Board of Trustees, in their capacities as Trustees of the Laborers Health and Welfare Trust Fund For Northern California et al v. Titan DVBE Incorporated

Filing 21

ORDER Continuing Case Management Conference. Case Management Statement due by 11/13/2013. Case Management Conference set for 11/20/2013 01:30 PM. Signed by Magistrate Judge Donna M. Ryu on 08/16/2013. (dmrlc1, COURT STAFF) (Filed on 8/16/2013)

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BARRY E. HINKLE, Bar No. 071223
CONCEPCIÓN E. LOZANO-BATISTA, Bar No. 227227
DANIEL S. BROME, Bar No. 278915
WEINBERG, ROGER & ROSENFELD
A Professional Corporation
1001 Marina Village Parkway, Suite 200
Alameda, California 94501
Telephone [phone]
Fax [phone]
E-Mail: [e-mail]
[e-mail]
[e-mail]

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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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SAN FRANCISCO DIVISION

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THE BOARD OF TRUSTEES, in their capacities
as Trustees of the LABORERS HEALTH AND
WELFARE TRUST FUND
FOR NORTHERN CALIFORNIA; LABORERS
VACATION-HOLIDAY TRUST FUND FOR
NORTHERN CALIFORNIA; LABORERS
PENSION TRUST FUND FOR NORTHERN
CALIFORNIA; and LABORERS TRAINING
AND RETRAINING TRUST FUND FOR
NORTHERN CALIFORNIA,

No. C 12-06044 DMR
STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE;
[PROPOSED] ORDER

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Plaintiff,

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v.
TITAN DVBE INCORPORATED, a California
Corporation
Defendant.

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WEINBERG, ROGER &
ROSENFELD
A Professional Corporation
1001 Marina Village Parkway, Suite 200
Alameda, California 94501
[phone]

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
Case No. C 12-06044 DMR

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Pursuant to Civil Local Rules 7-12 and 16-2, Plaintiffs THE BOARD OF TRUSTEES, in

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their capacities as Trustees of the LABORERS HEALTH AND WELFARE TRUST FUND FOR

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NORTHERN CALIFORNIA; LABORERS VACATION-HOLIDAY TRUST FUND FOR

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NORTHERN CALIFORNIA; LABORERS PENSION TRUST FUND FOR NORTHERN

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CALIFORNIA; and LABORERS TRAINING AND RETRAINING TRUST FUND FOR

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NORTHERN CALIFORNIA (hereinafter “Plaintiffs”), by and through the undersigned counsel,

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and Defendant TITAN DVBE, INC., a California Corporation (hereinafter “Defendant”), by and

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through the undersigned counsel, hereby respectfully request that the Case Management

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Conference currently scheduled for August 21, 2013 at 1:30pm be continued for ninety days.

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The parties are involved in ongoing settlement negotiations regarding the results of the

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payroll audit of Defendant’s books and records. The parties are continuing to exchange

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information and are optimistic they will be able to resolve their disputes prior to any rescheduled

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Case Management Conference. The negotiations and exchange of information conducted thus far

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have already significantly focused the issues of the case. Even if the parties are not able to

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resolve this matter fully, having this meeting will significantly narrow what facts and claims are

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in dispute. Accordingly, the parties respectfully request that the August 21, 2013 Case

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Management Conference be continued for ninety days.

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Dated: August 14, 2013

WEINBERG, ROGER & ROSENFELD
A Professional Corporation

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By:

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Dated: August 14, 2013

/s/ Daniel S. Brome
DANIEL S. BROME
Attorneys for Plaintiffs
COOK BROWN LLP

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By:

/s/ Debra Hinshaw Vierra
DEBRA HINSHAW VIERRA
Attorneys for Defendant

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WEINBERG, ROGER &
ROSENFELD
A Professional Corporation
1001 Marina Village Parkway, Suite 200
Alameda, California 94501
[phone]

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
Case No. C 12-06044 DMR

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[PROPOSED] ORDER

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Based upon the foregoing Stipulation to Continue Case Management Conference, the

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Court orders the continuance of the August 21, 2013 Case Management Conference for ninety

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(90) days, or as soon thereafter as a court date is available. In addition, the Court Orders:

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to Nov. 20, 2013 at 1:30 p.m. The Case Management Statement is due Nov. 13, 2013.

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Dated:

Aug. 16, 2013

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_________________________________________
HONORABLE DONNA M. RYU
UNITED STATES MAGISTRATE JUDGE

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132311/721101

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WEINBERG, ROGER &
ROSENFELD
A Professional Corporation

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1001 Marina Village Parkway, Suite 200
Alameda, California 94501
[phone]

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
Case No. C 12-06044 DMR