Monrad v. Krueger et al

Filing 14

STIPULATION AND ORDER re 13 STIPULATION WITH PROPOSED ORDER : 1) EXTENDING DEFENDANTS' TIME TO FILE RESPONSIVE PLEADINGS; AND 2) CONTINUING THE INITIAL CASE MANAGEMENT CONFERENCE filed by Steven Monrad, Krueger Bros. Builders, Inc., David Krueger, Krueger Bros. Builders, Inc. Employees Defined Benefit Pension Plan Initial Case Management Conference set for 10/7/2014 01:30 PM in Courtroom 4, 3rd Floor, Oakland. Signed by Magistrate Judge Kandis A. Westmore on 6/24/14. (sisS, COURT STAFF) (Filed on 6/24/2014)

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J. MICHAEL MATTHEWS (Bar No.: 71848)
CARLSON, CALLADINE & PETERSON LLP
353 Sacramento Street, 16th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendants DAVID KRUEGER,
KRUEGER BROS. BUILDERS, INC.,
A California Corporation and KRUEGER BROS.
BUILDERS, INC. EMPLOYEES DEFINED
BENEFIT PLAN

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UNITED STATE DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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STEVEN MONRAD,
Plaintiff,

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v.

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DAVID KRUEGER, KRUEGER BROS.
BUILDERS, INC., A California
Corporation, and KRUEGER BROS.
BUILDERS, INC. EMPLOYEES
DEFINED BENEFIT PLAN,

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Defendants.
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Civil Action No.: 4:14-cv-2529 KAW
STIPULATION AND [PROPOSED]
ORDER: 1) EXTENDING DEFENDANTS’
TIME TO FILE RESPONSIVE
PLEADINGS; AND 2) CONTINUING THE
INITIAL CASE MANAGEMENT
CONFERENCE

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Plaintiff STEVEN MONRAD has brought this action alleging ERISA violations and

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seeking various remedies. Counsel for Plaintiff and counsel for Defendants David Krueger et. al.

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have cooperatively begun the “meet and confer” process mandated by Local Rules, and are

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exchanging documents that will allow each side to evaluate the claims and defenses. Their

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efforts will be complicated by the travel plans of Plaintiff’s lead counsel, who will be out of the

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country for three weeks during the month of July, 2014. Accordingly, they stipulate to the

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following, and ask that the Court enter its order as follows:

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1. Defendants’ time to file pleadings responsive to the Complaint in this action may be
Civil Action No. 4:14-cv-2529 KAW
STIPULATION AND [PROPOSED] ORDER

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and hereby is extended from June 23, 2014 to July 23, 2014; and
2. The Initial Case Management Conference, set for September 2, 2014, in Courtroom 4,
10/7/14
3rd Floor, of this Court, is continued approximately thirty days to ________________,
1:30 pm
at _________, in Courtroom 4, 3rd Floor, of this Court. The deadline for the parties to

meet and confer re: initial disclosures, early settlement, and discovery plan is continued
to twenty-eight (28) days before the new CMC date, and the last day for the parties to
file their Rule 26(f) Report, complete initial disclosures and file Case Management
Statement is continued until fourteen (14) days before the new CMC date.

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For Plaintiff:
DATED: June 25, 2014

LEWIS, FEINBERG, LEE, RENAKER &
JACKSON P.C.

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By
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/s/ Daniel Feinberg
DANIEL FEINBBERG
Attorneys for Plaintiff STEVEN MONRAD

For Defendants:
DATED: June 25, 2014

CARLSON, CALLADINE & PETERSON LLP

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By

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/s/ J. Michael Matthews
J. MICHAEL MATTHEWS
Attorneys for Defendants DAVID KRUEGER,
KRUEGER BROS. BUILDERS, INC.,
KRUEGER BROS. BUILDERS, INC.
EMPLOYEES DEFINED BENEFIT PLAN

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IT IS SO ORDERED; THE CMC IS CONTINUED AS INDICATED ABOVE.

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DATED: 6/24/14
HON. KANDIS A. WESTMORE
MAGISTRATE JUDGE OF THE UNITED
STATES DISTRICT COURT
Civil Action No. 4:14-cv-2529 KAW
STIPULATION AND [PROPOSED] ORDER