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

Filing 46

ORDER granting 45 Joint MOTION to Continue Case Management Conference. Case Management Statement due by 5/23/2014. Case Management Conference set for 5/30/2014 10:00 AM in Courtroom 1, 17th Floor, San Francisco. Signed by Judge Samuel Conti on 03/31/2014. (tmi, COURT STAFF) (Filed on 3/31/2014)

1 Michele R. Stafford, Esq. (SBN 172509)
Shivani Nanda, Esq. (SBN 253891)
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]
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Attorneys for Defendants
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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

14 NORTHERN CALIFORNIA GLAZIERS,
ARCHITECTURAL METAL AND GLASS
15 WORKERS PENSION PLAN, et al.
Plaintiffs,

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Case No.: C11-5116 SC
JOINT REQUEST FOR CONTINUANCE
OF CASE MANAGEMENT
CONFERENCE; and [PROPOSED]
ORDER THEREON

v.

18 HOSSEIN VAHEID, individually and dba
UNITED GLASS & ALUMINUM; aka T P
19 WINDOWS, INC., a California corporation,
Defendants.

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Date: Friday, April 4, 2014
Time: 10:00 a.m.
Ctrm: 1, 17th Floor
450 Golden Gate Avenue
San Francisco, California
Judge: The Honorable Samuel Conti

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Plaintiffs and Defendants both respectfully request

that

the

Case

Management

23 Conference scheduled for April 4, 2014, at 10:00 a.m., be continued for approximately thirty (30)
24 days, as follows:
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1.

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

26 Management Conference. During this time, the Parties have attempted to work together to resolve
27 several outstanding discrepancies with regard to the results of an audit taken of Defendants’
28 payroll records.

P:\CLIENTS\GLACL\United Glass & Aluminum\Pleadings\Joint Request to Continue CMC 032814.doc

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2.

On September 30, 2013, the parties participated in mediation. The case did not

2 settle at the mediation, but the parties continued settlement discussions thereafter, with the
3 assistance of the mediator, in an attempt to resolve this dispute.
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3.

Defendants made a proposal of a potential amount to be paid under a settlement

5 agreement. Plaintiffs have tentatively approved the settlement, pending a financial review by their
6 auditors. Defendants are assembling the documents for review, and have agreed to provide the
7 requested documents within 10 days.
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3.

Plaintiffs and Defendants herein respectfully request that the Case Management

9 Conference, currently scheduled for April 4, 2014, be continued for approximately thirty (30) days
10 to allow the Defendants to provide all the documents to Plaintiffs and for Plaintiffs’ auditors to
11 conduct their review.
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P:\CLIENTS\GLACL\United Glass & Aluminum\Pleadings\Joint Request to Continue CMC 032814.doc

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4.

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

2 scheduled Case Management Conference. In the interest of conserving costs as well as the Court’s
3 time and resources, both parties respectfully request that the Court continue the currently
4 scheduled Case Management Conference.
5 Dated: March 28, 2014

SALTZMAN & JOHNSON
LAW CORPORATION

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By:

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9 Dated: March 28, 2014

/S/
Shivani Nanda
Attorneys for Plaintiffs
LEONIDOU & ROSIN
PROFESSIONAL CORPORATION

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By:

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/S/
Patricia Walsh
Attorneys for Defendants

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14 IT IS SO ORDERED.

Based on the foregoing, and GOOD CAUSE APPEARING, the currently set Case
05/30/2014
Management Conference is hereby continued to _______________, and all related deadlines are
16 extended accordingly.
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03/31/2014
18 Date: ____________________
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_________________________________________
THE HONORABLE SAMUEL CONTI
UNITED STATES DISTRICT COURT

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ATTESTATION CERTIFICATE
In accord with the Northern District of California’s General Order No. 45, Section X(B), I

3 attest that concurrence in the filing of this document has been obtained from each of the other
4 signatories who are listed on the signature page.
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SALTZMAN & JOHNSON
LAW CORPORATION

Dated: March 28, 2014

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By:

/S/
Shivani Nanda
Attorneys for Plaintiffs

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