Northern California Glaziers Architectural Metal and Glass Workers Pension Plan et al v. Vaheid

Filing 39

ORDER Granting 38 MOTION to Continue JOINT REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE. Case Management Statement due by 12/6/2013. Case Management Conference set for 12/13/2013 10:00 AM in Courtroom 1, 17th Floor, San Francisco. Signed by Judge Samuel Conti on 08/19/2013. (tmi, COURT STAFF) (Filed on 8/19/2013)

1 Michele R. Stafford, Esq. (SBN 172509)
Muriel B. Kaplan, Esq. (SBN 124607)
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 Patricia Walsh, Esq. (SBN 121098)
LEONIDOU & ROSIN PROFESSIONAL CORPORATION
8 777 Cuesta Drive, Suite 200
Mountain View, California 94040
9 [phone]
[e-mail]
10
Attorneys for Defendants
11
UNITED STATES DISTRICT COURT
12
FOR THE NORTHERN DISTRICT OF CALIFORNIA
13
NORTHERN CALIFORNIA GLAZIERS,
Case No.: C11-5116 SC
14 ARCHITECTURAL METAL AND GLASS
WORKERS PENSION PLAN, et al.
JOINT REQUEST FOR CONTINUANCE
OF CASE MANAGEMENT
15
Plaintiffs,
CONFERENCE; and [PROPOSED]
ORDER THEREON
16
v.
Date: Friday, August 23, 2013
17
HOSSEIN VAHEID, individually and dba
Time: 10:00 a.m.
Ctrm: 1, 17th Floor
18 UNITED GLASS & ALUMINUM; aka T P
WINDOWS, INC., a California corporation,
450 Golden Gate Avenue
San Francisco, California
19
Defendants.
Judge: The Honorable Samuel Conti
20
21
22

Plaintiffs and Defendants both respectfully request

that

the

Case

Management

23 Conference scheduled for August 23, 2013, at 10:00 a.m., be continued for approximately ninety
24 (90) days, as follows:
25

1.

The Parties recognize that this Court has granted several continuances of the Case

26 Management Conference. The Parties have attempted to work together over the past several
27 months to resolve several outstanding discrepancies with regard to the results of an audit taken of
28

payroll records.
-1JOINT REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE; and [PROPOSED] ORDER THEREON
Case No.: C11-5116 SC
P:\CLIENTS\GLACL\United Glass & Aluminum\Pleadings\C11-5116 SC - Joint Request to Continue CMC 081413.docx

2.

1

An ADR telephone conference was conducted and both parties agreed to participate

2 in mediation within ninety (90) days.

The parties did not receive the expected referral to

3 mediation, so prepared and submitted an ADR Stipulation, stipulating to mediation. There was a
. Both parties are now in the process of

4

5 preparing for the mediation and a pre-mediation phone conference is scheduled for August 20,
6 2013.
7

3.

Plaintiffs and Defendants herein respectfully request that the Case Management

8 Conference, currently scheduled for August 23, 2013, be continued for ninety (90) days to allow
9 the parties to participate in mediation.
10

4.

There are no issues that need to be addressed by this Court at the currently

11
12 time and resources, both parties respectfully request that the Court continue the currently
13 scheduled Case Management Conference.
14 Dated: August 15, 2013

SALTZMAN & JOHNSON
LAW CORPORATION

15
By:

16
17
18 Dated: August 15, 2013

/S/
Michele Stafford
Attorneys for Plaintiffs
LEONIDOU & ROSIN
PROFESSIONAL CORPORATION

19
By:

20

/S/
Patricia Walsh
Attorneys for Defendants

21
22
23 IT IS SO ORDERED.
24

Based on the foregoing, and GOOD CAUSE APPEARING, the currently set Case
12/13/2013
Management Conference is hereby continued to _______________, and all related deadlines are
25 extended accordingly.
26
08/19/2013
27 Date: ____________________
28

_________________________________________
THE HONORABLE SAMUEL CONTI
UNITED STATES DISTRICT COURT

-2JOINT REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE; and [PROPOSED] ORDER THEREON
Case No.: C11-5116 SC
P:\CLIENTS\GLACL\United Glass & Aluminum\Pleadings\C11-5116 SC - Joint Request to Continue CMC 081413.docx