Crosthwaite et al v. Fremont Paving Company, Inc. et al

Filing 31

ORDER GRANTING 30 Joint MOTION to Continue CASE MANAGEMENT CONFERENCE. Case Management Statement due by 9/28/2012. Initial Case Management Conference set for 10/5/2012 01:30 PM in Courtroom 11, 19th Floor, San Francisco.. Signed by Judge Jeffrey S. White on 8/1/12. (jjoS, COURT STAFF) (Filed on 8/1/2012)

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Case3:11-cv-04417-JSW Document30 Filed07/31/12 Page1 of 2 1 Michele R. Stafford, Esq. (SBN 172509) Blake E. Williams, Esq. (SBN 233158) 2 SALTZMAN & JOHNSON LAW CORPORATION 44 Montgomery Street, Suite 2110 3 San Francisco, CA 94104 (415) 882-7900 4 (415) 882-9287 – Facsimile mstafford@sjlawcorp.com 5 bwilliams@sjlawcorp.com 6 Attorneys for Plaintiffs 7 Robert E. Carey, Jr., Esq. (State Bar No. 47556) CAREY & CAREY, A LAW CORPORATION 8 Post Office Box 1040 Palo Alto, CA 94302 9 (650) 328-5510 (650) 853-3632 – Facsimile 10 rec@careyandcareylaw.com 11 Attorneys for Defendant Fremont Paving Company, Inc. 12 UNITED STATES DISTRICT COURT 13 FOR THE NORTHERN DISTRICT OF CALIFORNIA 14 F.G. CROSTHWAITE, et al. Plaintiffs, 15 16 17 v. FREMONT PAVING COMPANY, INC., a California Corporation, et al., Case No.: C11-4417-JSW JOINT CASE MANAGEMENT CONFERENCE STATEMENT and REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER THEREON 20 Date: Time: Ctrm: Judge: 21 Defendant Fremont Paving Company, Inc. hereby joins in Plaintiffs’ previously filed 18 Defendants. 19 August 3, 2012 1:30 p.m. 11, 19th Floor Honorable Jeffrey S. White 22 Request to Continue Case Management Statement. The parties jointly request that the Case 23 Management Conference, currently on calendar for August 3, 2012, be continued to allow 24 Plaintiffs to file their Motions for Summary Judgment and Default Judgment respectfully. 25 1. Plaintiffs have made several offers to resolve this matter by payment plan. 26 Defendants are unable to commit to any resolution at the current time. Defendants are aware that 27 Plaintiffs must move this matter forward by filing dispositive Motions. 28 2. There are no issues that need to be addressed at the currently scheduled Case -1JOINT CMC STATEMENT AND REQUEST TO CONTINUE CMC; PROPOSED ORDER Case No.: C11-4417-JSW P:\CLIENTS\OE3CL\Fremont Paving Company Inc\Pleadings\C11-4417-JSW - JOINT Request to Continue CMC - 073112.DOC Case3:11-cv-04417-JSW Document30 Filed07/31/12 Page2 of 2 1 Management Conference. In the interest of conserving costs as well as the Court’s time and 2 resources, Plaintiffs respectfully request that the Case Management Conference, currently 3 scheduled be continued for 60 days. 4 Dated: July 31, 2012 SALTZMAN & JOHNSON LAW CORPORATION 5 By: 6 7 8 Dated: July 31, 2012 CAREY & CAREY, A LAW CORPORATION 9 10 By: 11 12 13 14 15 16 /S/ Michele R. Stafford Attorneys for Plaintiffs /S/ Robert E. Carey, Jr. Attorneys for Defendant Fremont Paving Company, Inc. IT IS SO ORDERED. Based on the foregoing, and GOOD CAUSE APPEARING, the currently set Case October 5, 2012 at 1:30 p.m. Management Conference is hereby continued to _____________________________. All related deadlines are extended accordingly. 17 18 Date: ____________________ August 1, 2012 19 _________________________________________ THE HONORABLE JEFFREY S. WHITE UNITED STATES DISTRICT COURT JUDGE 20 21 22 23 24 25 26 27 28 -2JOINT CMC STATEMENT AND REQUEST TO CONTINUE CMC; PROPOSED ORDER Case No.: C11-4417-JSW P:\CLIENTS\OE3CL\Fremont Paving Company Inc\Pleadings\C11-4417-JSW - JOINT Request to Continue CMC - 073112.DOC

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