Avcon Constructors, Inc. v. K.O.O. Construction, Inc. et al
Filing
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STIPULATION and ORDER TO EXTEND DISCOVERY DEADLINES signed by District Judge Troy L. Nunley on 1/11/18. The deadline to complete Discovery is CONTINUED from 1/16/18 4/13/2018. The deadline for designating Expert Witnesses is CONTINUED from 3/19/18 to 4/23/2018. (Mena-Sanchez, L)
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John E. Borba, Esq. [SBN: 169463]
Kristen Frizzell Kerns, Esq. [SBN: SBN 221384]
Borba Frizzell Kerns, P.C.
50 Old Courthouse Square, Ste. 605
Santa Rosa, CA 95404
(707) 578-7000
(707) 578-7003 Fax
Attorneys for Plaintiff
Avcon Constructors, Inc.
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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UNITED STATES GOVERNMENT
FOR THE USE AND BENEFIT OF
AVCON CONSTRUCTORS, INC.,
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v.
K.O.O CONSTRUCTION INC.;
TRAVELERS CASUALTY AND
SURETY COMPANY; and DOES 1-50
Defendants.
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STIPULATION TO EXTEND
DISCOVERY DEADLINES
Plaintiff,
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Case No.: 16-cv-00478-TLN-KJN
_______________________
The parties to this action hereby stipulate and
agree
to
extend
the
action for 90 days.
because
the
representing
law
discovery
cutoff
dates
in
this
Good cause exists for doing so,
office
plaintiff,
of
Borba
AVCON
Frizzell
&
CONSTRUCTORS,
Kerns
Inc.,
located in Santa Rosa, was significantly impacted by
the destructive fires in and around Santa Rosa.
Not
only was the office closed or functioning in just a
limited capacity during the fires, but a Shareholder,
Kristen Frizzell Kerns, who is the attorney who handles
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the
day
to
day
activities
of
this
matter
and
a
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paralegal, suffered severe property loss as well, which
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caused continuing disruption after the fires as well.
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The parties realize that this is the second
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extension of time stipulated in this case. The parties
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have agreed to mediate the case and are working on the
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selection of a mediator. If the case is not resolved
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through
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operatively in good faith between themselves and with
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the Court to solve any problems that may arise out of
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this
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lawsuit. Trial in this matter is set for October 15,
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2018.
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trial date.
mediation,
unforeseen
the
setback
parties
to
the
commit
to
prosecution
work
of
co-
this
The parties are not seeking a continuance of the
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The deadline to complete discovery, as set forth in
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the Stipulation to Extend Discovery Deadlines and Order
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dated October 17, 2017 (Docket no. 17), is therefore
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stipulated to be continued from January 16, 2018 to
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April 13, 2018.
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The deadline for designating expert witnesses as
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set in the Stipulation to Extend Discovery Deadlines
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and Order dated October 17, 2017 (Docket no. 17) is
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stipulated to be continued from March 19, 2018 to April
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23, 2018.
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////
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Dated:
January 4, 2018
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BORBA FRIZZELL KERNS
By: /s/ John Borba
John Borba
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Attorneys for Plaintiff
UNITED STATES GOVERNMENT for
the use and benefit of AVCON
CONSTRUCTORS, INC.
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Dated:
January 4, 2018
REYNOLDS MADDUX
WOODWARD
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By: /s/ Arthur Woodward
Arthur Woodward
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Attorneys for Defendant
K.O.O. CONSTRUCTION, INC.
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Dated:
January 4, 2018
SMTD LAW LLP
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By: /s/ Edward R. Stepans
Michael J. Timpane
Edward R. Stepans
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Attorney for Defendant
TRAVELERS CASUALTY AND
SURETY COMPANY OF AMERICA
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IT IS SO ORDERED.
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Dated: January 11, 2018
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Troy L. Nunley
United States District Judge
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