Bay Area Painters and Tapers Pension Trust Fund et al v. Reyes Drywall, Inc.
Filing
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STIPULATION AND ORDER re 20 STIPULATION WITH PROPOSED ORDER - STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION COMPLETION DEADLINE BY SIXTY DAYS filed by District Council 16 Northern California Apprentice and Journeyman Trainin g Trust Fund, Bay Area Painters and Tapers Pension Trust Fund, James Williams, Chris Christopherson, Les Proteau, Marion Bourboulis, John Maggiore, District Council 16 Northern California Health and Welfare Trust Fund, District Council 16 of the International Union of Painters and Allied Trades, Charles Del Monte, I.U.P.A.T. Union and Industry National Pension Fund Case Management Statement due by 1/9/2014. Further Case Management Conference set for 1/16/2014 10:30 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 10/21/13. (bpf, COURT STAFF) (Filed on 10/21/2013)
1 Michele R. Stafford, Esq. (SBN 172509)
Shivani Nanda (SBN 253891)
2 SALTZMAN & JOHNSON LAW CORPORATION
44 Montgomery Street, Suite 2110
3 San Francisco, CA 94104
Telephone: (415) 882-7900
4 Facsimile: (415) 882-9287
mstafford@sjlawcorp.com
5 snanda@sjlawcorp.com
6 Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
10 BAY AREA PAINTERS AND TAPERS
PENSION TRUST FUND, et al.,
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Plaintiffs,
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v.
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REYES DRYWALL, INC. and DOES 1-10,
14 inclusive;
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Case No.: C13-1752 EMC
STIPULATION AND [PROPOSED] ORDER
TO EXTEND MEDIATION COMPLETION
DEADLINE BY SIXTY DAYS
Defendant.
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The parties to this action hereby respectfully request and stipulate to extend the deadline to
18 hold the mediation session by 60 days. Good cause exists for the continuance, as follows:
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1.
On July 15, 2013, the Court ordered the parties to participate in mediation within
20 the presumptive deadline of ninety days. (Docket No. 15).
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2.
On August 12, 2013, ADR Clerk, Richard Wieking notified the parties that
22 Katherine Ritchey was the assigned mediator for this case. (Docket No. 19).
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3.
On August 19, 2013, the parties participated in a pre-mediation conference with
24 Ms. Ritchey and scheduled the mediation for October 14, 2013.
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4.
The parties are currently engaged in settlement discussions and are close to
26 resolving this matter. To avoid the time and expense of preparing for and attending mediation, the
27 parties agreed to cancel the October 14, 2013 mediation and continue informal settlement
28 discussions.
-1STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION COMPLETION DEADLINE
CASE NO.: C13-1752 EMC
P:\CLIENTS\PATCL\Reyes Drywall Inc. (Patterson) 2 REYESD2\Pleadings\C13-1752 EMC Stipulation and Proposed Order to Extend Mediation Deadline 101513.doc
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5.
If the matter does not resolve informally, the parties have agreed to reschedule a
2 mediation session with Ms. Ritchey.
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6.
The parties therefore request that the Court extend the deadline to hold the
4 mediation session by 60 days.
5 Dated: October 15, 2013
SALTZMAN & JOHNSON
LAW CORPORATION
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By:
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/S/
Shivani Nanda
Attorneys for Plaintiffs
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10 Dated: October 15, 2013
LAW OFFICE OF
GEORGE R. GORE
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By:
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/S/
George R. Gore
Attorney for Defendant
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IT IS SO ORDERED.
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The deadline to hold the mediation session is extended by sixty days to
12/15
16 _______________________, 2013. The CMC originally set for 11/7/13 is reset for
ST
RT
U
O
S DI CHEN
THE HONORABLE EDWARD M. RICT
TE COURT C
UNITED STATES DISTRICT
TA
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RT
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dwa
Judge E
ER
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A
H
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hen
rd M. C
NO
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ERED
O ORD D
IT IS S
DIFIE
AS MO
R NIA
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LI
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UNIT
ED
S
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1/16/14 at 10:30 a.m. An updated CMC statement
shall _________________________________________
be filed by 1/9/14.
FO
10/21/13
17 Date: ____________________
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F
D IS T IC T O
R
C
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-2STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION COMPLETION DEADLINE
CASE NO.: C13-1752 EMC
P:\CLIENTS\PATCL\Reyes Drywall Inc. (Patterson) 2 REYESD2\Pleadings\C13-1752 EMC Stipulation and Proposed Order to Extend Mediation Deadline 101513.doc
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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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Dated: October 15, 2013
SALTZMAN & JOHNSON
LAW CORPORATION
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By:
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/S/
SHIVANI NANDA
Attorneys for Plaintiffs
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-1ATTESTATION CERTIFICATE RE: STIPULATION AND [PROPOSED] ORDER TO EXTEND
MEDIATION COMPLETION DEADLINE
CASE NO.: C13-1752 EMC
P:\CLIENTS\PATCL\Reyes Drywall Inc. (Patterson) 2 REYESD2\Pleadings\C13-1752 EMC Stipulation and Proposed Order to Extend Mediation Deadline 101513.doc
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