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Board of Trustees of Plumbers and Pipefitters Local 525 Health and Welfare Trust and Plan v. Strong Man Services, Inc.

United States District Court, D. Nevada

February 16, 2018

BOARD OF TRUSTEES OF THE PLUMBERS AND PIPEFITTERS LOCAL 525 HEALTH AND WELFARE TRUST AND PLAN; BOARD OF TRUSTEES OF THE PLUMBERS AND PIPEFITTERS UNION LOCAL 525 PENSION PLAN; AND BOARD OF TRUSTEES OF PLUMBERS AND PIPEFITTERS LOCAL UNION 525 APPRENTICE AND JOURNEYMAN TRAINING TRUST FOR SOUTHERN NEVADA, Plaintiffs,
v.
STRONG MAN SERVICES, INC. dba SMS Mechanical, a Nevada corporation; LINDA NASH, an individual; AFFORDABLE CONCEPTS, INC., a Nevada corporation, BENTAR DEVELOPMENT, INC., a Nevada corporation; B & R BUILDERS, INC. dba Breslin Builders, a Nevada corporation; DAKEM & ASSOCIATES, LLC, a Nevada limited liability company; KITTRELL JENSEN CONTRACTORS, LLC, a Nevada limited liability company; LAFARGO, INC. dba LaFargo Builders, a Nevada corporation; LEDCOR CONSTRUCTION, INC., a Washington corporation; NORTH WIND ENVIRONMENTAL, INC., an Arkansas corporation; THE PENTA BUILDING GROUP, LLC, a Nevada limited liability company; SCI CONSTRUCTION, L.P., a Texas limited partnership; SR CONSTRUCTION, INC., a Nevada corporation; STARKE, INC. dba Starke Contractors, a Nevada corporation; UHS OF DELAWARE, INC., a Delaware corporation; NORTH RIVER INSURANCE COMPANY aka Crum & Forster, a Pennsylvania corporation, Defendants.

          BROWNSTEIN HYATT FARBER SCHRECK, LLP, Christopher M. Humes, Adam P. Segal, Esq. Becky A. Pintar, Esq. Bryce C. Loveland, Esq. Christopher M. Humes, Esq. Attorneys for Plaintiffs

          PINTAR ALBISTON, LLP Becky A. Pintar, Esq. Bryan L. Albiston, Esq. Ryan W. Reynolds, Esq. Attorneys for Defendant, Affordable Concepts, Inc.

          FISHER & PHILLIPS, LLP David B. Dornak David B. Dornak, Esq. Allison Kheel, Esq. Attorneys for Defendant, Linda Nash; Strong Man Services, Inc., dba SMS Mechanical; Bentar Development, Inc.; Kittrell Jensen Contractors, LLC; LaFargo, Inc. dba LaFargo Builders; Ledcor Construction, Inc.; North Wind Environmental, Inc.; SCI Construction, L.P.; SR Construction, Inc.; Starke, Inc., dba Starke Contractors; UHS of Delaware, Inc.

          STIPULATION AND ORDER TO EXTEND DISCOVERY FIRST REQUEST

         Plaintiffs Boards of Trustees of the Plumbers and Pipefitters Union Local 525 Health and Welfare Trust and Plan, the Plumbers and Pipefitters Union Local 525 Pension Plan, and the Plumbers and Pipefitters Local Union 525 Apprentice and Journeyman Training Trust for Southern Nevada (collectively "Trust Funds"), by and through their counsel of record Brownstein Hyatt Farber Schreck, LLP; Defendant Affordable Concepts, Inc., ("Defendant Affordable") by and through its counsel of record Pintar Albiston, LLP; and Defendants Linda Nash, Strong Man Services, Inc., dba SMS Mechanical, Bentar Development, Inc., Kittrell Jensen Contractors, LLC, LaFargo, Inc. dba LaFargo Builders, Ledcor Construction, Inc., North Wind Environmental, Inc., SCI Construction, L.P., SR Construction, Inc., Starke, Inc., dba Starke Contractors and UHS of Delaware, Inc. (collectively "Strong Man Defendants") (Defendant Affordable and Strong Man Defendants collectively referred to as "Defendants"), by and through their counsel of record Fisher & Phillips, LLC, hereby stipulate and agree that the Scheduling Order (EFC No. 71) in this case be extended sixty (60) days from the current discovery deadline of February 19, 2018, to April 20, 2018, and the dispositive motion deadline be extended from March 21, 2018, to May 21, 2018. This is first request to extend the discovery deadline and is being made more than 21 days prior to the close of discovery.

         A. DISCOVERY COMPLETED:

1. 10/19/2017 Defendant Affordable's Initial Disclosures and Witnesses.
2. 10/20/2017 Trust Funds' Initial Disclosures and Witnesses.
3. 11/1/2017 Trust Funds' Revised Initial Disclosures and Witnesses.
4. 12/15/2017 Defendant Strong Man's and Defendant Linda Nash's Initial Disclosures and Witnesses.
5. 12/19/2017 Defendant LaFargo's Initial Disclosures and Witnesses.
6. 12/19/2017 Defendant North Wind's Initial Disclosures and Witnesses.
7. 12/19/2017 Defendant Starke's Initial Disclosures and Witnesses.
8. 12/22/2017 Trust Funds' First Supplemental Initial Disclosures.
9. 12/22/2017 Trust Funds' First Admissions to Defendant Affordable.
10. 12/22/2017 Trust Funds' First Admissions to Defendant Bentar Development, Inc.
11. 12/22/2017 Trust Funds' First Admissions to Defendant Kittrell Jensen Contractors, LLC.
12. 12/22/2017 Trust Funds' First Admissions to Defendant LaFargo, Inc.
13. 12/22/2017 Trust Funds' First Admissions to Defendant Ledcor Construction, Inc.
14. 12/22/2017 Trust Funds' First Admissions to Defendant Linda Nash.
15. 12/22/2017 Trust Funds' First Admissions to Defendant North Wind Environmental, Inc.
16. 12/22/2017 Trust Funds' First Admissions to Defendant SCI ...

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