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