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

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA


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. Beck's assets, please

6. Did Paul T. Beck have any ongoing jobs at the time that the receiver was

7. For all jobs identified in Number 6 above, who finished / completed each job?

Please also identify specifically if James Beck individually or JRB Grading and Paving obtained 18 completed any of the jobs for Paul T. Beck. 19

8. If anyone other than Paul Beck completed any of the jobs identified in Number 6 20 above, did they assume the contract or was a new contract executed? 21 22 work on the project? 23

24 another entity completed the work and/or got paid for finishing the job. 25

9. For any jobs identified in Number 6 above, did Paul T. Beck get fully paid for their

10. If the answer to Number 9 is "no", please explain why, including whether or not

11. For all assets sold or liquidated and all monies collected, and/or for the period from December 2009 to the present, please identify each and every creditor paid, the amount that the 27 creditor received and the basis for paying that creditor. 28

12. Please produce any and all documents showing the collection, valuation and 2 disposition of any of the assets or funds identified above. 3 4 5 6

ORDER

Defendant Paul T. Beck is hereby Ordered to provide responses to the above 8 interrogatories within ____ days of the date of this Order and no later than ______________, 2011 9 forthwith. 10 11

IT IS SO ORDERED.

THE HONORABLE SAMUEL CONTI

PROOF OF SERVICE

I, the undersigned, declare: 3

I am a citizen of the United States and am employed in the County of San Francisco, State 4 of California. I am over the age of eighteen and not a party to this action. My business address is 5 44 Montgomery Street, Suite 2110, San Francisco, California 94104.

On March 9, 2011, I served the following document(s):

PLAINTIFFS' PROPOSED ORDER re DISCOVERY

8 on the interested parties in said action by First Class U.S. Mail by placing a true and exact copy of 9 each document in a sealed envelope with postage thereon fully prepaid, in a United States Post 10 Office box in San Francisco, California, addressed as follows: 11

I declare under penalty of perjury that the foregoing is true and correct and that this 17 declaration was executed on this 9th day of March, 2011, at San Francisco, California. 18 19

s/ Qui X. Lu

20110316

© 1992-2011 VersusLaw Inc.



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