Trustees of the Bricklayers & Allied Craftworkers Local 13 Defined Contribution Pension Trust For Southern Nevada et al v. Commercial Union Tile & Stone, Inc. et al

Filing 67

ORDER Granting 66 Stipulation for Extension of Time (Third Request) to File Responses to 53 , 54 , 55 , and 56 Motions for Summary Judgment. Responses due by 3/13/2017. Signed by Judge Andrew P. Gordon on 2/8/2017. (Copies have been distributed pursuant to the NEF - SLD)

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Case 2:15-cv-02129-APG-NJK Document 66 Filed 02/08/17 Page 1 of 3 1 2 3 4 5 6 7 GARG GOLDEN LAW FIRM ANTHONY B. GOLDEN, ESQ. Nevada Bar No. 9563 PUNEET K. GARG, ESQ. Nevada Bar No. 9811 3185 St. Rose Parkway, Suite 325 Henderson, Nevada 89052 Tel: (702) 850-0202 Fax: (702) 850-0204 Email: agolden@garggolden.com Counsel for Defendants Vegas Affordable Stone and Tile, Inc., Stone Consulting, LLC, and Jedediah Michael Feller 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 11 12 13 14 15 16 17 18 19 TRUSTEES OF THE BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 DEFINED CONTRIBUTION PENSION TRUST FOR SOUTHERN NEVADA; TRUSTEES OF THE BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 HEALTH BENEFITS FUND; TRUSTEES OF THE BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 VACATION FUND; BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 NEVADA; TRUSTEES OF THE BRICKLAYERS & TROWEL TRADES INTERNATIONAL PENSION FUND; TRUSTEES OF THE BRICKLAYERS & TROWEL TRADES INTERNATIONAL HEALTH FUND; and TRUSTEES OF THE INTERNATIONAL MASONRY INSTITUTE, CASE NO.: STIPULATION AND ORDER TO EXTEND TIME TO FILE RESPONSES TO PENDING MOTIONS FOR SUMMARY JUDGMENT AS BETWEEN PLAINTIFFS AND DEFENDANTS VEGAS AFFORDABLE STONE AND TILE, INC., STONE CONSULTING, LLC, AND JEDEDIAH MICHAEL FELLER (THIRD REQUEST) Plaintiffs, 20 21 vs. 22 COMMERCIAL UNION TILE & STONE, INC., a Nevada corporation; VEGAS AFFORDABLE STONE AND TILE, INC., a Nevada corporation; STONE CONSULTING, LLC, a Nevada limited liability company; JONATHAN WILLIAM CANJA, individually; and JEDEDIAH MICHAEL FELLER, individually, 23 24 25 26 Defendants. 27 28 GARG GOLDEN LAW FIRM 3185 St. Rose Parkway Suite 325 Henderson, Nevada 89052 (702) 850-0202 2:15-cv-02129-APG-NJK 1 of 3 Case 2:15-cv-02129-APG-NJK Document 66 Filed 02/08/17 Page 2 of 3 1 Plaintiffs, by and through their undersigned counsel, and Defendants Vegas Affordable 2 Stone and Tile, Inc., Stone Consulting, LLC, and Jedediah Michael Feller (collectively, 3 “Stipulating Defendants”), by and through their undersigned counsel, stipulate and agree to 4 further extend the deadline to file responses to the following pending motions for summary 5 judgment from February 13, 2017 to March 13, 2017: 6 Defendant Jedediah Feller’s Motion for Summary Judgment (dkt. # 53); 7 Plaintiffs’ Motion for Summary Judgment as against Stipulating Defendants only (dkt. # 8 54); Defendant Vegas Affordable Stone and Tile, Inc.’s Motion for Summary Judgment (dkt. 9 10 # 55); 11 Defendant Stone Consulting, LLC’s Motion for Summary Judgment (dkt. # 56); 12 This is the third request for an extension of time for these deadlines, and the request is not 13 made for the purpose of delay. The parties to this stipulation have reached a settlement 14 agreement in principle and are in the process of finalizing the language for a written agreement. 15 The remaining defendants, Commercial Union Tile & Stone, Inc. and Jonathan William Canja, 16 are not parties to the aforementioned settlement or to this stipulation. The parties to this 17 stipulation submit that good cause appears for the extension, and they continue to wish to 18 dedicate time and resources to the resolution without incurring additional litigation expense. 19 Although stated in the previous stipulation in this matter, the parties to this stipulation anticipate 20 this to be their last request for such an extension in this matter and expect to have the written 21 agreement executed prior to the 22 /// 23 24 25 26 27 28 GARG GOLDEN LAW FIRM 3185 St. Rose Parkway Suite 325 Henderson, Nevada 89052 (702) 850-0202 /// 2 of 3 Case 2:15-cv-02129-APG-NJK Document 66 Filed 02/08/17 Page 3 of 3 1 2 3 4 5 6 7 8 new response deadline. Dated this 8th day of February, 2017. GARG GOLDEN LAW FIRM THE URBAN LAW FIRM By /s/ Anthony B. Golden By /s/ Nathan R. Ring Anthony B. Golden, Esq. Michael A. Urban, Esq. 3185 St. Rose Parkway, Suite 325 Nathan R. Ring, Esq. Henderson, Nevada 89052 4270 S. Decatur Blvd., Suite A-9 (702) 850-0202 (702) 968-8087 Counsel for Plaintiffs Counsel for Vegas Affordable Stone and Tile, Inc., Stone Consulting, LLC, and Jedediah Michael Feller 9 10 ORDER IT IS SO ORDERED: 11 12 14 _ UNITED STATES DISCTRICT JUDGE UNITED STATES DISTRICT JUDGE Dated: February 8, 2017. 15 DATED: 13 16 17 18 19 20 21 22 23 24 25 26 27 28 GARG GOLDEN LAW FIRM 3185 St. Rose Parkway Suite 325 Henderson, Nevada 89052 (702) 850-0202 3 of 3

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