District Council 16 Northern California Health and Welfare Trust Fund, and its Joint Board of Trustees et al v. Brown

Filing 10

STIPULATION AND ORDER Case Management Statement due by 3/10/2016. Case Management Conference set for 3/17/2016 11:00 AM in Courtroom C, 15th Floor, San Francisco.. Signed by Judge Laurel Beeler on 2/5/16. (lrcS, COURT STAFF) (Filed on 2/5/2016)

Case 3:15-cv-05209-LB Document 9 Filed 02/04/16 Page 1 of 2

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Michele R. Stafford, Esq. (SBN 172509)
Erica J. Russell, Esq. (SBN 274494)
SALTZMAN & JOHNSON LAW CORPORATION
44 Montgomery Street, Suite 2110
San Francisco, California 94104
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Plaintiffs, District Council 16
Northern California Health and Welfare
Trust Fund, et al.

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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 HEALTH AND WELFARE
TRUST FUND, et al.

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PLAINTIFFS’ REQUEST TO CONTINUE
CASE MANAGEMENT CONFERENCE;
xxxxxxxxxx ORDER THEREON
[PROPOSED]

Plaintiffs,

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Case No. C15-5209 LB

v.

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ROBERT BROWN, individually and dba
ARTISTIC DRYWALL SYSTEMS, a California
sole proprietorship,
Defendant.

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Plaintiffs respectfully request that the Case Management Conference, currently on calendar for

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February 11, 2016, be continued for approximately thirty (30) days. Good cause exists for the granting

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of the continuance as follows:

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1.

As the Court’s records will reflect, this action was filed on November 13, 2015 (Dkt. #1).

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Defendant has not yet been served with the Complaint as the parties are working toward an informal

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resolution of this matter, and Plaintiffs anticipate filing an Acknowledgement of Receipt of Service of

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Process executed by Defendant.

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2.

Defendant requested a payment plan for the amounts owed to Plaintiffs. Plaintiffs sent

Defendant a proposed Judgment Pursuant to Stipulation, which allows Defendant to make monthly

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1
PLAINTIFFS’ REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
THEREON
Case No. C15-5209 LB
P:\CLIENTS\PATCL\Artistic Drywall Systems\Pleadings\Request to Continue CMC 020316.docx

Case 3:15-cv-05209-LB Document 9 Filed 02/04/16 Page 2 of 2

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payments to Plaintiffs to satisfy its debt. Plaintiffs are awaiting receipt of the executed Judgment

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Pursuant to Stipulation from Defendant and, upon receipt, will file said document with the Court.

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3.

As the parties have agreed to resolve this matter informally, there are no issues that need

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to be addressed by the parties at the currently scheduled Case Management Conference. In the interest of

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conserving costs, as well as the Court’s time and resources, Plaintiffs respectfully request that the

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upcoming Case Management Conference be continued for approximately thirty (30) days to allow

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sufficient time for Defendant to review and execute the Judgment Pursuant to Stipulation and for

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Plaintiffs to file said document with the Court.

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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: February 4, 2016

SALTZMAN & JOHNSON LAW CORPORATION

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By:

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/S/
Erica J. Russell
Attorney for Plaintiffs

IT IS SO ORDERED.
The

currently

set

Case

Management

Conference

is

hereby

continued

to

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March 17, 2016
11:00 am
__________________________ at __________________, and all previously set deadlines and dates

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related to this case are continued accordingly.

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February 5
DATED: _________, 2016

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xxxxxxxxxxxxx
UNITED STATES DISTRICT COURT JUDGE
MAGISTRATE

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PLAINTIFFS’ REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
THEREON
Case No. C15-5209 LB
P:\CLIENTS\PATCL\Artistic Drywall Systems\Pleadings\Request to Continue CMC 020316.docx