Board of Trustees of the Resilient Floor Covering Pension Fund et al v. Front Range Finishes, LLC

Filing 19

STIPULATION AND ORDER re 18 STIPULATION WITH PROPOSED ORDER to Continue CMC filed by Resilient Floor Covering Pension Fund, Board of Trustees of the Resilient Floor Covering Pension Fund. Case Management Statement due by 4/13/2016. Initial Case Management Conference set for 4/20/2016 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on March 17, 2016. (wsn, COURT STAFF) (Filed on 3/17/2016)

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George M. Kraw (California Bar No. 71551)
Donna L. Kirchner (California Bar No. 138320)
Katherine McDonough (California Bar No. 241426)
Kraw and Kraw Law Group
605 Ellis Street, Suite 200
Mountain View, California 94043
Telephone: [phone]
Facsimile: 650-314-7899
[e-mail]
[e-mail]
[e-mail]

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Counsel for Plaintiffs:
Board of Trustees of the Resilient Floor Covering
Pension Trust Fund, and the Resilient Floor
Covering Pension Trust Fund
UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
BOARD OF TRUSTEES OF THE RESILIENT)
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FLOOR COVERING PENSION TRUST
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FUND, ET AL.,
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Plaintiffs,
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v.
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FRONT RANGE FINISHES, LLC,
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Defendant.
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Case No.: 3:15-cv-05528-JST
JOINT STIPULATION AND
[PROPOSED] ORDER CONTINUING
THE CASES MANAGEMENT
CONFERENCE

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Plaintiffs, BOARD OF TRUSTEES OF THE RESILIENT FLOOR COVERING PENSION TRUST

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FUND, and the RESILIENT FLOOR COVERING PENSION TRUST FUND (herein after jointly

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“Plaintiffs”) and Defendant, FRONT RANGE FINISHES, LLC (“Defendant”), stipulate and

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respectfully request this Court to continue the Case Management Conference currently set for

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March 30, 2016 at 2:00 p.m. The parties propose to continue the Case Management Conference

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to Wednesday, April 20, 2016 at 2:00 p.m., or as soon thereafter as this Court is available. The
STIPULATION AND [PROPOSED ORDER] CONTINUING - 1
CASE NO.: 3:15-CV-05528-JST

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above named parties previously stipulated to extend the deadline for the Defendant to file an

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Answer to April 9, 2016 (See, ECF No. 17). Accordingly, the parties have requested the first

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available Court Date after the April 9th deadline. The reason for this request is that the parties are

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currently involved in ongoing settlement negotiations and believe the extension will allow the

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Parties to focus on attempting to resolve their dispute.

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Dated: March 16, 2016

KRAW LAW GROUP, APC

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/s/ Donna L. Kirchner
Donna L. Kirchner (SBN 138320)
Attorneys for Plaintiffs, Board of Trustees
of the Resilient Floor Covering Pension
Trust Fund, and the Resilient Floor
Covering Pension Trust Fund

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Dated: March 16, 2016

TRUCKER HUSS, APC

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/s/ Sean T. Strauss
Robert F. Schwartz
Sean T. Strauss
Attorneys for Defendant, Front Range
Finishes LLC

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ORDER

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Pursuant to the Stipulation of the Parties set forth above, the Case Management Conference set for

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March 30, 2016 shall be continued to April 20, 2016 at 2:00 p.m. and the Joint Case Management

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Statement shall be filed no later than one week prior to the scheduled Case Management

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Conference. IT IS SO ORDERED.

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Dated: ________________
March 17, 2016

_________________________________
HONORABLE JON S. TIGAR
United Stated District Court Judge

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STIPULATION AND [PROPOSED ORDER] CONTINUING - 2
CASE NO.: 3:15-CV-05528-JST