District Council 16 Northern California Journeyman and Apprentice Training Trust Fund et al v. Lineation Markings Corporation et al
Filing
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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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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
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Attorneys for Plaintiffs,
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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DISTRICT COUNCIL 16 NORTHERN
CALIFORNIA JOURNEYMAN AND
APPRENTICE TRAINING TRUST FUND, et al.,
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PLAINTIFFS’ REQUEST TO CONTINUE
CASE MANAGEMENT CONFERENCE;
[PROPOSED] ORDER THEREON
Plaintiffs,
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Case No. C15-1823 TEH
v.
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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
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Defendants.
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Plaintiffs respectfully request that the Case Management Conference, currently on calendar for
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January 4, 2016, be continued for approximately thirty (30) days. Good cause exists for the granting of
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the continuance, as follows:
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1.
As the Court’s records will reflect, this action was filed on April 22, 2015. Defendants
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were served on June 18, 2015. Plaintiffs filed Proofs of Service of Summons with the Court on June 22,
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2015 (Dkts. #11 & 12). Defendants failed to plead or otherwise respond to the lawsuit, and the Clerk
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entered default as to Defendants on July 14, 2015 (Dkt. #15). Defendants were duly served with a copy
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of the Clerk’s Notice of Default Entry, and a Proof of Service of same was filed with the Court on July
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14, 2015 (Dkt. #16).
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2.
As previously mentioned, Plaintiffs have attempted to contact Defendants numerous
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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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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.
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DATED: December 18, 2015
SALTZMAN & JOHNSON LAW CORPORATION
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By:
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/S/
Adrian L. Canzoneri
Attorneys for Plaintiffs, District Council 16 Northern
California Health and Welfare Trust Fund, et al.
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IT IS SO ORDERED.
The
currently
set
Case
Management
Conference
is
hereby
continued
to
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February 8, 2016
1:30 PM
__________________________ at __________________, and all previously set deadlines and dates
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related to this case are continued accordingly.
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DATED: December ______, 2015
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UNITED STATES DISTRICT JUDGE
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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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