District Council 16 Northern California Journeyman and Apprentice Training Trust Fund et al v. Lineation Markings Corporation et al

Filing 25

STIPULATION AND ORDER to Continue Case Management Conference. Case Management Statement due by 2/1/2016. Initial Case Management Conference set for 2/8/2016 01:30 PM in Courtroom 12, 19th Floor, San Francisco. Signed by Judge Thelton E. Henderson on 12/22/2015. (tmiS, COURT STAFF) (Filed on 12/22/2015)

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1 5 Michele R. Stafford, Esq. (SBN 172509) Adrian L. Canzoneri, Esq. (SBN 265168) SALTZMAN & JOHNSON LAW CORPORATION 44 Montgomery Street, Suite 2110 San Francisco, California 94104 Telephone: (415) 882-7900 Facsimile: (415) 882-9287 mstafford@sjlawcorp.com acanzoneri@sjlawcorp.com 6 Attorneys for Plaintiffs, 2 3 4 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 11 12 DISTRICT COUNCIL 16 NORTHERN CALIFORNIA JOURNEYMAN AND APPRENTICE TRAINING TRUST FUND, et al., 13 PLAINTIFFS’ REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER THEREON Plaintiffs, 14 Case No. C15-1823 TEH v. 15 16 Date: Time: Location: LINEATION MARKINGS CORPORATION, a California corporation; LUKE MIDDLETON, an individual, Courtroom: Judge: January 4, 2016 1:30 p.m. 450 Golden Gate Avenue San Francisco, CA 94102 12 – 19th Floor Hon. Thelton E. Henderson 17 Defendants. 18 Plaintiffs respectfully request that the Case Management Conference, currently on calendar for 19 January 4, 2016, be continued for approximately thirty (30) days. Good cause exists for the granting of 20 the continuance, as follows: 21 1. As the Court’s records will reflect, this action was filed on April 22, 2015. Defendants 22 were served on June 18, 2015. Plaintiffs filed Proofs of Service of Summons with the Court on June 22, 23 2015 (Dkts. #11 & 12). Defendants failed to plead or otherwise respond to the lawsuit, and the Clerk 24 entered default as to Defendants on July 14, 2015 (Dkt. #15). Defendants were duly served with a copy 25 of the Clerk’s Notice of Default Entry, and a Proof of Service of same was filed with the Court on July 26 14, 2015 (Dkt. #16). 27 2. As previously mentioned, Plaintiffs have attempted to contact Defendants numerous 28 1 PLAINTIFFS’ REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE Case No. C15-1823 TEH P:\CLIENTS\PATCL\Lineation Markings Corp\Pleadings\C15-1823 TEH Plaintiffs Request to Continue CMC 121815.docx 1 2 3 4 5 6 7 8 9 10 11 12 times in an effort to resolve the matter without the need for litigation. Plaintiffs have been unsuccessful to date. 3. Plaintiffs are finalizing their Motion for Default Judgment, including obtaining the necessary declarations and documents in support thereof. Plaintiffs intend to file their Motion for Default Judgment by January 29, 2016. 4. There are no issues that need to be addressed by the parties at the currently scheduled Case Management Conference. In the interest of conserving costs, as well as the Court’s time and resources, Plaintiffs respectfully request that the Court continue the currently scheduled Case Management Conference for approximately thirty (30) days, to allow for sufficient time for Plaintiffs to finalize and file a Motion for Default Judgment against Defendants. I declare under penalty of perjury that I am the attorney for the Plaintiffs in the above entitled action, and that the foregoing is true of my own knowledge. 13 14 DATED: December 18, 2015 SALTZMAN & JOHNSON LAW CORPORATION 15 16 By: 17 /S/ Adrian L. Canzoneri Attorneys for Plaintiffs, District Council 16 Northern California Health and Welfare Trust Fund, et al. 18 19 20 IT IS SO ORDERED. The currently set Case Management Conference is hereby continued to 21 February 8, 2016 1:30 PM __________________________ at __________________, and all previously set deadlines and dates 22 related to this case are continued accordingly. 23 24 22 DATED: December ______, 2015 25 26 UNITED STATES DISTRICT JUDGE 27 28 2 PLAINTIFFS’ REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE Case No. C15-1823 TEH P:\CLIENTS\PATCL\Lineation Markings Corp\Pleadings\C15-1823 TEH Plaintiffs Request to Continue CMC 121815.docx

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