FRANCISCO KATHLEEN PAULSEN, et al. Plaintiffs, v. TEAMSTERS LOCAL 856; INTERNATIONAL BROTHERHOOD OF TEAMSTERS; AND JOE MARTINELLI, Defendants. Case No. C08-3109 EDL STIPULATION AND PROPOSED ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE Hearing Date: Hearing Time: Courtroom: Judge: Complaint Filed: September 30, 2008 3:00 p.m. E, 15th Floor Elizabeth D. Laporte June 26, 2008

STIP & PROPOSED ORDER TO CONTINUE CMC Case No. C08-3109 EDL

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 /// /// ///

Plaintiffs and Defendants Teamsters Local 856, International Brotherhood of Teamsters, and Joseph Martinelli hereby stipulate to continue the Initial Case Management Conference in this matter, currently calendared for September 30, 2008, to October 31, 2008, immediately following the hearing in this matter on Defendants' Motions to Dismiss, or on a later date after determination on the Motions. Good cause exists to grant this continuance on the following grounds: (1) Defendants have filed Motions to Dismiss the Complaint which are set for hearing approximately one month after the presently scheduled Initial Case Management Conference; (2) the outcome of the Motions to Dismiss would likely impact the scope and substance of the pre-trial scheduling order in this case; and (3) judicial economy, including the costs of litigation, would be furthered by either hearing the Motions concurrently with the Initial Case Management Conference, or setting the Initial Case Management Conference after the determination on the pending Motions. The parties are not making this request for any improper purpose, including delay. Dated: September 23, 2008 BEESON, TAYER & BODINE, APC By: /s/Andrew H. Baker ANDREW H. BAKER Attorneys for Teamsters Local 856 & Joe Martinelli Dated: September 23, 2008 INTNL. BROTHERHOOD OF TEAMSTERS By: /s/Richard W. Gibson RICHARD W. GIBSON Attorneys for IBT Dated: September 23, 2008 KAHN BROWN & POORE LLP By: /s/David M. Poore DAVID M. POORE Attorneys for Plaintiffs

1
STIP & PROPOSED ORDER TO CONTINUE CMC Case No. C08-3109 EDL

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

PURSUANT TO STIPULATION, IT IS SO ORDERED. The Initial Case Management Conference October 31 10:0 __.m. is hereby continued from September 30, 2008, to ________________, 2008, at ____ 0 a in Courtroom E, 15th Floor, 450 Golden Gate, San Francisco, California.

UNIT ED

September 23, 2008 Dated: _________________

ER

N

D IS T IC T R

OF

A

C

LI

FO

La beth D. ge Eliza Ju d

porte

R NIA

___________________________________ Honorable Elizabeth D. Laporte RED U.S. MagistrateSO ORDE Judge IS

S

S DISTRICT TE C TA

RT U O

IT

NO

RT
STIP & PROPOSED ORDER TO CONTINUE CMC Case No. C08-3109 EDL

H

2