AMEC Environment & Infrastructure, Inc. v. Integral Consulting, Inc. et al

Filing 253

STIPULATION AND ORDER allowing for a 30-day continuance for the close of discovery to June 26, 2015 and vacating and resetting the dispositive motion hearing deadline for July 31, 2015. Signed by Judge Samuel Conti on 6/17/2015. (sclc1, COURT STAFF) (Filed on 6/18/2015)

Case3:12-cv-01735-SC Document252 Filed05/21/15 Page1 of 3

1 Matthew F. Miller, Bar No. 172661
[e-mail]
2 Robert J. Nolan, Bar No. 235738
[e-mail]
3 Wallace E. Smith, Bar No. 112091
[e-mail]
4 CARROLL, BURDICK & McDONOUGH LLP
Attorneys at Law
5 44 Montgomery Street, Suite 400
San Francisco, California 94104
6 Telephone:
415.989.5900
Facsimile:
415.989.0932
7
Attorneys for Plaintiff AMEC Environment &
8 Infrastructure, Inc.
9

UNITED STATES DISTRICT COURT

10

NORTHERN DISTRICT OF CALIFORNIA

11

SAN FRANCISCO DIVISION

12 AMEC ENVIRONMENT &
INFRASTRUCTURE, INC.,
13
Plaintiff,
14
v.
15
INTEGRAL CONSULTING, INC.,
16 EDWARD P. CONTI, an individual,
MATTHEW HILLYARD, an individual, and
17 DAVID AVERILL, an individual,
18

Case No. CV 12-01735 SC (NC)
NOTICE OF SETTLEMENT AND
STIPULATION AND ORDER TO
CONTINUE DISCOVERY DEADLINE
AND DISPOSITIVE MOTION DEADLINE
TO FINALIZE SETTLEMENT
AGREEMENT

Defendants.

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CARROLL, BURDICK &
MCDONOUGH LLP
ATTORNEYS AT LAW

SAN FRANCISCO

4827-5608-0673.1CBM-SF\SF658697-1

Case No. CV 12-01735 SC (NC)
NOTICE OF SETTLEMENT AND STIPULATION AND ORDER TO CONTINUE DISCOVERY DEADLINE

Case3:12-cv-01735-SC Document252 Filed05/21/15 Page2 of 3

1

WHEREAS, on May 6, 2015, the parties agreed to a settlement of this case and a related

2 coverage case pending in the United States District Court for the Western District of Washington;
3

WHEREAS, the parties are in the process of finalizing a formal settlement agreement,

4 which they expect to be completed within two weeks;
5

WHEREAS, discovery presently closes on May 29, 2015, and the Court recently ordered

6 AMEC to produce additional documents by May 27, 2015;
7

WHEREAS, the dispositive motion hearing deadline is presently set for June 26, 2015

8 requiring such motion to be filed by May 22, 2015.
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WHEREAS, to finalize the settlement agreement, the parties have agreed to a mutual stay

10 of all discovery and litigation in this action, and have agreed to continue all document productions
11 and depositions to June 2015;
12

WHEREAS, the parties have agreed to a 30-day continuance of the discovery deadline and

13 a continuance of the dispositive motion hearing deadline to July 31, 2015 to allow the parties to
14 finalize the terms of the settlement agreement;
15

WHEREAS, in the event the parties are not able to finalize the formal settlement

16 agreement within two weeks, the parties reserve the right to seek further continuances from the
17 Court of discovery and other scheduled dates if the circumstances require it for good cause.
18

WHEREAS the parties request that the Court enter an order allowing for a 30-day

19 continuance for the close of discovery to allow the parties to finalize the settlement agreement
20 such that all discovery will close on June 29, 2015;
21

WHEREAS, the parties request that the dispositive motion hearing deadline presently set

22 for June 26, 2015, be vacated and re-set for July 31, 2015, in accordance with the continuance of
23 the discovery cutoff.
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NOW THEREFORE, IT IS HEREBY STIPULATED by and between the parties hereto

25 through their respective attorneys of record as follows:
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The parties stipulate to continue the close of discovery in this case to June 29, 2015 and

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CARROLL, BURDICK &
MCDONOUGH LLP
ATTORNEYS AT LAW

SAN FRANCISCO

4827-5608-0673.1CBM-SF\SF658697-1

Case No. CV 12-01735 SC (NC)
-2NOTICE OF SETTLEMENT AND STIPULATION AND ORDER TO CONTINUE DISCOVERY DEADLINE

Case3:12-cv-01735-SC Document252 Filed05/21/15 Page3 of 3

1 that the dispositive motion hearing deadline presently set for June 26, 2015, be vacated and re-set
2 for July 31, 2015.
3

IT IS SO STIPULATED.

4 Dated: May 21, 2015.

CARROLL, BURDICK & McDONOUGH LLP

5

By

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7

/s/Robert J. Nolan
Robert J. Nolan
Attorneys for Plaintiff AMEC Environment &
Infrastructure, Inc.

8 Dated: May 21, 2015.

LEWIS, BRISBOIS, BISGAARD & SMITH LLP

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By

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/s/Leo Bautista
Leo Bautista
Attorneys for Defendant Integral Consulting, Inc.

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Dated: May 21, 2015.

By

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BURNHAM BROWN
/s/Brendan Brownfield
Brendan Brownfield
Attorneys for Defendants Edward P. Conti and
Matthew Hillyard and David Averill

I, Robert Nolan, hereby attest that I have the concurrence of the above counsel in the filing

17 of this document.
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19

ORDER
PURSUANT TO STIPULATION, IT IS HEREBY ORDERED the close of discovery in

20 this action is continued to June 29, 2015, and that the dispositive motion hearing deadline
21 presently set for June 26, 2015, is vacated and re-set to July 31, 2015 to allow the parties time to
22 finalize the settlement agreement.
23

IT IS SO ORDERED.

24 DATED:

2015.

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HONORABLE SAMUEL CONTI
UNITED STATES DISTRICT JUDGE

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CARROLL, BURDICK &
MCDONOUGH LLP
ATTORNEYS AT LAW

SAN FRANCISCO

4827-5608-0673.1CBM-SF\SF658697-1

Case No. CV 12-01735 SC (NC)
-3NOTICE OF SETTLEMENT AND STIPULATION AND ORDER TO CONTINUE DISCOVERY DEADLINE