The opinion of the court was delivered by: Judge: The Honorable Thelton E. Henderson
Time: 1:30 p.m. trm: 12, 19th Floor 15 450 Golden Gate Avenue San Francisco, California
TEH PLAINTIFFS' REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE; and [PROPOSED] ORDER THEREON
Date: Monday, February 25, 2013
Plaintiffs respectfully request that the Case Management Conference scheduled for February 25, 2013, at 1:30 p.m., be continued for approximately 30 -- 45 days, as follows: 20 1. As the Court's records will reflect, this action was filed on November 15, 2012 to 19 21 compel Defendants to comply with the terms of their Collective Bargaining Agreement. 22 2. At Defendant's request, a payment plan in the form of a stipulated judgment was 23 drafted and sent to Defendants for execution. The payment plan included all amounts owed from 24 Defendants to Plaintiffs Trust Funds. 25
3. However, Defendants did not execute the payment plan, but instead, advised they 26 would make a lump sum payment. The parties then failed to agree upon a settlement amount. 27 4. Defendants recently retained counsel and both parties are now close to finalizing a 28 payment plan.
5. Therefore, Plaintiffs respectfully request that the Case Management Conference be 2 continued for approximately 30 -- 45 days in order to allow sufficient time for both parties to 3 finalize and execute the payment plan. 4 6. There are no issues that need to be addressed by this Court at the currently 5 scheduled Case Management Conference. In the interest of conserving costs as well as the Court's 6 time and resources, Plaintiffs respectfully request that the Court continue the currently scheduled 7 Case Management Conference. 8
7. Plaintiffs recognize that a case management conference statement is due seven days 9 in advance of the case management conference date and that the statement must include all 10 elements requested in the "Standing Order for All Judges of the Northern District of California -- 11 Contents of Joint Case Management Statement" pursuant to Local Rule 16-9. Should this Court 12 require Plaintiffs to file a Case Management Conference Statement, Plaintiffs will do so promptly.
SALTZMAN & JOHNSON LAW CORPORATION By: /s/ Michele R. Stafford 16 Attorneys for Plaintiffs
Based on the foregoing, and GOOD CAUSE APPEARING, the currently set Case Management Conference is hereby continued to _______________, and all re 04/08/2013 lated deadlines are extended accordingly. 21
THE HONORABLE THELTON E. HENDERSON UNITED STATES DISTRICT COURT Judge Thelton Henderson
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