Board of Trustees of the Painters and Floorcoverers Joint Committee v. Super Structures Inc.

1 MARC P. COOK Nevada State Bar No. 004574 GEORGE P. KELESIS Nevada State Bar No. 000069 COOK & KELESIS, LTD. S. 9th Street Las Vegas, Nevada 89101 Telephone: 702-737-7702 Facsimile: 702-737-7712 Email: [email protected] Attorneys for Defendants Super Structures Inc., dba Super Structures; Super Structures, Inc.,dba Super Structures; Tracey Reynolds, Robert Reynolds, Western National Mutual Insurance Company UNITED STATES DISTRICT COURT DISTRICT OF NEVADA BOARD OF TRUSTEES OF THE CASE NO. 2:18-CV-01364-GMN-GWF PAINTERS AND FLOORCOVERERS JOINT COMMITTEE; BOARD OF TRUSTEES OF THE EMPLOYEE PAINTERS' TRUST; BOARD OF TRUSTEES OF THE PAINTERS, GLAZIERS AND FLOORCOVERERS JOINT APPRENTICESHIP AND STIPULATION FOR EXTENSION OF JOURNEYMAN TRAINING TRUST; TIME FOR ALL PARTIES TO FILE BOARD OF TRUSTEES OF THE THEIR REPLIES TO RESPONSES IN PAINTERS, GLAZIERS AND OPPOSITION (ECF 51 AND 52) TO FLOORCOVERERS SAFETY TRAINING MOTIONS FOR SUMMARY TRUST FUND; BOARD OF TRUSTEES JUDGMENT (ECF 44 AND 50) OF THE SOUTHERN NEVADA PAINTERS AND DECORATORS AND (FIRST REQUEST) GLAZIERS LABOR-MANAGEMENT COOPERATION COMMITTEE TRUST; BOARD OF TRUSTEES OF THE SOUTHERN NEVADA GLAZIERS AND FABRICATORS PENSION TRUST FUND; PDCA/FCA INDUSTRY PROMOTION FUND; PAINTERS ORGANIZING FUND; SOUTHERN NEVADA PAINTERS AND GLAZIERS MARKET RECOVERY TRUST FUND; BOARD OF TRUSTEES OF THE INTERNATIONAL PAINTERS AND ALLIED TRADES INDUSTRY PENSION FUND; BOARD OF TRUSTEES OF THE FINISHING TRADES INSTITUTE; PAINTERS AND ALLIED TRADES LABOR- MANAGEMENT COOPERATION INITIATIVE, Plaintiffs, vs. SUPER STRUCTURES INC., a Nevada |corporation dba SUPER STRUCTURES; SUPER STRUCTURES, INC., a Nevada 3, |eorporation dba SUPER STRUCTURES; RACEY REYNOLDS, an individual; ROBERT REYNOLDS, an individual; ESTERN NATIONAL MUTUAL INSURANCE COMPANY, a Minnesota oporation; JOHN DOES I-XX, inclusive; land ROE ENTITIES I-XX, inclusive, 7 Defendants.

8 Defendants’, Super Structures, et al, and Plaintiffs’ Board of Trustees of the Painters and ? Floorcoverers Joint Committee, et al., so hereby stipulate and agree to extend the time set for filing their Replies to Responses in Opposition (ECF 51 and 52) to Motions for Summary M udgment (ECF 44 and 50) for one (1) week up to and including October 28, 2019.

12 It is therefore respectfully requested by and between the parties that this Court order a one 1) week extension up to and including October 28, 2019, in which the parties may file their M4 Replies to Responses in Opposition (ECF 51 and 52) to Motions for Summary Judgment (ECF 1S 4 and 50).

16 Respectfully submitted this __ day of October, 2019.

M OOK & KELESIS, LTD. CHRISTENSEN JAMES & MARTIN, CHTD /s/ Marc P. Cook, Esq. /s/ Wesley J. Smith, Esq.

29 [MARC P. COOK, ESQ. WESLEY J. SMITH, Esq.

Nevada Bar No. 004574 Nevada Bar No. 011871 [617 South 9" Street 7440 West Sahara Avenue Las Vegas, Nevada 89101 Las Vegas, Nevada 89117 Attorneys for Plaintiffs Board of Trustees Counsel for Defendants of the Painters & Floorcovers Joint 23 Committee. et al.

IT IS SO ORDERED.

25 .

6 Dated this_21 day of October, 2019.

27 Glorta Mi Navarro, District Judge UNITED STATES DISTRICT COURT Page 2 of 2