District Council 16 Northern California Health & Welfare Trust Fund et al v. Vanderhave Flooring et al

Filing 25

ORDER Initial Case Management Conference set for 6/3/2011 03:00 PM. (tf, COURT STAFF) (Filed on 3/15/2011)

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District Council 16 Northern California Health & Welfare Trust Fund et al ...nderhave Flooring et al Doc. 25 1 Muriel B. Kaplan, Esq. (SBN 124607) Michele R. Stafford, Esq. (SBN 172509) 2 SALTZMAN & JOHNSON LAW CORPORATION 44 Montgomery Street, Suite 2110 3 San Francisco, CA 94104 (415) 882-7900 4 (415) 882-9287 Facsimile mkaplan@sjlawcorp.com 5 mstafford@sjlawcorp.com 6 Attorney for Plaintiffs 7 8 9 10 11 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA Case No: C10-3515 SI REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE; PLAINTIFFS' CASE MANAGEMENT CONFERENCE STATEMENT; [PROPOSED] ORDER THEREON Date: Time: Ctrm: Judge: March 18, 2011 2:30 p.m. 10, 19th Floor The Honorable Susan Illston 12 DISTRICT COUNCIL 16 NORTHERN CALIFORNIA HEALTH AND WELFARE 13 TRUST FUND, et al., 14 15 Plaintiffs, v. 16 VANDERHAVE FLOORING, a California partnership; RALPH LEE VANDERHAVE, 17 partner; and CHRISTIAN LEE VANDERHAVE, partner, 18 Defendants. 19 20 Plaintiffs herein respectfully submit their Case Management Statement, requesting that the 21 Case Management Conference, currently on calendar for March 18, 2011, be continued for 22 approximately 60 days, pending Plaintiffs' filing their Motion for Default Judgment. 23 1. As the Court's records will reflect, a Complaint was filed in this matter on August 24 11, 2010. 25 2. Service on Defendants was effectuated on August 28, 2010, and a Proof of Service 26 of Summons was filed with the Court on August 30, 2010. 27 28 3. On October 5, 2010, the Court entered the default of all Defendants. -1REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE; PLAINTIFFS' CASE MANAGEMENT CONFERENCE STATEMENT; [PROPOSED] ORDER THEREON Case No.: C10-3515 SI P:\CLIENTS\FLRCL\Vanderhave Flooring\Pleadings\C10-3515 SI CMC Continuance Request 031011.DOC Dockets.Justia.com 1 4. Plaintiffs have prepared a Motion for Default Judgment which they anticipate filing 2 with the Court within seven days. 3 5. There are no issues that need to be addressed at the currently scheduled Case 4 Management Conference. In the interest of conserving costs as well as the Court's time and 5 resources, Plaintiffs respectfully request that the Case Management Conference, currently 6 scheduled for March 18, 2011, be vacated, or in the alternative be continued to either coincide 7 with the date to be set for the Motion or continued for 60 days to allow filing and disposition of 8 the Motion. 9 I declare under penalty of perjury that I am the attorney for the Plaintiffs in the above 10 entitled action, and that the foregoing is true of my own knowledge. 11 12 13 14 15 16 IT IS SO ORDERED. 17 Based on the foregoing, and GOOD CAUSE APPEARING, the currently set Case 18 Management Conference is hereby vacated. 19 20 or By: /S/Michele R. Stafford Michele R. Stafford Attorneys for Plaintiffs Executed this 10th day of March, 2011, at San Francisco, California. SALTZMAN & JOHNSON LAW CORPORATION Based on the foregoing, and GOOD CAUSE APPEARING, the currently set Case June 3, 2011 21 Management Conference is hereby continued to _____________________________. All related deadlines are extended accordingly. 22 23 3/15/11 24 Date: ____________________ 25 26 27 28 -2REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE; PLAINTIFFS' CASE MANAGEMENT CONFERENCE STATEMENT; [PROPOSED] ORDER THEREON Case No.: C10-3515 SI P:\CLIENTS\FLRCL\Vanderhave Flooring\Pleadings\C10-3515 SI CMC Continuance Request 031011.DOC _________________________________________________ THE HONORABLE SUSAN ILLSTON UNITED STATES DISTRICT COURT JUDGE 1 2 3 I, the undersigned, declare: PROOF OF SERVICE I am a citizen of the United States and am employed in the County of San Francisco, State 4 of California. I am over the age of eighteen and not a party to this action. My business address is 5 44 Montgomery Street, Suite 2110, San Francisco, California 94104. 6 7 8 On March 10, 2011, I served the following document(s): REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE; PLAINTIFFS' CASE MANAGEMENT CONFERENCE STATEMENT; [PROPOSED] ORDER THEREON 9 on the interested parties in said action by placing a true and exact copy of each document in a 10 sealed envelope with postage thereon fully prepaid, in a United States Post Office box in San 11 Francisco, California, addressed as follows: 12 13 14 15 16 Vanderhave Flooring 469 Moffat Boulevard, Suite E Manteca, California 95336 Christian Lee Vanderhave 469 Moffat Boulevard, Suite E Manteca, California 95336 I declare under penalty of perjury that the foregoing is true and correct and that this Ralph Lee Vanderhave 469 Moffat Boulevard, Suite E Manteca, California 95336 17 declaration was executed on this 10th day of M arch, 2011, at San Francisco, California. 18 19 20 21 22 23 24 25 26 27 28 -3REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE; PLAINTIFFS' CASE MANAGEMENT CONFERENCE STATEMENT; [PROPOSED] ORDER THEREON Case No.: C10-3515 SI P:\CLIENTS\FLRCL\Vanderhave Flooring\Pleadings\C10-3515 SI CMC Continuance Request 031011.DOC ________________/S/________________ Vanessa de Fabrega

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