JOINT REQUEST TO EXTEND MEDIATION DEADLINE AND 

CONTINUE CASE MANAGEMENT CONFERENCE 

CASE NO.: C09-2241 SI 

P:\CLIENTS\FLRCL\M B Flooring\Pleadings\C09-2241 SI Joint Request to Continue Mediation Deadline 012510.DOC

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Muriel B. Kaplan, Esq. (SBN 124607) 

Michele R. Stafford, Esq. (SBN 172509) 

SALTZMAN & JOHNSON LAW CORPORATION 

44 Montgomery Street, Suite 2110 

San Francisco, CA 94104 

(415) 882-7900 

(415) 882-9287 – Facsimile 

mkaplan@sjlawcorp.com

mstafford@sjlawcorp.com 

Attorneys for Plaintiffs 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

Case No.: C09-2241 SI 

JOINT REQUEST TO EXTEND 

MEDIATION DEADLINE AND 

CONTINUE CASE MANAGEMENT 

CONFERENCE 

DISTRICT COUNCIL 16 NORTHERN 

CALIFORNIA HEALTH AND WELFARE 

TRUST FUND, et. al.,. 

 Plaintiffs, 

 v. 

M B FLOORING, INC., 

 Defendant. 

Date:

Time: 

Ctrm: 

Judge:

March 26, 2010 

2:30 p.m. 

10, 19th Floor 

The Honorable Susan Illston 

The parties to the above-entitled action jointly request that the deadline for mediation be 

extended for the following reasons: 

1. On December 3, 2009, the appointment of Mediator Michael Sobel in this action 

was vacated [Docket No. 20]. 

2. On January 14, 2010, Arthur Siegel was appointed as the Mediator in this action, 

replacing Michael Sobel. [Docket No. 23]. 

3. An initial telephone conference occurred today, January 25, 2010. During the 

conference call, a mediation date of March 16, 2010 was set. 

Case 3:09-cv-02241-SI Document 26 Filed 01/27/10 Page 1 of 2 Case3:09-cv-02241-SI Document24 Filed01/26/10 Page1 of 2
JOINT REQUEST TO EXTEND MEDIATION DEADLINE AND 

CONTINUE CASE MANAGEMENT CONFERENCE 

CASE NO.: C09-2241 SI 

P:\CLIENTS\FLRCL\M B Flooring\Pleadings\C09-2241 SI Joint Request to Continue Mediation Deadline 012510.DOC

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 4. To allow the mediation to occur as scheduled, the parties request that the deadline 

be extended to late March – early April, 2010. The parties have been exchanging documents and 

other information, hoping to resolve the matter. Extending the deadline will also allow 

negotiations to continue.

5. A Case Management Conference is currently set for March 26, 2010. Based on the 

foregoing, there are no issues to discuss pending mediation. The parties therefore jointly request 

that the date be continued to 30 days after the new mediation deadline. 

Respectfully submitted, 

Dated: January 26, 2010 SALTZMAN & JOHNSON 

LAW CORPORATION 

By: /S/Michele R. Stafford 

 Michele R. Stafford 

Attorneys for Plaintiffs 

 

Dated: January 25, 2010 RANDICK O’DEA AND TOOLIATOS 

By: /S/Brian M. O’Dea 

 Brian M. O’Dea 

Attorneys for Defendants 

ORDER 

 Good cause appearing, the mediation deadline is extended to _______________, 2010. 

The Case Management Conference currently set for December 18, 2009 is continued to 

___________________, 2010. 

IT IS SO ORDERED. 

Date: ________________________________________ 

 THE HONORABLE SUSAN ILLSTON 

 UNITED STATES DISTRICT COURT JUDGE 

Case3:09-cv-02241-SI Document24 Filed01/26/10 Page2 of 2

April 2,

May 7

Case 3:09-cv-02241-SI Document 26 Filed 01/27/10 Page 2 of 2