Operating Engineers Pension Trust Fund et al v. Terrasearch et al

Filing 77

STIPULATION AND ORDER re 76 STIPULATION AND PROPOSED ORDER for Extension of Time to Amend Pleadings filed by 3 MAK, LLC, F.G. Crosthwaite, Russell E. Burns, Terrasearch, Operating Engineers Pension Trust Fund. Signed by Judge ARMSTRONG on 5/2/12. (lrc, COURT STAFF) (Filed on 5/2/2012)

1 RICHARD C. JOHNSON (SBN 40881)
SHAAMINI A. BABU (SBN 230704)
2 SALTZMAN & JOHNSON LAW CORPORATION
44 Montgomery Street, Suite 2110
3 San Francisco, CA 94104
[phone]
4 [phone] – Facsimile
[e-mail]
5 [e-mail]
Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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(OAKLAND DIVISION)

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OPERATING ENGINEERS’ PENSION
TRUST FUND; F.G. CROSTHWAITE and
RUSSELL E. BURNS, as Trustees,
Plaintiffs,

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STIPULATION TO EXTEND TIME
FOR JOINDER OF PARTIES AND TO
AMEND PLEADINGS AND ORDER

vs.

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Case No.: CV 10-04964 SBA

TERRASEARCH, a California Corporation, 3
MAK, LLC, a California Limited Liability
Company, and DOES 1-20,

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Defendants.

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The parties filed a Joint Case Management Statement on February 15, 2012. Docket No.

20 72. A Case Management Conference was held via telephone on February 22, 2012. Docket No.
21 73. Thereafter, the Court issued an Order for Pre-Trial Preparation on February 27, 2012, and
22 specified May 1, 2012, as the deadline to join parties and amend the pleadings. Docket No. 74.
23 The parties are attempting to resolve the pending dispute.
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The parties hereby stipulate to an extension of 10-days until Friday May 11, 2012, for

25 Plaintiffs to join additional parties and amend the Complaint if necessary.

All other deadlines

26 specified in the Order for Pre-Trial Preparation will remain unchanged.

As such, the parties

27 respectfully request the Court to extend the deadline for joinder and to amend the pleadings to
28 May 11, 2012.
P:\CLIENTS\OE3WL\CASES\Terrasearch\Trial\Stipulation to Extend Time to Amend 050112.doc

-1REQUEST TO CONTINUE CMC
Case No.: CV 10-04964 SBA

1 Dated: May 1, 2012

SALTZMAN & JOHNSON LAW CORPORATION

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By: __________/s/______________
Shaamini A. Babu
Attorneys for Plaintiff

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6 Dated: May 1, 2012

LITTLER MENDELSON P.C.

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By: __________/s/______________
Stephen C. Tedesco
Attorneys for Defendants___

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10 IT IS SO ORDERED.
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Based on the foregoing, and good cause appearing, the parties shall have until May 11,

12 2012, to join other parties and amend the pleadings. All other deadlines specified in the Order for
13 Pre-Trial Preparation will remain unchanged.
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17 Date: _5/2/12
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_________________________________________________
SAUNDRA ARMSTRONG
United States District Court Judge

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P:\CLIENTS\OE3WL\CASES\Terrasearch\Trial\Stipulation to Extend Time to Amend 050112.doc

-2REQUEST TO CONTINUE CMC
Case No.: CV 10-04964 SBA