The opinion of the court was delivered by: Judge: The Honorable Susan Illston
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 -- Telephone 4 (415) 882-9287 -- Facsimile email@example.com 5 firstname.lastname@example.org 6 Attorney for Plaintiffs
Date: December 9, 2011 Time: 3:00 p.m.
[PROPOSED] ORDER THEREON
JOINT REQUEST FOR CONTINUANCE
OF CASE MANAGEMENT CONFERENCE and JOINT CASE
Ctrm: 10, 19th 16
The parties herein respectfully submit their Joint Case Management Statement and joint 19 request to continue the Case Management Conference, currently on calendar for December 9, 20 2011, for approximately 30 days. 21
1. As the Court's records will reflect, a Complaint this action was filed on January 28, 2011, to compel Defendants' compliance with their obligations under the Collective Bargaining 23 Agreement to which they are signatory. 24
2. On two previous occasions, Defendants requested a payment plan to satisfy the 25 amounts due, and on each occasion, Plaintiffs drafted such agreements which Defendants 26 ultimately did not sign. 27
3. After a long hiatus in communication, Defendants' counsel recently made a settlement proposal which was reviewed by Plaintiffs. Plaintiffs provided a counter proposal and 2 are waiting for Defendants' response thereto. 3
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 5 resources, the parties respectfully request that the Case Management Conference, currently 6 scheduled for December 9, 2011, be continued for approximately 30 days to allow the parties to 7 attempt settlement with the goal of resolving this matter without the further intervention of the Court, and for the preparation, review, and execution of a Judgment Pursuant to Stipulation if an 9 agreement is reached. If an agreement is not reached and filed with the Court within that time, 10
Plaintiffs will immediately proceed with preparation and filing of a Motion for Summary 11 Judgment. 12
Respectfully submitted, 13
Based on the foregoing, and GOOD CAUSE APPEARING, the currently set Case
Management Conference is hereby continued to ...