Board of Trustees of the Northern California Sheet Metal Workers Health Care Plan et al v. Ram Mechanical, Inc.

Filing 5

ORDER Case Management Statement due by 12/1/2011. Case Management Conference set for 12/8/2011 10:00 AM in Courtroom B, 15th Floor, San Francisco.. Signed by Judge Maria-Elena James on 10/11/11. (cdnS, COURT STAFF) (Filed on 10/11/2011)

1

4

ERSKINE & TULLEY
A PROFESSIONAL CORPORATION
MICHAEL J. CARROLL (St. Bar #50246)
3030 Bridgeway, Suite 121
Sausalito, CA 94965
Telephone: [phone]
FAX: [phone]

5

Attorneys for Plaintiffs

2
3

6
7
8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

10
11
12
13
14
15
16

BOARD OF TRUSTEES OF THE NORTHERN
CALIFORNIA SHEET METAL, et al.,

)
)
)
Plaintiffs,
)
)
vs.
)
)
RAM MECHANICAL, INC., etc.,
)
)
Defendant.
)
____________________________________ )

NO.

C 11 3360 MEJ

PLAINTIFFS’ CASE
MANAGEMENT STATEMENT &
REQUEST FOR CONTINUANCE;
ORDER
DATE: 10/20/11
TIME: 10:00 a.m.

17

Plaintiffs in the above-entitled action submit this Case

18

Management Statement reporting on the status of this case as follows:

19

1.

Service

was

accomplished

20

subservice on July 14, 2011.

21

upon

the

only

party

by

filed.

22
23
24

2.

No responsive pleading has yet been

An extension of time to plead has been granted to

defendant’s newly retained counsel to October 14, 2011.
3.

The efforts to settle this matter continue and

25

defendant has requested that its latest position be considered by the

26

Trustees who meet next on November 16, 2011.

27

4. It is respectfully requested that the Court continue the

28

Case Management Conference to December 8, 2011 to allow defendant time

PLAINTIFFS’ CASE MANAGEMENT STATEMENT & REQUEST FOR CONTINUANCE; ORDER

1

1

to file an Answer in this case and for the Trustees to review

2

defendant’s latest position.

3

5.

Good cause exists to grant plaintiffs’ request for a

4

continuance of the Case Management Conference currently set for

5

October 20, 2011 to December 8, 2011 to allow the parties additional

6

time to work on settlement of this case and avoid any unnecessary

7

burden to the Court.

8
9
10

I declare under penalty of perjury that the foregoing is
true and correct to the best of my knowledge.
Executed on October 10, 2011 at Sausalito, California.

11
/s/ Michael J. Carroll
Michael J. Carroll

12
13
14
15

O R D E R

16

IT IS ORDERED that the Case Management Conference in this

17

case set for October 20, 2011 be continued to December 8, 2011 at

18

10:00 a.m. in Courtroom No. B, 15th Floor, 450 Golden Gate Avenue, San

19

Francisco, California.
October 11, 2011
Dated:_________________

20

____________________________________
Magistrate Judge Maria-Elena James

21
22
23
24
25
26
27
28

PLAINTIFFS’ CASE MANAGEMENT STATEMENT & REQUEST FOR CONTINUANCE; ORDER

2

1

PROOF OF SERVICE BY MAIL

2

I am a citizen of the United States and employed in the City of

3

Sausalito, County of Marin, California. I am over the age of eighteen

4

years and not a party to the within above entitled action; my business

5

address is 3030 Bridgeway, Suite 121, Sausalito, CA 94965. On October

6

10, 2011 I served the within PLAINTIFFS’ CASE MANAGEMENT STATEMENT &

7

REQUEST FOR CONTINUANCE; ORDER on defendant’s counsel in said action,

8

by placing a true copy thereof enclosed in a sealed envelope with

9

postage thereon fully prepaid, in the United States post office mail

10

box at Rio Vista, addressed as follows:

11

13

Charles K. Brunn
Mahanvir S. Sahota
Brunn & Flynn
928-12th Street, Suite 200
Modesto, CA 95354

14

I, DIANE ANDRADE, certify (or declare), under penalty of perjury that

15

the foregoing is true and correct.

16

Executed on October 10, 2011 at Rio Vista, California.

12

17
18
19
20
21
22
23
24
25
26
27
28

/s/Diane Andrade
DIANE ANDRADE