UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA
July 18, 2008
BOARD OF TRUSTEES OF THE NORTHERN CALIFORNIA FLOOR COVERING INDUSTRY WELFARE FUND, et al., PLAINTIFFS,
JOE WANG, INDIVIDUALLY, AND dba J W CARPET, ET AL., DEFENDANTS.
The opinion of the court was delivered by: Judge: The Honorable William H. Alsup
REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE Date: July 24, 2008 Time: 2:30 p.m. Ctrm: 9, 19th Floor
Saltzman & Johnson Law Corporation recently substituted as counsel for Plaintiffs on June 12, 2008, and are in the process of familiarizing themselves with the claims in this matter.
The parties are attempting to resolve their dispute regarding the balance owed by the Defendant to Plaintiffs in anticipation of entering into a stipulated judgment in this action. In the event that the settlement negotiations are unsuccessful, Plaintiffs will file a motion for summary judgment.
Plaintiffs therefore, respectfully request that the Case Management Conference, currently scheduled for July 24, 2008, be continued for approximately sixty (60) days to allow the parties ample opportunity to resolve their differences and enter into a stipulated judgment.
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 17th day of July, 2008, at San Francisco, California.
SALTZMAN & JOHNSON LAW CORPORATION
Shaamini A. Babu Attorneys for Plaintiffs
IT IS SO ORDERED.
The currently set Case Management Conference is hereby continued to __________________________ at __________________. All related deadlines are extended accordingly.
Date: _________________________ __________________________________
United States District Court Judge
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 July 17, 2008, I served the following document(s):
REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE 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:
Joe Wang, individually and dba Joe Wang Carpet and Flooring J W Carpet & Flooring 116A Starlite Street 116A Starlite Street South San Francisco, California 94080 South San Francisco, California 94080
I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed on this 17th day of July, 2008, at San Francisco, California.
Vanessa de Fábrega
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