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

Filing 79

STIPULATION AND ORDER re 78 STIPULATION WITH PROPOSED ORDER to Extend Time for Joinder of Parties and 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 5/10/12. (lrc, COURT STAFF) (Filed on 5/10/2012)

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 On May 1, 2012, parties stipulated to an extension of 10-days until Friday, May 11, 2012, for
24 Plaintiffs to join additional parties and amend the Complaint if necessary.

All other deadlines

25 specified in the stipulation for Pre-Trial Preparation were to remain unchanged. Docket 76. The
26 court approved the extension on May 2, 2012. Docket 77.
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C:\Users\clarkl\AppData\Local\Temp\notes06E812\Stipulation to Extend Time to Amend 050912.doc

-1STIPULATION TO EXTEND TIME
FOR JOINDER AND TO AMEND
Case No.: CV 10-04964 SBA

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The parties are continuing to attempt to resolve the pending dispute and hereby stipulate to

2 an additional extension of 21-days until Friday, June 1, 2012, for Plaintiffs to join additional
3 parties and amend the Complaint if necessary. All other deadlines specified in the Order for Pre4 Trial Preparation will remain unchanged. As such, the parties respectfully request the Court to
5 extend the deadline for joinder and to amend the pleadings to June 1, 2012.
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7 Dated: May 9, 2012

SALTZMAN & JOHNSON LAW CORPORATION

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

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12 Dated: May 9, 2012

LITTLER MENDELSON P.C.

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

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16 IT IS SO ORDERED.
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Based on the foregoing, and good cause appearing, the parties shall have until June 1,

18 2012, to join other parties and amend the pleadings. All other deadlines specified in the Order for
19 Pre-Trial Preparation will remain unchanged.
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23 Date: ___5/10/12
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_________________________________________________
SAUNDRA ARMSTRONG
United States District Court Judge

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C:\Users\clarkl\AppData\Local\Temp\notes06E812\Stipulation to Extend Time to Amend 050912.doc

-2STIPULATION TO EXTEND TIME
FOR JOINDER AND TO AMEND
Case No.: CV 10-04964 SBA