UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA
May 5, 2011
BAY AREA PAINTERS AND TAPERS PENSION TRUST FUND, ET AL.,
AIC PAINTING CORPORATION, A CALIFORNIA CORPORATION; MARK DALE BOHN, INDIVIDUALLY AND DBA AIC PAINTING,
The opinion of the court was delivered by: The Honorable Susan Illston United States District Court Judge
Muriel B. Kaplan, Esq. (SBN 124607) Michele R. Stafford, Esq. (SBN 172509) 2 SALTZMAN & JOHNSON LAW CORPORATION 44 Montgomery Street, Suite 2110 3 San Francisco, CA 94104 (415) 882-7900 4 (415) 882-9287 -- Facsimile firstname.lastname@example.org 5 email@example.com 6 Attorney for Plaintiffs
REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE; PLAINTIFFS' CASE MANAGEMENT CONFERENCE STATEMENT; [PROPOSED] ORDER THEREON
Date: May 13, 2011 Time: 2:30 p.m. Ctrm: 10, 19th 16 Floor Judge: The Honorable Susan Illston
Plaintiffs herein respectfully submit their Case Management Statement, requesting that the Case Management Conference, currently on calendar for May 13, 2011, be continued for 20 approximately 60--90 days, as follows: 21
1. As the Court's records will reflect, a Complaint was filed in this action on January 28, 2011 for contributions due to the Trust Funds for work performed by Defendants' employees. 23
2. Defendants have requested a payment plan to satisfy the amounts
are currently drafting said payment plan which will be in the form
of a Stipulated Judgment 25
("Stipulation"), and anticipate filing the Stipulation with the Court
within approximately thirty
3. Defendants have retained counsel, who has yet to appear. Plaintiffs agreed to extend the time to respond in anticipation of resolving this matter.
4. 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 4 resources, Plaintiffs respectfully request that the Case Management Conference, currently 5 scheduled for May 13, 2011, be continued for approximately 60--90 days to allow for the 6 preparation, review, execution and filing of the Stipulation.
IT IS SO ORDERED.
Based on the foregoing, and GOOD CAUSE APPEARING, the currently set Case Management Conference is hereby continued to _____________________________. All related
August 12, 2011 deadlines are extended accordingly. 16 17
PROOF OF SERVICE
I, the undersigned, declare: 3
1. I am a citizen of the United States and am employed in the County of San Francisco, State of California. My business address is 44 Montgomery Street, Suite 2110, San 5 Francisco, California 94104. 6
2. I am over the age of eighteen and not a party to this action.
3. May 4, 2011, I served the following document(s):
REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE; PLAINTIFFS' CASE MANAGEMENT CONFERENCE STATEMENT;
[PROPOSED] ORDER THEREON
10 on the interested parties in said action by enclosing a true and exact copy of each document in a 11 sealed envelope and placing the envelope for collection and mailing following our ordinary 12 business practices. I am readily familiar with this business' practice for collecting and processing 13 correspondence for mailing. On the same day that correspondence is placed for collection and 14 mailing, it is deposited in the ordinary course of business with the United States Postal Service in 15 a sealed envelope with First Class postage fully prepaid. 16
4. The envelope(s) were addressed and sent via First Class U.S. Mail as follows:
Dawna J. Cilluffo, Esq. DC Law 2005 De La Cruz Blvd., Suite 215 Santa Clara, California 95050 I declare under penalty of perjury that the foregoing is true and correct and that this 0 declaration was executed on this 4th day of May, 2011, at San Francisco, California. 21 22
/S/ Vanessa de Fabrega Vanessa de Fabrega Paralegal
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