Bay Area Painters and Tapers Pension Trust Fund et al v. Reyes Drywall, Inc.

Filing 27

STIPULATION AND ORDER re 26 Joint MOTION to Continue Case Management Conference filed by District Council 16 Northern California Apprentice and Journeyman Training 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 4/14/2014. Further Case Management Conference set for 4/24/2014 10:30 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 2/24/14. (bpf, COURT STAFF) (Filed on 2/25/2014)

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: [phone]
4 Facsimile: [phone]
[e-mail]
5 [e-mail]
6 Attorneys for Plaintiffs
7
8

UNITED STATES DISTRICT COURT

9

FOR THE NORTHERN DISTRICT OF CALIFORNIA

10 BAY AREA PAINTERS AND TAPERS
PENSION TRUST FUND, et al.,
11
Plaintiffs,
12
v.
13
REYES DRYWALL, INC. and DOES 1-10,
14 inclusive;

Case No.: C13-1752 EMC

15

Courtroom:
Judge:

Defendant.

16
17

1.

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

February 27, 2014
10:30 a.m.
450 Golden Gate Ave.
San Francisco
7, 19th Floor
Honorable Edward M. Chen

The parties to the above-entitled action jointly request that the Case Management

18 Conference, currently set for February 27, 2014, be continued for approximately 45 - 60 days.
19 Good cause exists for the granting of the continuance, as follows:
20

2.

Defendant has made a settlement offer, which has been considered and approved

21 by Plaintiffs’ Board of Trustees.
22

3.

Plaintiffs have provided Defendant a proposed Stipulated Judgment, which is under

23 review and consideration by Defendant and its counsel.
24

4.

Accordingly, the parties respectfully request that the Case Management

25 Conference, currently scheduled for February 27, 2014, be continued for approximately 45 - 60 to
26 allow time to finalize and file the Stipulated Judgment with the Court, without the necessity of
27 further litigation.
28
-1JOINT REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE
Case No.: C13-1752 EMC
P:\CLIENTS\PATCL\Reyes Drywall Inc. (Patterson) 2 REYESD2\Pleadings\C13-1752 EMC Joint Request to Continue CMC 022014.doc

1

5.

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

2 scheduled Case Management Conference. In the interest of conserving costs as well as the Court’s
3 time and resources, the parties respectfully request that the Court continue the currently scheduled
4 Case Management Conference.
5 Dated: February 20, 2014

SALTZMAN & JOHNSON
LAW CORPORATION

6
By:

7
8

/S/
Shivani Nanda
Attorneys for Plaintiffs

9
10 Dated: February 20, 2014

LAW OFFICE OF
GEORGE R. GORE

11
By:

12
13

/S/
George R. Gore
Attorney for Defendant

14
ORDER
15
BASED ON THE FOREGOING and GOOD CAUSE APPEARING, the Case
16 Management Conference currently set for February 27, 2014, is continued to _____________ 2014
April 24, at
______ ___.m.
10:30 a
17

25

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24

RT

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DIFI
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_________________________________________
D
THE HONORABLE EDWARD M. CHEN
RDERE
UNITED
IS SO O STATES DISTRICT COURT
IT
ED

A

21

UNIT
ED

20

2/25/14
Date: ____________________

S DISTRICT
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19

S

18 IT IS SO ORDERED.

N

F
D IS T IC T O
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C

26
27
28
-2JOINT REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE
Case No.: C13-1752 EMC
P:\CLIENTS\PATCL\Reyes Drywall Inc. (Patterson) 2 REYESD2\Pleadings\C13-1752 EMC Joint Request to Continue CMC 022014.doc