August 22, 2013
SERVICE EMPLOYEES INTERNATIONAL UNION NATIONAL INDUSTRY PENSION FUND; STEPHEN ABRECHT, Trustee, ROD BASHIR, Trustee; KEVIN J. DOYLE, Trustee; MYRIAM ESCAMILLA, Trustee; STEVEN W. FORD, Trustee; EDWARD J. MANKO, Trustee; FRANK A. MAXSON, Trustee; JOHN J SHERIDAN, Trustee; LARRY T. SMITH, Trustee; DAVID STILWELL, Trustee, Plaintiff,
EMPLOYEE EQUITY ADMINISTRATION, INC., a California corporation, d/b/a Westline Medical Management, et al., Defendants.
DAVID R. JOHANSON (SBN 164141), JACKSON LEWIS LLP, Los Angeles, California,
CHARLES F. SEEMANN III (admitted pro hac vice), JACKSON LEWIS LLP, New Orleans, Louisiana, Attorneys for Defendants SOL HEALTHCARE, LLC; SOLNUS TWO, LLC; SOLNUS THREE, LLC; SOLNUS FOUR, LLC; SOLNUS EIGHT, LLC; SOL MAJER; and SHLOMO RECHNITZ
SALTZMAN & JOHNSON LAW CORPORATION, Kimberly A. Hancock, Attorneys for Plaintiffs.
SHELLEY R. BUCHANAN, Attorneys for Defendants Employee Equity Administration, Inc., et al.
JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; and [PROPOSED] ORDER
JOHN S. TIGAR, District Judge.
Plaintiffs Service Employees International Union National Industry Pension Fund, Stephen Abrecht, Rod Bashir, Kevin J. Doyle, Myriam Escamilla, Steven W. Ford, Edward J. Manko, Frank A. Maxson, John J. Sheridan, Larry T. Smith, and David Stillwell (collectively, the "Plaintiffs"), the Westline Defendants (which includes Defendants Employee Equity Administration, Inc., Oak Facility, Inc., RCC Facility, Inc., RV Facility, Inc., SP Facility, Inc., SJ Facility, Inc., Pleasant View Convalescent Hospital, Inc., Willow Street Properties, LLC, Northgate Center, Inc., Jaline, Inc., Skilled Logic Systems, Jack Easterday, and Deline Davis), and the Solnus Defendants (which include Sol Healthcare, LLC, SOLNUS TWO, LLC, SOLNUS THREE, LLC, SOLNUS FOUR, LLC, SOLNUS EIGHT, LLC, Sol Majer, and Shlomo Rechnitz), (collectively, the "Parties"), hereby stipulate as follows:
1. A Case Management Conference is currently scheduled for September 4, 2013, pursuant to Docket No. 46.
2. This Court previously ordered Mediation to occur pursuant to Docket No. 38. Such Mediation is scheduled to occur on September 25, 2013, at this Court's ADR Unit in San Francisco, California. The Parties believe that it would be more efficient and cost effective to conduct the initial Case Management Conference with Judge Tigar after the Mediation occurs.
3. The Parties jointly request that the Case Management Conference be continued to the next available date for the Parties after the Mediation, which is October 9, 2013, or as soon thereafter (except for October 16, October 23, or October 30, when the parties are unavailable) when this Court is next available. Please note that the parties are also not available on October 3, 2013.
4. The Parties request that the Joint Case Management Conference Statement be submitted to the Court ten court days before the new Case Management Conference date.
IT IS SO STIPULATED.
The terms of the Stipulation herein above are hereby approved and adopted.
The Case Management Conference currently scheduled for September 4, 2013, is hereby continued to November 6, 2013, at 2:00 p.m. The Parties shall file with this Court a Joint Statement ten (10) court days prior to that date. IT IS SO ORDERED.