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REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE 

Case No.: C09-2069 SI 

P:\CLIENTS\FLRCL\Mortensen's Carpet\Pleadings\C09-2069 SI - Req to Continue CMC 021810.doc 

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Michele R. Stafford, Esq. (SBN 172509) 

Blake E. Williams, Esq. (SBN 233158) 

SALTZMAN & JOHNSON LAW CORPORATION 

44 Montgomery Street, Suite 2110 

San Francisco, CA 94104 

(415) 882-7900 

(415) 882-9287 – Facsimile 

mstafford@sjlawcorp.com

bwilliams@sjlawcorp.com

Attorneys for Plaintiffs 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

DISTRICT COUNCIL 16 NORTHERN 

CALIFORNIA HEALTH AND WELFARE TRUST 

FUND, et al., 

 Plaintiffs, 

 v. 

MORTENSEN’S CARPETS, INC., a California 

Corporation,

 Defendant. 

Case No.: C09-2069 SI 

REQUEST TO CONTINUE CASE 

MANAGEMENT CONFERENCE 

Date: February 26, 2010 

Time: 2:30 p.m. 

Courtroom: 10, 19th Floor 

 450 Golden Gate Avenue 

 San Francisco, CA 94102 

Judge: Honorable Susan Illston

Plaintiffs respectfully request that the Case Management Conference currently scheduled 

for February 26, 2010, at 2:30 p.m., be continued for approximately sixty to ninety (60-90) days, 

as follows: 

 1. A Complaint was filed by Plaintiffs in this matter on May 12, 2009. 

2. Defendant did not answer or otherwise appear in this action. After numerous 

requests (both initial, and amended) for entry of default, the Clerk finally entered Default against 

Defendant on February 5, 2010.

3. Plaintiffs are preparing a Motion for Default Judgment, which will be filed within 

the next 7 days. Accordingly, Plaintiffs request that the Case Management Conference be 

continued for 60-90 days to allow the Motion to be filed and heard.

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORN

I

A

Submitting counsel are

directed to serve this 

order upon all other 

non-efiling parties 

in this action.

Case 3:09-cv-02069-RS Document 30 Filed 02/19/10 Page 1 of 3
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REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE 

Case No.: C09-2069 SI 

P:\CLIENTS\FLRCL\Mortensen's Carpet\Pleadings\C09-2069 SI - Req to Continue CMC 021810.doc 

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 I declare under penalty of perjury that I am the attorney for the Plaintiffs in the above 

entitled action, and that the foregoing is true and correct. 

 Executed this 18th day of February, 2010 at San Francisco, California. 

 SALTZMAN & JOHNSON 

 LAWCORPORATION 

 By: ___________/s/___________________ 

 Blake E. Williams 

 Attorneys for Plaintiffs 

IT IS SO ORDERED. 

 The Case Management Conference in this action is hereby continued to __________. 

Dated: ____________________ _________________________________ 

 United States District Court Judge 

May 14,

2010

Case 3:09-cv-02069-RS Document 30 Filed 02/19/10 Page 2 of 3
REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE 

Case No.: C09-2069 SI 

P:\CLIENTS\FLRCL\Mortensen's Carpet\Pleadings\C09-2069 SI - Req to Continue CMC 021810.doc 

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PROOF OF SERVICE

I, the undersigned, declare: 

 I am a citizen of the United States and am employed in the County of San Francisco, State 

of California. I am over the age of eighteen and not a party to this action. My business address is 

44 Montgomery Street, Suite 2110, San Francisco, California 94104. 

 On February 18, 2010, I served the following document(s): 

REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE

on the interested parties in said action by First Class U.S. Mail by placing a true and exact copy of 

each document in a sealed envelope with postage thereon fully prepaid, in a United States Post 

Office box in San Francisco, California, addressed as follows: 

Shirley Figgins 

Mortensen’s Carpets, Inc. 

42 Moss Pointe 

Alameda, California 94502 

 I declare under penalty of perjury that the foregoing is true and correct and that this 

declaration was executed on this 18th day of February, 2010, at San Francisco, California.

___________/S/_______________

 Vanessa de Fábrega 

 

Case 3:09-cv-02069-RS Document 30 Filed 02/19/10 Page 3 of 3