F.G. CROSTHWAITE, et al., Plaintiffs,
GIACALONE ELECTRICAL SERVICES, INC., et al., Defendants. PENSION PLAN FOR PENSION TRUST FUND FOR OPERATING ENGINEERS, et al., Plaintiffs,
GIACALONE ELECTRICAL SERVICES, INC., et al., Defendants.
Michele R. Stafford, Esq. (SBN 172509) Shaamini A. Babu, Esq. (SBN 230704) SALTZMAN & JOHNSON LAW CORPORATION San Francisco, CA, Attorneys for Plaintiffs
Roger M. Mason, Esq. SWEENEY, MASON, WILSON & BOSOMWORTH, Los Gatos, CA, Attorneys for Defendant Gilroy Construction, Inc.
Amy Jensen (SBN 226589) Hinshaw & Culbertson LLP, San Francisco, CA, Attorneys for Defendants Vincent Giacalone and Lisa Giacalone
STIPULATED REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE
SUSAN ILLSTON, District Judge.
In accordance with Rule 16 and 26(f) of the Federal Rules of Civil Procedure, Northern District Local Rule 16-9, Standing Order for All Judges of the Northern District of California, and Honorable Susan Illston's Case Management Order, the parties hereto submit this Stipulated Request to Continue the Case Management Conference.
1. On June 18, 2013, the Court related Crosthwaite v. Giacalone Electrical Services, Inc., et al., Case No. CV12-6178 SI ("Contributions Action") to Pension Plan for Pension Trust Fund for Operating Engineers, et al., v. Giacalone Electrical Services, Inc., et al., Case No. CV13-2338 ("Withdrawal Liability Action"). Docket No. 38.
2. In the Contributions Action, Plaintiffs seek delinquent contributions and other related sums in excess of $850, 000 found due to the Operating Engineers Trust Funds ("Trust Funds") upon audit of the records of Defendant Giacalone Electrical Services, Inc. ("Giacalone Electrical") for the time period January 1, 2005, through July 24, 2009.
3. In the Withdrawal Liability Action, Plaintiffs seek withdrawal liability of $2, 231, 762 and other related sums as a result of Defendant Giacalone Electrical's withdrawal from the Pension Plan for Pension Trust Fund for Operating Engineers ("Plan").
4. Defendant Giacalone Electrical was named in the Contributions Action and the Withdrawal Liability Action, and the Court entered default against said defendant in both actions. Docket Nos. 33 and 22, respectively.
5. Defendants Giacalone McDermott Management, LLC, Luchessa Road, LLC, Ronan Avenue Investors, LLC were named only in the Withdrawal Liability Action, and the Count entered default against said defendants. Docket Nos. 22, and 30.
6. Defendant Giacalone Design Services, Inc. was only named in the Contributions Action and has been dismissed. Docket No. 54.
7. Defendants VLG2, LLC, and Crow Court LLC, were only named in the Withdrawal Liability Action and have ...