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Trustees of the Bricklayers Local No. 3 Pension Trust v. Capitol City Tile and Marble Inc.

November 7, 2011

TRUSTEES OF THE BRICKLAYERS LOCAL NO. 3 PENSION TRUST;
TRUSTEES OF THE LOCAL NO. 7 PENSION TRUST;
TRUSTEES OF THE BRICKLAYERS LOCAL NO. 3 HEALTH AND WELFARE TRUST;
TRUSTEES OF THE BRICKLAYERS AND ALLIED CRAFTS LOCAL NO. 3 APPRENTICETRAINING TRUST; INTERNATIONAL UNION OF BRICKLAYERS AND ALLIED CRAFTSMEN, AFL-CIO, LOCAL UNION NO. 3, ON BEHALF OF ITSELF AND AS AGENT FOR ITS MEMBERS; TRUSTEES OF THE INTERNATIONAL UNION
OF BRICKLAYERS AND ALLIED CRAFTSMEN PENSION FUND; TRUSTEES OF THE NORTHERN CALIFORNIA TILE INDUSTRY PENSION TRUST; TRUSTEES OF THE NORTHERN CALIFORNIA TILE INDUSTRY HEALTH AND WELFARE TRUST FUND; TRUSTEES OF THE NORTHERN CALIFORNIA TILE INDUSTRY APPRENTICESHIP AND TRAINING TRUST FUND; TILE INDUSTRY PROMOTION FUND OF NORTHERN CALIFORNIA, INC., A NOT-FOR-PROFIT CALIFORNIA CORPORATION; AND TILE
EMPLOYERS CONTRACT ADMINISTRATION FUND,
PLAINTIFFS,
v.
CAPITOL CITY TILE AND MARBLE INC., A CALIFORNIA CORPORATION;
INTERNATIONAL FIDELITY INSURANCE COMPANY, A NEW JERSEY CORPORATION; AMERICAN CONTRACTORS INDEMNITY COMPANY, A CALIFORNIA CORPORATION, DEFENDANTS.



The opinion of the court was delivered by: Hon. Maria-Elana James Chief United States Magistrate Judge

Kent Khtikian, Esq. (#99843) Conor D. Mack, Esq. (#253878) 2 Katzenbach and Khtikian 1714 Stockton Street, Suite 300 3 San Francisco, California 94133-2930 Telephone: (415) 834-1778 4 Facsimile: (415) 834-1842 5 Attorneys for Plaintiffs 6 Gaurav Bobby Kalra, Esq. (#219483) Veda Counsel, Attorneys at Law 7 770 L Street, Suite 950 Sacramento, California 95814 8 Telephone: (916) 492-6088 Facsimile: (916) 492-6087 9 Attorney for Defendant 10 CAPITOL CITY TILE AND MARBLE INC. 11 12

PLAINTIFFS' AND DEFENDANT CAPITOL CITY TILE & MARBLE INC.'S STIPULATION EXTENDING DATE FOR TRIAL, DISCOVERY CUT-OFF AND ALL OTHER RELATED DATES [proposed] ORDER

been negotiating a settlement in this matter for several months; 0 participated in a Settlement Conference before Magistrate Judge Nandor J. Vadas on October 19, 11 2011; 12 13 postponed discovery while negotiating a settlement; 14 15 believe they are close to reaching a settlement in this matter; 17 the only parties that have appeared in this matter; 18 19 hereby stipulate to extend the discovery cut-off date, the date for trial and all other dates in the 20 Court's April 26, 2011 Case Management Order for a period of One Hundred Twenty (120) days; 21 22 extending discovery cut-off date, the date for trial and all other dates in the Court's April 26, 23 2011 Case Management Order for a period of One Hundred Twenty (120) days. 24

SO STIPULATED 25

WHEREAS plaintiffs and defendant CAPITOL CITY TILE AND MARBLE INC., have

WHEREAS plaintiffs and defendant CAPITOL CITY TILE AND MARBLE INC.,

WHEREAS plaintiffs and defendant CAPITOL CITY TILE AND MARBLE INC., have

WHEREAS plaintiffs and defendant CAPITOL CITY TILE AND MARBLE INC.,

WHEREAS plaintiffs and defendant CAPITOL CITY TILE AND MARBLE INC., are

WHEREAS plaintiffs and defendant CAPITOL CITY TILE AND MARBLE INC.,

NOW THEREFORE, the parties hereto request that the Court at this time enter this order

VEDA COUNSEL

I, Conor Mack, declare that Gaurav Kalra, attorney for Defendant Capitol City Tile & Marble Inc., has signed the Stipulation set forth above and that I have in my possession his 11 signatures on this document.

I declare under penalty of perjury that the foregoing is true and correct.

Executed this 5th day of November 2011, in San Francisco, California.

/s/ Conor Mack Conor D. Mack

[proposed] ORDER

Disclosure of Expert Witnesses:

The deadline for serving the name, address, qualifications, resume, and a written report 4 which complies with Federal Rule of Civil Procedure 26(a)(2)(B) of any expert witness is 5 extended by 120 days, from 11/11/2011 to 3/11/2012. 6

Rebuttal Expert Witnesses:

The deadline for serving the name, address, qualifications, resume, and a written report 8 which complies with Federal Rule of Civil Procedure 26(a)(2)(B) of any rebuttal expert witness 9 is ...


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