UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA
June 23, 2008
GIL CROSTHWAITE, ET AL., AS TRUSTEES OF THE OPERATING ENGNEERS HEALTH AND WELFARE TRUST FUND FOR NORTHERN CALIFORNIA, ET AL., PLAINTIFFS,
JOLANDCO, INC., DEFENDANT.
The opinion of the court was delivered by: Marilyn H. Patel Judge
REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE AND ORDER THEREON
Plaintiffs herein respectfully request a Continuance of the Case Management Conference currently on calendar for June 30, 2008.
1. Plaintiffs are currently in discussions with defendant to establish a payment plan for all amounts owed by defendant to date, thereby resolving the matter. Plaintiffs have requested that the plan be included in a Judgment Pursuant to Stipulation.
2. Upon execution of a Judgment Pursuant to Stipulation, plaintiffs will file it with the court and request that the court to retain jurisdiction in the event of defendants' default.
3. Plaintiffs therefore respectfully request that the Case Management Conference, currently scheduled for June 30, 2008, be continued for approximately 60 days to allow the Judgment Pursuant to Stipulation to be signed and thereby bring this matter to resolution.
4. It is furthermore requested that all previously set deadlines and dates related to this case be continued as well.
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.
Executed this 19th day of June, 2008, at San Francisco, California.
IT IS SO ORDERED.
The currently set Case Management Conference is hereby continued to __________________________ at __________________, and all previously set deadlines and August 25, 2008 3:00 p.m. dates related to this case are vacated, to be reset at that Conference.
IT IS SO ORDERED
Date: June 20, 2008
PROOF OF SERVICE
I, the undersigned, declare:
I am a citizen of the United States and am employed in the County of San Francisco, State of California. I am over the age of eighteen and not a party to this action. My business address is 44 Montgomery Street, Suite 2110, San Francisco, California 94104.
On June 19, 2008, I served the following document(s):
REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE AND ORDER THEREON on the interested parties in said action by placing a true and exact copy of each document in a sealed envelope with postage thereon fully prepaid, in a United States Post Office box in San Francisco, California, addressed as follows: Christopher D. Johnson Authorized Agent for Service of Process Jolandco, Inc. 9083 Foothills Blvd., Suite 350 Roseville, California 95747
I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed on this 19th day of June, 2008, at San Francisco, California.
Vanessa de Fábrega
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