Bricklayers Local No. 3 Pension Trust and its Board of Trustees et al v. South Valley Masonry, Inc., a California Corporation

Filing 19

ORDER GRANTING 18 MOTION to Continue Case Management Conference. Case Management Statement due by 1/9/2015. Initial Case Management Conference set for 1/16/2015 11:00 AM in Courtroom 5, 2nd Floor, Oakland. Signed by Judge JEFFREY S. WHITE on 11/10/14. (jjoS, COURT STAFF) (Filed on 11/10/2014)

Case4:14-cv-03515-JSW Document18 Filed11/06/14 Page1 of 3

1 Michele R. Stafford, Esq. (SBN 172509)
Erica J. Russell, Esq. (SBN 274494)
2 Adrian L. Canzoneri (SBN 265168)
SALTZMAN & JOHNSON LAW CORPORATION
3 44 Montgomery Street, Suite 2110
San Francisco, CA 94104
4 [phone] – Telephone
[phone] – Facsimile
5 [e-mail]
[e-mail]
6 [e-mail]
7 Attorneys for Plaintiffs
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9

UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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12 BRICKLAYERS LOCAL NO. 3 PENSION
TRUST, et al.
13
Plaintiffs,
14
v.
15
SOUTH VALLEY MASONRY, INC., a
16 California Corporation,

Case No.: C14-03515 JSW
PLAINTIFFS’ REQUEST TO CONTINUE
CASE MANAGEMENT CONFERENCE;
[PROPOSED] ORDER THEREON
Date:
Time:
Location:

Defendant.

17

Judge:

November 14, 2014
11:00 a.m.
1301 Clay Street
Oakland, CA 94612
Courtroom 5, 2nd Floor
Honorable Jeffrey S. White

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19

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

20 for November 14, 2014, be continued for approximately sixty (60) days. Good cause exists for the
21 granting of the continuance, as follows:
22

1.

As the Court’s records will reflect, this action was filed on August 4, 2014.

23 Defendant was served on August 11, 2014, and Proof of Service of Summons was filed with the
24 Court on August 18, 2014 (Dkt. #11). Defendant failed to plead or otherwise respond to the
25 lawsuit, and the Clerk entered default as to Defendant on September 8, 2014 (Dkt. #15).
26 Defendant was duly served with a copy of the Clerk’s Notice of Default Entry, and a Proof of
27 Service of same was filed with the Court on September 18, 2014 (Dkt. #16).
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-1REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE
Case No.: C14-03515 JSW
P:\CLIENTS\BRICL\South Valley Masonry\Pleadings\Request To Continue CMC 110614.docx

Case4:14-cv-03515-JSW Document18 Filed11/06/14 Page2 of 3

1

2.

Plaintiffs are preparing a Motion for Default Judgment, and will be filing the

2 Motion within the next fourteen (14) days. Accordingly, Plaintiffs respectfully request that the
3 Case Management Conference, currently scheduled for November 14, 2014, be continued for sixty
4 (60) days to allow for the preparation and filing of Plaintiffs’ Motion for Default Judgment.
5

3.

There are no issues that need to be addressed by the parties at the currently

6 scheduled Case Management Conference. In the interest of conserving costs, as well as the
7 Court’s time and resources, Plaintiffs respectfully request that the Court continue the currently
8 scheduled Case Management Conference.
9

I declare under penalty of perjury that I am the attorney for the Plaintiffs in the above

10 entitled action, and that the foregoing is true of my own knowledge.
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Executed this 6th day of November, 2014, at San Francisco, California.

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SALTZMAN & JOHNSON
LAW CORPORATION

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14
By:
15

/S/
Erica J. Russell
Attorneys for Plaintiffs

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17
18
19

IT IS SO ORDERED.
The currently

set

Case

Management

Conference

is

hereby

continued

to

January 16, 2015
20 _________________ at ____________, and all previously set deadlines and dates related to this
11:00 a.m.
21 case are continued accordingly.
22
23
24

November 10, 2014
Date: ____________________

_________________________________________
HONORABLE JEFFREY S. WHITE
UNITED STATES DISTRICT COURT JUDGE

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-2REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE
Case No.: C14-03515 JSW
P:\CLIENTS\BRICL\South Valley Masonry\Pleadings\Request To Continue CMC 110614.docx