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The Board of Trustees, In Their v. Paul T. Beck Contractors

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


February 23, 2011

THE BOARD OF TRUSTEES, IN THEIR
CAPACITIES AS TRUSTEES OF THE CEMENT MASONS HEALTH AND WELFARE TRUST
FUND FOR NORTHERN CALIFORNIA, CEMENT MASONS PENSION TRUST FUND
FOR NORTHERN CALIFORNIA, CEMENT ; MASONS VACATION/HOLIDAY TRUST
FUND FOR NORTHERN CALIFORNIA, CEMENT MASONS APPRENTICESHIP AND TRAINING TRUST FUND FOR NORTHERN CALIFORNIA,
PLAINTIFFS,
v.
PAUL T. BECK CONTRACTORS, INC, A
CALIFORNIA CORPORATION.
DEFENDANT.

The opinion of the court was delivered by: Honorable Elizabeth D. Laporte United States District Court Judge

BARRY E. HINKLE, Bar No. 071223 PATRICIA A. DAVIS, Bar No. 179074 KRISTINA M. ZINNEN, Bar No. 245346 WEINBERG, ROGER & ROSENFELD A Professional Corporation 1001 Marina Village Parkway, Suite 200 Alameda, CA 94501-1091 Telephone (510) 337-1001 5 Facsimile (510) 337-1023 6 Attorneys for Plaintiffs ROBERT E. ROSENTHAL, Bar No. 067343 ANDREW B. KREEFT, Bar No. 126673 BOHNEN, ROSENTHAL & KREEFT 787 Munros Avenue, Suite 200 P.O. Box 1111 Monterey, CA 93942 Telephone (831) 649-5551 Facsimile (831) 649-0272 Attorneys for Defendants

STIPULATION TO EXTEND DISCOVERY CUT-OFF [PROPOSED] ORDER

Plaintiffs The Board of Trustees, in their capacities as Trustees of the Cement Masons

WEINBERG, ROGER & ROSENFELD

A Professional Corporation 1001 Marina Village Parkway

Suite 200

Stipulation to Extend Discovery Cut-Off; [Proposed] Order

Alameda, CA 94501-1091

(510) 337-1001

Health and Welfare Trust Fund for Northern California, Cement Masons Pension Trust Fund for

Northern California, Cement Masons Vacation-Holiday Trust Fund for Northern California, and

Cement Masons Apprenticeship and Training Trust Fund for Northern California ("Plaintiffs") and Defendants Paul T. Beck Contractors, Inc. ("Defendant"), by and through the undersigned counsel, 5 hereby stipulate and request that the Court order that the discovery cut-off date in the above-6 entitled action be extended to March 28, 2011. The basis for this request is that Defendant's Person Most Knowledgeable has been out of town and unavailable for deposition. Furthermore,

Defendant recently informed Plaintiffs that the assets of Defendant were liquidated during a 9 receivership. Plaintiffs therefore require additional time to investigate the information Defendant 10 provided and to determine how to proceed in the litigation.

It is further stipulated that all other deadlines in the Court's scheduling order of September 21, 2010 (Document 17) shall remain unchanged.

124118/609573

WEINBERG, ROGER & ROSENFELD

A Professional Corporation 1001 Marina Village Parkway Suite 200

Stipulation to Extend Discovery Cut-Off; [Proposed] Order Alameda, CA 94501-1091 (510) 337-1001

Pursuant to Stipulation, IT IS SO ORDERED.

Dated: Feb. 25, 2011

WEINBERG, ROGER & ROSENFELD

1001 Marina Village Parkway Suite 200

Stipulation to Extend Discovery Cut-Off; [Proposed] Order

A Professional Corporation Alameda, CA 94501-1091 (510) 337-1001

20110223

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