Operating Engineers Health and Welfare Trust Fund et al v. Rhino Engineering, Inc. et al

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JOINT REQUEST TO CONTINUE PRE-SETTLEMENT CONFERENCE TELEPHONE CONFERENCE;
[PROPOSED] ORDER THEREON
Case No. 26-cv-02960-KAW
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OPERATING ENGINEERS’ HEALTH AND
WELFARE TRUST FUND, et al.,
Plaintiffs,
v.
RHINO ENGINEERING INC., a California
Corporation; and MATTHEW NEWMAN, an
Individual,
Defendants.
Case No. 26-cv-02960-KAW
JOINT REQUEST TO CONTINUE PRE-
SETTLEMENT CONFERENCE
TELEPHONE CONFERENCE;
[PROPOSED] ORDER THEREON
The parties respectfully request that the Pre-Settlement Conference (Telephone Conference)
before Judge Thomas S. Hixson, currently on calendar for October 16, 2026 (ECF 20), be continued for
approximately 30 days. Good cause exists for the granting of the continuance, as follows:
Matthew P. Minser, Esq. (SBN 296344)
Tanisha M. Arata, Esq. (SBN 280588)
SALTZMAN & JOHNSON LAW CORPORATION
5100-B1 Clayton Road, Suite 373
Concord, CA 94521
Telephone: (510) 906-4710
mminser@sjlawcorp.com
tarata@sjlawcorp.com
Attorneys for Plaintiffs, Operating Engineers’
Health and Welfare Trust Fund, et al.
Robert L. Rediger, Esq. (SBN 109392)
Justin R. Rediger, Esq. (SBN 296510)
Arielle M. Rediger, Esq. (CA Bar No. 313794)
REDIGER LABOR LAW LLP
555 Capitol Mall, Suite 1240
Sacramento, California 95814
Telephone: (916) 442-0033
rlr@rediger.law/jrr@rediger.law/amr@rediger.law
Attorneys for Defendants,
Rhino Engineering, Inc., and Matthew Newman
Case 4:26-cv-02960-KAW Document 24 Filed 10/15/26 Page 1 of 3

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JOINT REQUEST TO CONTINUE PRE-SETTLEMENT CONFERENCE TELEPHONE CONFERENCE;
[PROPOSED] ORDER THEREON
Case No. 26-cv-02960-KAW
1. 	As the Court’s records will reflect, this action was filed on April 6, 2026. (Dkt #1).
2. 	Defendants were served via substitute service on April 17, 2026, with April 17, 2026
mailings deeming service effectuated on April 27, 2026. A Proof of Service of Summons was filed with
the Court on May 8, 2026. (Dkt. #9).
3. 	Defendants filed an Answer to Plaintiffs’ Complaint on May 11, 2026. (Dkt. #10).
4. 	On June 16, 2026, the parties filed a Stipulation and [Proposed] Order Selecting an Early
Settlement Conference with a Magistrate Judge as their preferred ADR Process. (Dkt. #16).
5. 	On June 22, 2026, the Court granted the parties’ Stipulation Selecting an Early
Settlement Conference with a Magistrate Judge. (Dkt. #17.)
6. 	On June 26, 2026, the Clerk issued a Notice setting the Pre-Settlement Conference
Telephone Conference for October 16, 2026. (Dkt. #20.)
7. 	Plaintiffs have issued a Proposed Judgment Pursuant to Stipulation, which provides for a
payment plan to allow Defendants to satisfy their debt to Plaintiff Trust Funds by making monthly
payments, to Defendants for review and execution.
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Case 4:26-cv-02960-KAW Document 24 Filed 10/15/26 Page 2 of 3

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JOINT REQUEST TO CONTINUE PRE-SETTLEMENT CONFERENCE TELEPHONE CONFERENCE;
[PROPOSED] ORDER THEREON
Case No. 26-cv-02960-KAW
By:
8. Accordingly, there are no issues that need to be addressed by the parties at the currently
scheduled Pre-Settlement Conference Telephone Conference. In the interest of conserving costs as well
as the Court’s time and resources, the parties respectfully request that the Court continue the Pre-
Settlement Conference Telephone Conference, currently scheduled for October 16, 2026, for 30 days. If
the parties are unsuccessful in resolving this matter through a Judgment Pursuant to Stipulation, the
parties anticipate moving forward with the Early Settlement Conference with a Magistrate Judge.
Respectfully submitted.
DATED: October 15, 2026 SALTZMAN & JOHNSON LAW CORPORATION
Tanisha M. Arata, Esq.
Attorneys for Operating Engineers’ Health and
Welfare Trust Fund, et al.
IT IS SO ORDERED.
The currently set Pre-Settlement Conference Telephone Conference is hereby continued to
_11/17/2026 at 3:00 PM, and all previously set deadlines and dates related to this case are
continued accordingly.
DATED: October 15, 2026
THOMAS S. HIXSON
UNITED STATES MAGISTRATE JUDGE
DATED: October __, 2026
By:
REDIGER LABOR LAW LLP
Arielle M. Rediger, Esq.
Attorneys for Defendants, Rhino Engineering, Inc.,
and Matthew Newman
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/S/
Case 4:26-cv-02960-KAW Document 24 Filed 10/15/26 Page 3 of 3