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)

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
[phone]
4 [phone] – Facsimile
[e-mail]
5 [e-mail]
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.

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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

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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.
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26

September 14, 2011
Date: ____________________

_________________________________________________
THE HONORABLE JEFFREY S. WHITE
UNITED STATES DISTRICT COURT

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-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