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

Filing 49

STIPULATION AND ORDER re 47 STIPULATION WITH PROPOSED ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE. Case Management Statement due by 10/23/2013. Initial Case Management Conference set for 11/6/2013 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on August 22, 2013. (wsn, COURT STAFF) (Filed on 8/22/2013)

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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 SHLOMO 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:

September 4, 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 Shlomo 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 September 4, 2013, pursuant

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to Docket No. 46.

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2.

This Court previously ordered Mediation to occur pursuant to Docket No. 38. Such

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Mediation is scheduled to occur on September 25, 2013, at this Court’s ADR Unit in San Francisco,

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California. The Parties believe that it would be more efficient and cost effective to conduct the initial

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Case Management Conference with Judge Tigar after the Mediation occurs.

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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 after the Mediation, which is October 9, 2013, or as soon thereafter (except

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for October 16, October 23, or October 30, when the parties are unavailable) when this Court is next

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available. Please note that the parties are also not available on October 3, 2013.

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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 the new Case Management Conference date.

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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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IT IS SO STIPULATED.

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Date: August 21, 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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Date: August 21, 2013

SALTZMAN & JOHNSON LAW CORPORATION

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By:

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________________________

Kimberly A. Hancock

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Attorneys for Plaintiffs

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/S/

Date: August 21, 2013

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By:

/S/

________________________

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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 September 4, 2013, is hereby continued
November 6, 2013
to October 9, 2013, at 2:00 p.m. The Parties shall file with this Court a Joint Statement ten (10) court
days prior to that date. IT IS SO ORDERED.

August 22
__________________, 2013
District Court Judge Jon S. Tigar

CASE NO.: CV 12 4494 JST

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JOINT STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE