Bay Area Painters and Tapers Pension Trust Fund, and its Joint Board of Trustees et al v. Oaktown Construction, Inc. et al

Filing 15

ORDER Initial Case Management Conference set for 7/8/2011 02:30 PM. (tf, COURT STAFF) (Filed on 5/5/2011)

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
[phone]
4 [phone] – Facsimile
[e-mail]
5 [e-mail]
6 Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

10 BAY AREA PAINTERS AND TAPERS
PENSION TRUST FUND, and its JOINT
11 BOARD OF TRUSTEES; LES PROTEAU and
CHARLES DEL MONTE, TRUSTEES,
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Plaintiffs,
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v.
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OAKTOWN CONSTRUCTION, INC., a
15 California corporation; and JOSIE RAGAS
McFARLANE, individually,
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Defendants.
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Case No.: C11-0483 SI
REQUEST FOR CONTINUANCE OF
CASE MANAGEMENT CONFERENCE
Date:
Time:
Courtroom:
Judge:

May 13, 2011
2:30 p.m.
10, 19th Floor
450 Golden Gate Avenue
San Francisco, CA 94102
The Honorable Susan Illston

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Plaintiffs respectfully request that the Case Management Conference currently scheduled

20 for May 13, 2011, at 2:30 p.m., be continued for approximately 60 - 90 days, as follows:
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1.

A Complaint was filed in this action on February 1, 2011 for contributions due to

22 the Trust Funds for work performed by Defendants’ employees.
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2.

Defendants have paid a portion of the contributions due, and have requested a

24 payment plan to satisfy the remaining balance. The payment plan will be in the form of a
25 Stipulated Judgment (“Stipulation”). Plaintiffs are in the process of preparing the Stipulation.
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3.

Plaintiffs have also granted an extension for Defendants to file an Answer, in

27 anticipation of the matter being resolved by Stipulation.
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4.

The parties estimate that the Stipulated Judgment will be filed in the next thirty
-1REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE
Case No.: C11-0483 SI

P:\CLIENTS\PATCL\Oaktown Construction 2\Pleadings\C11-0483 SI - Request to Continue CMC 050311.DOC

1 (30) days.
5.

2

Therefore, Plaintiffs respectfully request that the Case Management Conference be

3 continued for approximately 60 - 90 days in order to allow preparation, review, and signature of
4 the Stipulated Judgment.
5 Date: May 3, 2011

SALTZMAN & JOHNSON
LAW CORPORATION

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By:

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__________/s/______________
Michele R. Stafford
Attorneys for Plaintiffs

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10
11 ORDER
12 The Case Management Conference currently scheduled for May 13, 2011 at 2:30 p.m. is hereby
13 continued to ______________________. All related deadlines are extended accordingly.
7/8/11
14
15 Date:
16

5/4/11

_______________________________________
UNITED STATES DISTRICT COURT JUDGE

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-2REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE
Case No.: C11-0483 SI

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PROOF OF SERVICE:

1
2 I, the undersigned, declare:
3

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

On May 3, 2011, I served the following document(s):
REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE

8 on the interested parties in said action by First Class U.S. Mail by placing a true and exact copy of
9 each document in a sealed envelope with postage thereon fully prepaid, in a United States Post
10 Office box in San Francisco, California, addressed as follows:
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Attorneys for Defendant:

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Patricia Walsh, Esq.
Leonidou & Rosin Professional Corporation
777 Cuesta Drive, Suite 200
Mountain View, California 94040

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I declare under penalty of perjury that the foregoing is true and correct and that this

16 declaration was executed on this 3rd day of May, 2011, at San Francisco, California.
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___________/s/_______________
Qui X. Lu

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P:\CLIENTS\PATCL\Oaktown Construction 2\Pleadings\C11-0483 SI - Request to Continue CMC 050311.DOC

-1PROOF OF SERVICE
Case No.: C11-0483 SI