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Gil Crosthwaite and Russ Burns, In Their v. Paul T. Beck Contractors

March 16, 2011

GIL CROSTHWAITE AND RUSS BURNS, IN THEIR
RESPECTIVE CAPACITIES AS TRUSTEES OF THE OPERATING ENGINEERS' HEALTH ANDRE WELFARE TRUST FUND, ET AL., DISCOVERY
PLAINTIFFS,
v.
PAUL T. BECK CONTRACTORS, INC., A
CALIFORNIA CORPORATION,
DEFENDANT.



The opinion of the court was delivered by: Judge: Honorable Samuel Conti

PLAINTIFFS' PROPOSED ORDER

Plaintiffs hereby submit their Proposed Order regarding Discovery, pursuant to the Court's 19 request at the March 4, 2011 Case Management Conference in this matter. Plaintiffs request that 20 Defendant answer the specific interrogatories and produce the specific documents requested 21 below. Plaintiffs also reserve the right to depose the receiver and/or the "person most 22 knowledgeable" of Paul T. Beck in the event that the discovery responses are not adequate.

DISCOVERY REQUESTS

1. Identify all of the assets of Paul T. Beck at the time that the receiver was appointed 25 in December 2009. List all assets individually, including equipment (both office and construction 26 related), vehicles and any other real or personal property. Please identify any assets that were sold 27 or transferred during the six (6) months preceding the appointment of the receiver. 28

PLAINTIFFS' PROPOSED ORDER re DISCOVERY

2 in December 2009? How much of these funds were collected? Who were they collected from and 3 when? 4 5 asset, the value assigned to the asset, and how that value was assigned as well as the disposition of 6 each asset. 7

8 present, and explain the disposition of the funds, i.e., who was paid, how much, and why. 9

10 identify that entity and under what terms the asset was sold or transferred. Please also identify 11 specifically if James Beck individually or JRB Grading and Paving obtained any of the assets and 12 under what terms. 13

14 appointed? If so, please identify all jobs, including job title/location, general contractor, owner 15 and time period of job.

2. What funds were owed to Paul T. Beck at the time that the receiver was appointed

3. Who valued and disposed of Paul T. Beck's assets? Please identify each and every

4. Please identify the total funds collected by the receiver from December 2009 to

5. If any other entity purchased or obtained any of Paul T. ...


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