F.G. Crosthwaite et al v. Calex Engineering Company et al

Filing 32

ORDER GRANTING 31 Joint MOTION to Continue Case Management Conference. Case Management Statement due by 7/18/2014. Initial Case Management Conference set for 7/25/2014 11:00 AM in Courtroom 5, 2nd Floor, Oakland. Signed by Judge Jeffrey S. White on 3/12/14. (jjoS, COURT STAFF) (Filed on 3/12/2014)

Case3:13-cv-01718-JSW Document31 Filed03/07/14 Page1 of 3

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Michele R. Stafford, Esq. (SBN 172509)
Shivani Nanda, Esq. (SBN 253891)
SALTZMAN & JOHNSON LAW CORPORATION
44 Montgomery Street, Suite 2110
San Francisco, CA 94104
[phone]
[phone] – Facsimile
[e-mail]
[e-mail]

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Attorneys for Plaintiffs

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David Napper, Esq.
Chapman Glucksman Dean Roeb & Barger
11900 W. Olympic Blvd., Suite 800
Los Angeles, CA 90064
[phone]
[phone] – Facsimile
[e-mail]
Attorneys for Defendants

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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F.G. CROSTHWAITE, et al.,

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Plaintiffs,
v.

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Case No.: C13-1718 JSW

CALEX ENGINEERING COMPANY, a
California Partnership; CALEX
ENGINEERING, INC., a California
Corporation; EARTHWORK SYSTEMS INC.,
a California Corporation; and DOES 1 through
10, inclusive;

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Defendants.

JOINT REQUEST TO CONTINUE
CASE MANAGEMENT CONFERENCE;
[PROPOSED] ORDER THEREON
Date:
Time:
Location:

March 21, 2014
1:30 p.m.
450 Golden Gate Avenue
San Francisco, CA
Courtroom: 11
Judge:
Jeffrey S. White

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Plaintiffs and Defendants jointly request that the Case Management Conference, currently
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on calendar for March 21, 2014, be continued for 120 - 180 days.
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1.

Plaintiffs F.G. Crosthwaite, et al., and named Defendants Calex Engineering

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Company, a California Partnership; Calex Engineering, Inc., a California Corporation; Earthwork
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Systems Inc., a California Corporation, through their attorneys, have reached a conditional
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-1JOINT REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE
CASE NO.: C13-01718 JSW
P:\CLIENTS\OE3CL\CALEX ENGINEERING CO\PLEADINGS\CV13-1718 JSW JOINT REQUEST TO CONTINUE CMC 030714.DOCX

Case3:13-cv-01718-JSW Document31 Filed03/07/14 Page2 of 3

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settlement. Said parties have executed a Stipulation for Entry of Judgment Upon Default,

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(“Stipulation”) which provides a payment plan to allow Defendants to satisfy their debt to the

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Plaintiff Trust Funds by making monthly payments. Said Stipulation allows Plaintiffs to obtain

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judgment against the named Defendants and a personal guarantor in the event that Defendants fail

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to timely cure any default thereunder. A copy of the signed Stipulation is attached hereto as Exhibit

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A.

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2.

Defendants have made six of twelve stipulated payments as required, and are

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otherwise in compliance with the Stipulation. The parties anticipate filing a notice of dismissal

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upon bank clearance of Defendant’s twelve and final installment payment.

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3.

In the interest of conserving costs as well as the Court’s time and resources,

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Plaintiffs and Defendants respectfully request that the Case Management Conference, currently

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scheduled for March 21, 2014, be continued for 120 -180 days.

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Dated: March 7, 2014

SALTZMAN & JOHNSON
LAW CORPORATION

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/S/
Shivani Nanda, Esq.
Attorneys for Plaintiffs

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Dated: March 7, 2014

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CHAPMAN GLUCKSMAN DEAN ROEB
& BARGER

/S/
David Napper, Esq.
Attorneys for Defendants

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-2JOINT REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE
CASE NO.: C13-01718 JSW
P:\CLIENTS\OE3CL\CALEX ENGINEERING CO\PLEADINGS\CV13-1718 JSW JOINT REQUEST TO CONTINUE CMC 030714.DOCX

Case3:13-cv-01718-JSW Document31 Filed03/07/14 Page3 of 3

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IT IS SO ORDERED.
July 25
The currently set Case Management Conference is hereby continued to ___________,
The Court VACATES the pretrial conference and trial dates and will reset these
11:00 a.m.
2014 at _________, and all previously set deadlines and dates related to this case are continued
dates, if necessary, at the case management conference.
accordingly.
March 12, 2014
Date: ____________________
THE HONORABLE JEFFREY S. WHITE
UNITED STATES DISTRICT COURT JUDGE

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-3JOINT REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE
CASE NO.: C13-01718 JSW
P:\CLIENTS\OE3CL\CALEX ENGINEERING CO\PLEADINGS\CV13-1718 JSW JOINT REQUEST TO CONTINUE CMC 030714.DOCX