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California Health and Welfare Trust Fund, et al v. Vanderhave Flooring

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA DISTRICT COUNCIL NORTHERN


March 15, 2011

CALIFORNIA HEALTH AND WELFARE TRUST FUND, ET AL., PLAINTIFFS,
v.
VANDERHAVE FLOORING, A CALIFORNIA DATE: MARCH 18, 2011 PARTNERSHIP; RALPH LEE VANDERHAVE, TIME: 2:30 P.M. PARTNER; AND CHRISTIAN LEE CTRM: 10, 19TH FLOOR VANDERHAVE, PARTNER,
DEFENDANTS.

The opinion of the court was delivered by: Judge: The Honorable Susan Illston

REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE; PLAINTIFFS' CASE MANAGEMENT CONFERENCE STATEMENT; [PROPOSED] ORDER THEREON

Plaintiffs herein respectfully submit their Case Management Statement, requesting that the Case Management Conference, currently on calendar for March 18, 2011, be continued for approximately 60 days, pending Plaintiffs' filing their Motion for Default Judgment.

1. As the Court's records will reflect, a Complaint was filed in this matter on August 11, 2010.

2. Service on Defendants was effectuated on August 28, 2010, and a Proof of Service of Summons was filed with the Court on August 30, 2010.

3. On October 5, 2010, the Court entered the default of all Defendants.

4. Plaintiffs have prepared a Motion for Default Judgment which they anticipate filing with the Court within seven days.

5. There are no issues that need to be addressed at the currently scheduled Case Management Conference. In the interest of conserving costs as well as the Court's time and resources, Plaintiffs respectfully request that the Case Management Conference, currently scheduled for March 18, 2011, be vacated, or in the alternative be continued to either coincide with the date to be set for the Motion or continued for 60 days to allow filing and disposition of the Motion.

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 10th day of March, 2011, at San Francisco, California.

SALTZMAN & JOHNSON LAW CORPORATION By: /S/Michele R. Stafford Michele R. Stafford Attorneys for Plaintiffs

IT IS SO ORDERED.

Based on the foregoing, and GOOD CAUSE APPEARING, the currently set Case Management Conference is hereby vacated. or

Based on the foregoing, and GOOD CAUSE APPEARING, the currently set Case Management Conference is hereby continued to All related June 3, 2011 deadlines are extended accordingly.

THE HONORABLE SUSAN ILLSTON 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 March 10, 2011, I served the following document(s): 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: Vanderhave Flooring Ralph Lee Vanderhave 469 Moffat Boulevard, Suite E 469 Moffat Boulevard, Suite E Manteca, California 95336 Manteca, California 95336 Christian Lee Vanderhave 469 Moffat Boulevard, Suite E Manteca, California 95336

I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed on this 10th day of March, 2011, at San Francisco, California.

Vanessa de Fabrega

20110315

© 1992-2011 VersusLaw Inc.



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