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.
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
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 ...