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California Service Employees Health & Welfare Trust Fund v. Paramount Building Solutions

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


March 29, 2013

CALIFORNIA SERVICE EMPLOYEES HEALTH & WELFARE TRUST FUND,
MIKE GARCIA, TRUSTEE,
CHARLES GILCHRIST, TRUSTEE,
DAVID STILWELL, TRUSTEE, RAYMOND C. NANN,
TRUSTEE, AND LARRY T. SMITH, TRUSTEE,
PLAINTIFFS,
v.
PARAMOUNT BUILDING SOLUTIONS, LLC, AKA
JANITORIAL MANAGEMENT SERVICES/JMS, A DELAWARE LIMITED LIABILITY COMPANY;
JMS BUILDING SOLUTIONS, LLC, A DELAWARE LIMITED LIABILITY COMPANY; AND
DCSS INVESTMENTS, INC., A CALIFORNIA CORPORATION, FKA
PACIFIC MAINTENANCE SERVICES, INC., AKA PACIFIC BUILDING MAINTENANCE, INC.,
DEFENDANTS.

The opinion of the court was delivered by: William Alsup United States District Judge

STIPULATION FOR LEAVE TO FILE PLAINTIFFS' FIRST AMENDED COMPLAINT; (PROPOSED) ORDER

California Service Employees Health & Welfare Trust Fund, Mike Garcia, Charles Gilchrist, David Stilwell, Raymond C. Nann and Larry T. Smith, as Plaintiffs, and Paramount 25 Building Solutions, LLC and JMS Building Solutions, LLC (collectively "JMS/Paramount"), as 26 Defendants, are all of the parties to this action, the remaining defendants having been dismissed 27 pursuant to a settlement. The parties hereby stipulate and jointly request that the Court enter an 28 order as follows:

1. That Plaintiffs be granted leave to file a First Amended Complaint for the purpose

2 of removing the now-settled claim against former defendant DCSS and JMS/Paramount as 3 successor for amounts owing by DCSS, and adding the amounts claimed against JMS/Paramount 4 pursuant to the audit requested in the complaint and subsequently conducted; 5

2. That the First Amended Complaint be filed within five days after the Court enters an order approving this stipulation; and 7

3. That defendants have 21 days after the filing and ECF service of the First Amended Complaint within which to file their response. 9

4. The parties further stipulate that, should the Court deny leave to amend, defendants 10 shall respond to the original complaint within 10 days after the Court enters an order denying 11 leave to amend. 12

ATTESTATION RE SIGNATURES

I, Anne M. Bevington, declare under penalty of perjury that I have obtained concurrence

14 in the filing of this document from Jonathan M. Brenner, attorney of record for the defendants, 15 who agreed that the document may be filed with his electronic signature. 16

Dated: March 28, 2013 SALTZMAN & JOHNSON LAW CORPORATION 17 18 By: _____/S/ Anne M. Bevington__________ Anne M. Bevington 19 Attorneys for Plaintiffs Dated: March 28, 2013 SIDLEY AUSTIN LLP 21 22 By: ______/S/ Jonathan M. Brenner______ Jonathan M. Brenner Attorneys for Defendants PARAMOUNT BUILDING SOLUTIONS, LLC and JMS BUILDING SOLUTIONS, LLC

ORDER ON FOLLOWING PAGE -STIPULATION TO FILE FIRST AMENDED COMPLAINT; (PROPOSED) ORDER [CASE NO. C 12 5232 WHA]

ORDER

Pursuant to the above stipulation, the Court grants plaintiffs leave to file a First Amended Complaint within five days after entry of this order. Defendants shall respond to the First 4 Amended Complaint within 21 days of filing and ECF service.

Dated:

20130329

© 1992-2013 VersusLaw Inc.



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