JOINT SUPPLEMENTAL CASE MANAGEMENT CONFERENCE STATEMENT AND [PROPOSED] CASE 

MANAGEMENT ORDER 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

ATKINSON, ANDELSON, LOYA, RUUD & ROMO 

A PROFESSIONAL CORPORATION 

ATTORNEYS AT LAW 

A Professional Corporation 

012828.00008/242197v1 

ATKINSON, ANDELSON, LOYA, RUUD & ROMO 

A Professional Corporation 

Robert Fried, State Bar No. 85579 

5776 Stoneridge Mall Road, Suite 200 

Pleasanton, California 94588 

Telephone: (925) 227-9200 

Facsimile: (925) 227-9202 

Attorneys for Defendant Savior Plumbing, Inc., a 

California Corporation 

RICHARD K. GROSBOLL, Bar No. 99729 

SONYA M. GORDON, Bar No. 232600 

NEYHART, ANDERSON, FLYNN & GROSBOLL 

44 Montgomery Street, Suite 2080 

San Francisco, CA 94104 

Telephone (415) 677-9440 

Facsimile (415) 677-9445 

Attorneys for Plaintiffs 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

U.A. LOCAL 342 JOINT LABORMANAGEMENT COMMITTEE; 

NORTHERN CALIFORNIA PIPE TRADES 

PENSION TRUST; NORTHERN 

CALIFORNIA PIPE TRADES HEALTH AND 

WELFARE TRUST; LOCAL UNION 342, 

PLUMBERS & STEAMFITTERS, UNITED 

ASSOCIATION OF JOURNEYMEN AND 

APPRENTICES OF THE PLUMBING AND 

PIPEFITTING INDUSTRY OF THE UNITED 

STATES AND CANADA (AFL-CIO); U.A. 

LOCAL 342 APPRENTICESHIP & 

TRAINING TRUST FUND and JAMES 

WILLIAMS, as Trustee of the above 

TRUSTS., 

Plaintiff, 

vs. 

SAVIOR PLUMBING, INC., a California 

Corporation, 

Defendant. 

CASE NO.: C-09-2839-JSW 

JOINT SUPPLEMENTAL CASE 

MANAGEMENT CONFERENCE 

STATEMENT AND [PROPOSED] CASE 

MANAGEMENT ORDER

[Local Rule 16-9] 

JUDGE: Hon. Judge Jeffrey S. White 

DATE: April 9, 2010 

TIME: 1:309 p.m. 

DEPT: 11, 19th Floor 

LOCATION: 450 Golden Gate Avenue 

 San Francisco, CA 94102 

Case 3:09-cv-02839-JSW Document 20 Filed 04/05/10 Page 1 of 4 Case3:09-cv-02839-JSW Document19 Filed04/02/10 Page1 of 4
-2- 

JOINT SUPPLEMENTAL CASE MANAGEMENT CONFERENCE STATEMENT AND [PROPOSED] CASE 

MANAGEMENT ORDER 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

ATKINSON, ANDELSON, LOYA, RUUD & ROMO 

A PROFESSIONAL CORPORATION 

ATTORNEYS AT LAW 

Attorneys for Plaintiffs 

012828.00008/242197v1 

JOINT CASE MANAGEMENT STATEMENT

Pursuant to Federal Rule of Civil Procedure 26(f) and Local Rule 16-9, Plaintiffs and 

Defendants jointly submit this Case Management Statement and Rule 26(f) Report, and request 

that the Court adopt it as the Case Management Order in this case. 

Plaintiffs and Defendant asked the Court to grant an initial 60-day continuance of the 

Case Management Conference, to allow settlement discussions to continue on the expectation 

that a settlement will be forthcoming. The Court issued an order in accordance with this request 

on January 12, 2010. 

Since that date the parties have acted in accordance with the above representation and a 

course of action to access funds for the benefit of plaintiffs and in aid of settlement has been 

initiated. 

It is anticipated that a final resolution will follow the successful release of such funds 

after due consideration and agreement of all parties on the precise terms of a final settlement. If 

Defendant does not show progress in acquiring the necessary funds and/or otherwise settling the 

matter, Plaintiffs plan to file a summary judgment motion within three weeks. 

In accord with the above, the parties respectfully request the Court order a second 

continuance of the Case Management process for a period of sixty days and pledge their best 

efforts to ensure that this matter is definitively resolved prior to that time. 

Dated: April 2, 2010 Respectfully submitted, 

NEYHART, ANDERSON, FLYNN & 

GROSBOLL 

By: /s/Sonya M. Gordon 

 Sonya M. Gordon 

 Attorneys for Plaintiffs 

DATED: April 2, 2010 Respectfully submitted, 

Case 3:09-cv-02839-JSW Document 20 Filed 04/05/10 Page 2 of 4 Case3:09-cv-02839-JSW Document19 Filed04/02/10 Page2 of 4
-3- 

JOINT SUPPLEMENTAL CASE MANAGEMENT CONFERENCE STATEMENT AND [PROPOSED] CASE 

MANAGEMENT ORDER 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

ATKINSON, ANDELSON, LOYA, RUUD & ROMO 

A PROFESSIONAL CORPORATION 

ATTORNEYS AT LAW 

Attorneys for Plaintiffs 

012828.00008/242197v1 

 ATKINSON, ANDELSON, LOYA, 

 RUUD & ROMO 

 By: /s/ Robert Fried 

Robert Fried 

Attorneys for Defendant 

Case 3:09-cv-02839-JSW Document 20 Filed 04/05/10 Page 3 of 4 Case3:09-cv-02839-JSW Document19 Filed04/02/10 Page3 of 4
-4- 

JOINT SUPPLEMENTAL CASE MANAGEMENT CONFERENCE STATEMENT AND [PROPOSED] CASE 

MANAGEMENT ORDER 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

ATKINSON, ANDELSON, LOYA, RUUD & ROMO 

A PROFESSIONAL CORPORATION 

ATTORNEYS AT LAW 

Attorneys for Plaintiffs 

012828.00008/242197v1 

[proposed] CASE MANAGEMENT ORDER 

 This Case Management Statement and Proposed Order is hereby adopted by the Court as 

the Case Management Order for the case and the parties are ordered to comply with this Order. 

In addition, the Court orders a continuance of the Case Management Conference to 

, 2010. 

Dated: 

 United States District Judge 

Case3:09-cv-02839-JSW Document19 Filed04/02/10 Page4 of 4

June 25,

at 1:30 p.m.

April 5, 2010

Case 3:09-cv-02839-JSW Document 20 Filed 04/05/10 Page 4 of 4