Crosthwaite et al v. Brisbin

Filing 14

STIPULATION AND ORDER CONTINUING CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES. Initial Case Management Conference set for 1/13/2011 11:00 AM in Courtroom 9, 19th Floor, San Francisco. Joint case management statement due 1/6/2011. Signed by Judge William Alsup on 12/15/2010. (whasec, COURT STAFF) (Filed on 12/14/2010)

1 Muriel B. Kaplan, Esq. (SBN 124607) Blake E. Williams, Esq. (SBN 233158) 2 SALTZMAN & JOHNSON LAW CORPORATION 44 Montgomery Street, Suite 2110 3 San Francisco, CA 94104 [phone] 4 [phone] ­ Facsimile [e-mail] 5 [e-mail] 6 Attorneys for Plaintiffs 7 8 9 10 11 12 13 14 15 16 17 18 Plaintiffs and Defendants in the above-titled action jointly submit this Request to Continue v. JOHN CLARK BRISBIN, individually and dba CONSTRUCTION DEVELOPMENT SYSTEMS, Defendant. UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA F.G. CROSTHWAITE and RUSSELL E. BURNS, in their respective capacities as Trustees, et al., Plaintiffs, Case No.: C10-4266 WHA JOINT REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER THEREON Date: Time: Location: Courtroom: Judge: December 16, 2010 11:00 a.m. 450 Golden Gate Avenue San Francisco, CA 9, 19th Floor Honorable William H. Alsup

19 the Case Management Conference, based on the following: 20 1. This is an action by Plaintiff Trust Funds to compel Defendant's compliance with

21 an audit required by a Collective Bargaining Agreement to which he is signatory, and by the Trust 22 Agreements incorporated therein. 23 2. Counsel for both parties recently met and conferred. At his request, Plaintiffs

24 provided Defendant's counsel, Matthew W. Quall, Esq., with a copy of the letter sent previously 25 to Defendant, listing the records needed for an audit to be conducted. 26 3. Counsel for Plaintiffs and Defendant have discussed the scope of the audit and

27 compliance therewith by Defendant, with specific discussions regarding the scope and parameters 28 of the audit.
-1JOINT REQUEST TO CONTINUE CMC; [PROPOSED] ORDER Case No.: C10-4266 WHA

P:\CLIENTS\OE3CL\CDS - Construction Development Systems\Pleadings\C10-4266 WHA - Request to Continue CMC - 120910.DOC

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In an effort to keep fees and costs at a minimum, the parties respectfully request

2 that the currently set Case Management Conference be continued for a short period (including the 3 holiday periods) to January 13, 2011, to allow Defendant the opportunity to comply with the audit 4 before litigation proceeds further. 5 6 7 8 9 10 11 12 13 IT IS SO ORDERED. 14 The currently set Case Management Conference is hereby continued to January 13, 2011 at nded accordingly. 15 11:00 a.m., and all previously set deadlines and dates related to this case extevacated, to be reset at are 16 that Conference. 17
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Dated: December 9, 2010

SALTZMAN & JOHNSON LAW CORPORATION By: /S/ Muriel B. Kaplan Attorneys for Plaintiffs LANG, RICHERT & PATCH By: /S/ Matthew W. Quall Attorneys for Defendant

Dated: December 9, 2010

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18 Date: _________________________ December 14, 2010. 19 20

__________________________________ D United States SO ORDERE Judge S District Court
Judge W illiam A lsup

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P:\CLIENTS\OE3CL\CDS - Construction Development Systems\Pleadings\C10-4266 WHA - Request to Continue CMC - 120910.DOC

-2JOINT REQUEST TO CONTINUE CMC; [PROPOSED] ORDER Case No.: C10-4266 WHA

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