Service Employees International Union National Industry Pension Fund et al v. Employee Equity Administration, Inc., et al

Filing 46

STIPULATION AND ORDER re 44 STIPULATION WITH PROPOSED ORDER re 32 Clerk's Notice filed by SOL Healthcare, LLC: Case Management Statement due by 8/21/2013. Initial Case Management Conference set for 9/4/2013 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on June 20, 2013. (wsn, COURT STAFF) (Filed on 6/20/2013)

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DAVID R. JOHANSON (SBN 164141)
[e-mail]
JACKSON LEWIS LLP
725 South Figueroa Street, Suite 2500
Los Angeles, California 90017-5408
Telephone: [phone]
Facsimile: [phone]
CHARLES F. SEEMANN III (admitted pro hac vice)
[e-mail]
JACKSON LEWIS LLP
650 Poydras Street, Suite 1900
New Orleans, Louisiana 70130
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants SOL HEALTHCARE, LLC;
SOLNUS TWO, LLC; SOLNUS THREE, LLC;
SOLNUS FOUR, LLC; SOLNUS EIGHT, LLC; SOL
MAJER; and SCHLOMO RECHNITZ

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SERVICE EMPLOYEES INTERNATIONAL
UNION NATIONAL INDUSTRY PENSION
FUND; STEPHEN ABRECHT, Trustee, ROD
BASHIR, Trustee; KEVIN J. DOYLE, Trustee;
MYRIAM ESCAMILLA, Trustee; STEVEN W.
FORD, Trustee; EDWARD J. MANKO,
Trustee; FRANK A. MAXSON, Trustee; JOHN
J SHERIDAN, Trustee; LARRY T. SMITH,
Trustee; DAVID STILWELL, Trustee,
Plaintiff,

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vs.
EMPLOYEE EQUITY ADMINISTRATION,
INC., a California corporation, d/b/a Westline
Medical Management, et al.
Defendants.

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Case No.: CV 12 4494 JST

JOINT STIPULATION TO CONTINUE
CASE MANAGEMENT
CONFERENCE; and [PROPOSED] ORDER
Date:
Time:
Judge:
Location:

July 3, 2013
2:00 p.m.
Hon. Jon S. Tigar
Courtroom 9, 19th Floor
450 Golden Gate Ave.
San Francisco, California

First Amended
Complaint filed: May 16, 2013
Trial Date:
June 30, 2014

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CASE NO.: CV 12 4494 JST

JOINT STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE

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Plaintiffs Service Employees International Union National Industry Pension Fund, Stephen

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Abrecht, Rod Bashir, Kevin J. Doyle, Myriam Escamilla, Steven W. Ford, Edward J. Manko, Frank A.

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Maxson, John J. Sheridan, Larry T. Smith, and David Stillwell (collectively, the “Plaintiffs”), the

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Westline Defendants (which includes Defendants Employee Equity Administration, Inc., Oak Facility,

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Inc., RCC Facility, Inc., RV Facility, Inc., SP Facility, Inc., SJ Facility, Inc., Pleasant View

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Convalescent Hospital, Inc., Willow Street Properties, LLC, Northgate Center, Inc., Jaline, Inc., Skilled

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Logic Systems, Jack Easterday, and Deline Davis), and the Solnus Defendants (which include Sol

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Healthcare, LLC, SOLNUS TWO, LLC, SOLNUS THREE, LLC, SOLNUS FOUR, LLC, SOLNUS

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EIGHT, LLC, Sol Majer, and Schlomo Rechnitz), (collectively, the “Parties”), hereby stipulate as

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follows:

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1.

A Case Management Conference is currently scheduled for July 3, 2013, per Docket No.

2.

On June 18, 2013, counsel for the Solnus Defendants became aware that he no longer was

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available on July 3, 2013, for the Case Management Conference due to personal reasons involving

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ongoing medical care for a family member.

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3.

The Parties jointly request that the Case Management Conference be continued to the next

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available date for the Parties, which is August 28, 2013, or as soon thereafter when the court is next

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available.

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4.

The Parties request that the Joint Case Management Conference Statement be submitted to

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the Court ten court days before August 28, 2013.

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IT IS SO STIPULATED.

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Date: June 19, 2013

JACKSON LEWIS LLP

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By:

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/S/
DAVID R. JOHANSON

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Attorneys for Defendants Sol Healthcare LLC,
Solnus Two, LLC; Solnus Three, LLC;
Solnus Four, LLC; Solnus Eight, LLC; Sol Majer; and
Shlomo Rechnitz

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CASE NO.: CV 12 4494 JST

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JOINT STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE

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Date: June 19, 2013

SALTZMAN & JOHNSON LAW CORPORATION

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By:

/S/

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ANNE M. BEVINGTON

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Attorneys for Plaintiffs

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Date: June ___, 2013

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By:

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SHELLEY R. BUCHANAN

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Attorneys for Defendants Employee Equity
Administration, Inc., et al.

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[PROPOSED] ORDER

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The terms of the Stipulation herein above are hereby approved and adopted.
The Case Management Conference currently scheduled for July 3, 2013, is hereby continued to
September 4
__________________, 2013, at 2:00 p.m. The Parties shall file with the Court a Joint Statement ten (10)
court days prior to that date. IT IS SO ORDERED.

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June 20
__________________, 2013
District Court Judge Jon S. Tigar

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CASE NO.: CV 12 4494 JST

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JOINT STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE