Travelers Casualty and Surety Company of America v. K.O.O. Construction, Inc., et al

Filing 227

Order Granting Stipulation and Request to Extend Time to File Stipulation or Administrative Motion for Entry of Judgment.. Signed by Judge Joseph C. Spero on 11/9/18. (mllS, COURT STAFF) (Filed on 11/9/2018)

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Judge Joseph C. Spero
Date: 11/9/18

Attorneys for Plaintiff
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Travelers Casualty and Surety Company of America D I
CA
ST RIC T OF
Arthur G. Woodward (SBN 142914)
REYNOLDS MADDUX WOODWARD LLP
500 Auburn Folsom Road, Suite 210
Auburn, CA 95603
[phone]
[phone] (f)
[e-mail]
ER

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GRANTED

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UN
IT
ED

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Michael J. Timpane (SBN 115238)
Edward R. Stepans (SBN 154233)
SMTD LAW LLP
1999 Harrison Street, Suite 660
Oakland, California 94612-3584
[phone]
[phone] (f)
[e-mail]; [e-mail]

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ES DISTRI
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Attorneys for Defendants
K.O.O. Construction, Inc. and Keith Odister

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

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TRAVELERS CASUALTY AND
SURETY COMPANY OF
AMERICA, a Connecticut
corporation,

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Plaintiff,
v.
K.O.O. CONSTRUCTION, INC., a
California corporation; and KEITH
ODISTER, an individual, inclusive,

Case No. 316-CV-00518-JCS
STIPULATION AND REQUEST TO
EXTEND TIME TO FILE
STIPULATION OR
ADMINISTRATIVE MOTION FOR
ENTRY OF JUDGMENT
(Civil Local Rule 7-11)

Defendants.

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On November 5, 2018, this Court entered an order on the parties’ stipulation

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that a stipulation or an administrative motion for entry of judgment would be filed

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by November 8, 2018. (Dkt. No. 225.) The undersigned counsel have been

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working on a stipulation in lieu of such an administrative motion as required by

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SMTD L AW LLP
A LIMITED LIA BILITY
PART NER S HI P

STIPULATION AND REQUEST TO EXTEND TIME TO FILE STIPULATION OR ADMINISTRATIVE
MOTION FOR ENTRY OF JUDGMENT

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Civil Local Rule 7-11(a), but disagreements remain on its contents, particularly

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with regard to prejudgment interest. While significant progress has been made in

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closing the gap between the parties’ respective positions, the parties did not reach

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an agreement as to the language of stipulation to enter judgment as of the date of

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the filing of this document.

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The parties have made sincere good-faith efforts to agree upon the terms of a

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stipulated judgment. Undersigned counsel believe that further negotiations in the

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next week may allow the parties to come to an agreement on the total amount and

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terms of a stipulated judgment, thus sparing the Court the burden of considering a

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motion on entry of judgment. The parties therefore respectfully request that this

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Court give them another week to try to agree to the terms of a stipulated judgment,

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with the parties’ stipulation or an administrative motion being filed on or before

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November 15, 2018.

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Dated: November 8, 2018

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By:/s/ Edward R, Stepans
Michael Timpane
Edward R. Stepans
Attorneys for Plaintiff
TRAVELERS CASUALTY AND
SURETY COMPANY OF
AMERICA

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SMTD L AW LLP
A LIMITED LIA BILITY
PART NER S HI P

SMTD LAW LLP

Dated: November 8, 2018

REYNOLDS MADDUX
WOODWARD LLP
By: /s/ Arthur G. Woodward
Arthur G. Woodward
Attorneys for
Defendants/Counterclaimants
K.O.O. CONSTRUCTION, INC.
AND KEITH ODISTER
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STIPULATION AND REQUEST TO EXTEND TIME TO FILE STIPULATION OR ADMINISTRATIVE
MOTION FOR ENTRY OF JUDGMENT