F.G. Crosthwaite and Russell E. Burns et al v. Cooper Crane & Rigging, Inc.

Filing 20

ORDER granting 19 Request to Vacate or Continue Case Management Conference. Signed by Judge JEFFREY S. WHITE on 9/14/11. (jjoS, COURT STAFF) (Filed on 9/14/2011)

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Case3:11-cv-02866-JSW Document19 Filed09/13/11 Page1 of 3 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 Attorneys for Plaintiffs 7 8 9 UNITED STATES DISTRICT COURT 10 FOR THE NORTHERN DISTRICT OF CALIFORNIA 11 F.G. CROSTHWAITE and RUSSELL E. 12 BURNS, in their respective capacities as Trustees, of the OPERATING ENGINEERS’ 13 HEALTH AND WELFARE TRUST FUND FOR NORTHERN CALIFORNIA; 14 Plaintiffs, 15 v. 16 COOPER CRANE & RIGGING, INC., dba 17 ASSOCIATED DOCK ENTERPRISES, INC.; and dba WESTERN DOCK ENTERPRISES, 18 California Corporations, Case No.: C11-2866 JSW REQUEST TO VACATE OR CONTINUE CASE MANAGEMENT CONFERENCE; PLAINTIFFS’ CASE MANAGEMENT CONFERENCE STATEMENT; [PROPOSED] ORDER THEREON Date: September 23, 2011 Time: 1:30 p.m. Ctrm: 11, 19th Floor Judge: The Honorable Jeffrey S. White Defendants. 19 20 21 Plaintiffs herein respectfully submit their Case Management Statement, requesting that the 22 Case Management Conference, currently on calendar for September 23, 2011, be vacated, or in the 23 alternative be continued to coincide with the date set for the Motion. 24 1. As the Court’s records will reflect, a Complaint was filed in this matter on June 10, 25 2011, to compel Defendants’ compliance with their obligations under the Collective Bargaining 26 Agreements to which they are signatory. 27 2. Service on Defendants was effectuated on June 14, 2011, and a Proof of Service of 28 Summons was filed with the Court on June 21, 2011. -1REQUEST TO VACATE OR CONTINUE CASE MANAGEMENT CONFERENCE Case No.: C11-2866 JSW P:\CLIENTS\OE3CL\Cooper Crane & Rigging, Inc\Pleadings\C11-2866 JSW CMC Continuance Request 091311.DOC Case3:11-cv-02866-JSW Document19 Filed09/13/11 Page2 of 3 1 3. On July 21, 2011, the Court entered the default of Defendants. 2 4. On August 26, 2011, Plaintiffs filed a Motion for Default Judgment with 3 supporting Declarations. 4 5. On August 29, 2011, Plaintiffs’ Motion for Default Judgment was referred to 5 Magistrate Judge Laurel Beeler for Report and Recommendation. 6 6. There are no issues that need to be addressed at the currently scheduled Case 7 Management Conference. In the interest of conserving costs as well as the Court’s time and 8 resources, Plaintiffs respectfully request that the Case Management Conference, currently 9 scheduled for September 23, 2011, be vacated, or in the alternative be continued to coincide with 10 the date set for the Motion. 11 I declare under penalty of perjury that I am the attorney for the Plaintiffs in the above 12 entitled action, and that the foregoing is true of my own knowledge. 13 Executed this 13th day of September, 2011, at San Francisco, California. SALTZMAN & JOHNSON LAW CORPORATION 14 15 By: /S/Michele R. Stafford Michele R. Stafford Attorneys for Plaintiffs 16 17 18 ORDER 19 IT IS SO ORDERED. 20 Based on the foregoing, and GOOD CAUSE APPEARING, the currently set Case 21 Management Conference is hereby vacated. 22 or 23 Based on the foregoing, and GOOD CAUSE APPEARING, the currently set Case Management Conference is hereby continued to _____________________________. All related 24 deadlines are extended accordingly. 25 26 September 14, 2011 Date: ____________________ _________________________________________________ THE HONORABLE JEFFREY S. WHITE UNITED STATES DISTRICT COURT 27 28 -2REQUEST TO VACATE OR CONTINUE CASE MANAGEMENT CONFERENCE Case No.: C11-2866 JSW P:\CLIENTS\OE3CL\Cooper Crane & Rigging, Inc\Pleadings\C11-2866 JSW CMC Continuance Request 091311.DOC

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