Pension Plan for Pension Trust Fund for Operating Engineers v. GW Consulting Civil Engineers

Filing 19

ORDER re: 18 Request to Continue Case Management Conference. Case Management Statement due by 12/4/2014. Case Management Conference set for 12/11/2014 10:00 AM. Signed by Judge Maria-Elena James on 10/10/2014. (cdnS, COURT STAFF) (Filed on 10/10/2014)

1 SHAAMINI A. BABU (SBN 230704)
ANJULI M. CARGAIN (SBN 270546)
2 SALTZMAN & JOHNSON LAW CORPORATION
44 Montgomery Street, Suite 2110
3 San Francisco, CA 94104
[phone]
4 [phone] – Facsimile
[e-mail]
5 [e-mail]
6 Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

10 PENSION PLAN FOR PENSION TRUST
FUND FOR OPERATING ENGINEERS, et al.,
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Plaintiffs,
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vs.
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GW CONSULTING CIVIL ENGINEERS,
14 INC., et al.,
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Defendants.

Case No.: CV 14-3388 MEJ
REQUEST TO CONTINUE CASE
MANAGEMENT CONFERENCE;
[PROPOSED] ORDER
Date:
Time:
Location:

October 23, 2014
10:00 a.m.
450 Golden Gate Avenue
San Francisco, California
Courtroom: B, 15th Floor
Judge:
Honorable Maria-Elena James

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Plaintiffs hereby submit this Request to Continue the Case Management Conference

18 currently scheduled for October 23, 2014 at 10:00 a.m.
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A Complaint was filed by Plaintiffs in this matter on July 25, 2014. Docket 1. As of the

20 date of the filing of this request, Defendant GW Consulting Civil Engineers, Inc. (“GW, Inc.”) has
21 failed to answer the Complaint or file a responsive pleading. As such, Plaintiffs requested entry of
22 default against GW, Inc. on September 16, 2014. Docket 15. The clerk entered default as to GW,
23 Inc. on September 19, 2014. Docket 16.
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Plaintiffs intend to file a Motion for Default Judgment against GW, Inc. by October 24,

25 2014. Accordingly, Plaintiffs respectfully request that the Case Management Conference
26 scheduled for October 23, 2014, be continued to December 11, 2014, the date on which the
27 hearing on the Motion for Default Judgment will be noticed. The request is made in the interest of
28 conserving costs, as well as the Court’s time and resources.

P:\CLIENTS\OE3WL\CASES\GW Consulting Civil Engineers Inc\CMC\Request to Continue CMC 10-9-14.doc

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REQUEST TO CONTINUE CMC
Case No.: CV 14-3388 MEJ

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I declare under penalty of perjury that I am the attorney for the Plaintiffs in the above

2 entitled action, and that the foregoing is true of my own knowledge.
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4 Dated: October 9, 2014

SALTZMAN & JOHNSON LAW CORPORATION

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By:

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/s/
Shaamini A. Babu
Attorney for Plaintiffs
Pension Plan for Pension Trust Fund for Operating
Engineers, et al.

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ORDER

12 IT IS SO ORDERED.
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Based on the foregoing, and GOOD CAUSE appearing, the Case Management Conference

14 currently scheduled for October 23, 2014, at 10:00 a.m. is hereby continued to December 11, 2014
15 at 10:00 a.m. or such other date when the hearing on Plaintiffs’ Motion for Default Judgment will
16 be held. All related deadlines are extended accordingly.
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October 10, 2014
18 Dated: _________________
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_______________________________________
THE HONORABLE MARIA-ELENA JAMES
UNITED STATES MAGISTRATE JUDGE

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P:\CLIENTS\OE3WL\CASES\GW Consulting Civil Engineers Inc\CMC\Request to Continue CMC 10-9-14.doc

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REQUEST TO CONTINUE CMC
Case No.: CV 14-3388 MEJ

PROOF OF SERVICE

1
2 I, the undersigned, declare:

I am employed in the County of San Francisco, State of California. I am over the age of

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4 eighteen and not a party to this action. My business address is 44 Montgomery Street, Suite 2110,
5 San Francisco, California 94104.
On October 9, 2014, I served the following documents on the parties to this action in the

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7 manner described below:
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REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE;
[PROPOSED] ORDER

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MAIL by placing the envelope for collection and mailing on the date shown above
following our ordinary business practices. Being readily familiar with this business’s
practice for collecting and processing correspondence for mailing, on the same day that
correspondence is placed for collection and mailing, it is deposited in the ordinary course
of business with the United States Postal Service in a sealed enveloped with postage fully
prepaid.

GW Consulting Civil Engineers, Inc.,
a California Corporation
c/o Craig Hashimoto
1903 Balboa Drive
Roseville, CA 95661

GW Consulting Civil Engineers, Inc.,
a California Corporation
c/o Renee Parker
6310 Crimson Ridge Drive
Rocklin, CA 95765

GW Consulting Civil Engineers, Inc.,
a California Corporation
c/o Karen Wiese
4913 Olympia Court
Carmichael, CA 95608

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I declare under penalty of perjury that the foregoing is true and correct and that this

th
22 declaration was executed on this 9 day of October, 2014, at San Francisco, California.

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________________/s/______________
Catherine Jemera

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PROOF OF SERVICE
Case No.: CV 14-3388 MEJ
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