STIP AND JOINT REQUEST TO CONTINUE MEDIATION DATE; PROPOSED ORDER 

CASE NO. 17-cv-00602 JST 

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Anne M. Bevington (SBN 111320) 

abevington@sjlawcorp.com

Kimberly A. Hancock (SBN 205567) 

khancock@sjlawcorp.com

Carol A. Treasure (SBN 225751) 

ctreasure@sjlawcorp.com

SALTZMAN & JOHNSON LAW CORPORATION 

44 Montgomery Street, Suite 2110 

San Francisco, CA 94104 

Telephone: (415) 882-7900 

Facsimile: (415) 882-9287 

Attorneys for Plaintiffs Automotive Industries Pension Trust Fund, 

and Trustees James H. Beno, Don Crosatto, Stephen J. Mack, James Schwantz, 

Doug Cornford, John DiBernardo, Jose Santana, and James Wells 

Robert F. Schwartz, No. 227327 

Clarissa A. Kang, No. 210660 

Jahiz Noel Agard, No. 282988 

TRUCKER  HUSS 

A Professional Corporation 

One Embarcadero Center, 12th Floor 

San Francisco, CA 94111 

Telephone: (415) 788-3111 

Facsimile: (415) 421-2017 

E-mail: rschwartz@truckerhuss.com 

ckang@truckerhuss.com 

 jagard@truckerhuss.com 

 

Attorneys for Defendants 

Mike Rose’s Auto Body, Inc., Washington 

Township Central Investment Co., William 

F. Brunelli, James R. Brunelli, Andrew M. 

Brunelli, Joan M Brunelli Devries, Barbara 

A. Brunelli Young, Richard R. Brunelli 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

AUTOMOTIVE INDUSTRIES PENSION 

TRUST FUND, et al., 

Plaintiffs, 

v. 

MIKE ROSE’S AUTO BODY INC., a 

California corporation, et al. 

Defendants. 

Case No.: 17-cv-00602 JST 

_____________ 

STIPULATION AND JOINT 

REQUEST TO EXTEND THE 

DEADLINE FOR MEDIATION; 

PROPOSED ORDER 
STIP AND JOINT REQUEST TO CONTINUE MEDIATION DATE; PROPOSED ORDER 

CASE NO. 17-cv-00602 JST 

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IT IS HEREBY STIPULATED by and between the parties to this action, by and through 

their attorneys of record, and the parties jointly request that the Court permit them to extend the 

deadline for their mediation session, currently set as September 16, 2017, to September 20, 2017 

due to the availability of all parties and participants. The parties submit that good cause exists for 

the following reasons. 

1. On June 16, 2017, the parties filed a stipulation selecting ADR process and agreed 

that mediation would be completed within 90 days from the date of the Court’s order adopting the 

stipulation. The presumptive deadline for the mediation session is Saturday, September 16, 2017. 

(90 days from the date of the court’s order adopting the stipulation) On June 18, 2017, the 

Honorable Jon S. Tigar signed the order. 

2. On June 20, 2017, the parties were assigned to mediator Robert Hirsch, Esq. 

3. On July 24, 2017, the parties participated in a pre-mediation phone conference with 

Mediator Hirsh. During that conference call with the Mediator, the parties proposed several dates 

for scheduling the Mediation subject to the availability of all parties. 

4. The parties intend to conduct written discovery involving the exchange of 

documents prior to the Mediation. 

5. On July 26, 2017, the parties essential to resolving the case confirmed their 

availability to hold the mediation on September 20, 2017. 

6. For the reasons stated above, the parties respectfully request that the Court permit 

the parties to hold the mediation session on September 20, 2017, which should allow sufficient 

time to complete the ADR process well in advance of Trial, scheduled for October 29, 2018. 

7. The parties respectfully request that the Court approve this stipulation and 

incorporate its terms in an Order. 

// 

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STIP AND JOINT REQUEST TO CONTINUE MEDIATION DATE; PROPOSED ORDER 

CASE NO. 17-cv-00602 JST 

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IT IS SO STIPULATED. 

DATED: July 27, 2017 

SALTZMAN & JOHNSON LAW CORPORATION 

By: /S/ Carol A. Treasure 

 Anne M. Bevington 

 Kimberly Hancock 

 Carol A. Treasure 

 Attorneys for Plaintiffs 

DATED: July 27, 2017 

TRUCKER  HUSS 

By: /S/ Robert Schwartz 

 Robert Schwartz 

 Attorneys for Defendants 

CERTIFICATION RE SIGNATURES 

I attest that concurrence in the filing of this document has been obtained from each of the 

other Signatories. 

Dated: July 27, 2017 /s/ Carol A. Treasure 

 CAROL A. TREASURE 

IT IS SO ORDERED. 

Dated: July 31, 2017 

HON. JON S. TIGAR 

United States District Judge