Kirlin Builders, LLC v. North American Specialty Insurance Company

Filing 24

STIPULATION AND ORDER re 23 STIPULATION WITH PROPOSED ORDER Joint Stipulation and [Proposed] Order Continuing Case Management Conference and Other Pending Deadlines filed by Kirlin Builders, LLC. Case Management Statement due by 6/7/2017. Initial Case Management Conference set for 6/21/2017 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on April 27, 2017. (wsn, COURT STAFF) (Filed on 4/27/2017)

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BRADLEY ARANT BOULT CUMMINGS LLP
MICHAEL W. KNAPP (SBN 200422)
mknapp@braclley. com
Hearst Tower
214 North Tryon Street, Suite 3700
Charlotte, NC 28202
Telephone: [phone]
Facsimile: [phone]
PILLSBURY WINTHROP SHAW PITTMAN LLP
JOHN R. HEISSE (SBN 134964)
[e-mail]
WILLIAMS. HALE (SBN 260414)
[e-mail]
LAURA C. HURTADO (SBN 267044)
laura.hurtaclo@pillsburylaw .com
Four Embarcadero Center, 22nd Floor
San Francisco, CA 94111-5998
Telephone: [phone]
Facsimile: [phone]
Counselfor Plaint([( KIRLIN BUILDERS, LLC
Craig E. Guenther, bar No. 126134
f§gJ-tenthen(~{boothmi tchel. com

Booth, Mitchel & Strange LLP
701 South Parker Street, Suite 6500
Orange,CA 92868-4733
[phone] I Fax: [phone]
Counsel for Defendant North American
Specialty Insurance Company

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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KIRLIN BUILDERS, LLC, f/k/a JOHN J.
KIRLIN SPECIAL PROJECTS, LLC,

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Plaintiff,
v ..

Case No.3: 17-cv-00608 JST
JOINT STIPULATION AND
[PROPOSED] ORDER CONTINUING
CASE MANAGEMENT CONFERENCE
AND OTHER PENDING DEADLINES

NORTH AMERICAN SPECIALTY
INSURANCE COMPANY,
Defendant.

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AND RELATED CROSS-CLAIM
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STIPULATION AND [PROPOSED] ORDER CONTINUING
CMC AND OTHER PENDING DEADLINES
CASE NO. 3:17-cv-00608 JS

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This Stipulation is entered into by and among Plaintiff Kirlin Builders, LLC ("Kirlin")
and Def(mdant/Cross-PlaintiffNotih American Specialty Insurance Company (''NAS'')
(collectively "the Parties"), by and thmugh their respective counsel;
WHEREAS, Kirlin filed a complaint in the above-entitled action in the United States

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District Court for the Northem District of California, on February 7, 2017 (the "Complaint") and
served the Complaint on NASon March 7, 2017;

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WHEREAS, on February 23, 2017, the Clerk continued the date ofthe Case Management

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Statement from May 5, 2017 to May 15, 2017 and the Initial Case Management Conference from

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May 12, 2017 to May 24, 2017;
WHEREAS, NAS filed its answer to the Complaint and cross-claim (the "Cross-Claim")

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against Cross-Defendants, Federal Solutions Group, Inc, d/b/a Federal Construction, Bara
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Infoware, Inc., Selina Sing & Manjindar P. Singh on March 28, 2017 and served CrossDefendants on April12, 2017;

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WHEREAS, Cross-Defendants have not yet answered the Cross-Claim;

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WHEREAS, Cross-Defendants' answer to the Cross-Claim is currently due May 3, 2017;

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WHEREAS, on Apri121, 2017, the Parties met and conferred regarding the initial

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disclosures, early settlement, ADR process selection, and the discovery plan;

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WHEREAS, a Joint Case Management Statement is currently due by May 15, 2017 and
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the Initial Case Management Conference is set for May 24, 2017 (Dlct. No. 10);
WHEREAS, the Parties agree that a twenty-eight (28) day continuance of the Case

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Management Conference and related pending deadlines is necessary so as to allow the

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participation of Cross-Defendants, who have yet to answer the Cross-Claim;

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STIPULATION AND [PROPOSED] ORDER CONTINUING
CMC AND OTHER PENDING DEADLINES
CASE NO. 3:17-cv-00608 JS

WHEREAS, the Parties agree that a twenty-eight (28) day continuance of the Case

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Managem.ent Conference and related pending deadline~ will permit more efficient case

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management, will serve the interests of judicial economy, and will conserve Party and Court

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re~ources;

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NOW, THEREFORE, pursuant to Civil Local Rules 6-2(a) and 7-12, the Parties hereby

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stipulate and agree, through their respective counsel, as follows:
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eight (28) days to June 21, 2017 at 2PM, or another date thereafter that is convenient for the
Court.

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The May 24, 2017 Case Management Conference shall be continued by twenty-

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The deadline to file the Joint Case Management Statement, Rule 26(±) Report,

complete initial disclosures, or state objections in Rule 26(±) Report shall be continued to and

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including fourteen (14) days prior to the new date for the Case Management Conference.
IT IS SO STIPULATED.

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Dated: April 26, 2017

By:
/s/ Laura C. Hurtado
C. HUR1"ADO

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~-·--·---LAURA

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Counsel for Plaintiff KIRLIN BUILDERS, LLC

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Dated:

()l-r! ~(; 7

By:

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Counsel for D~fendant NORTH AMERICAN
SPECIALTY INSURANCE COMPANY

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[PRbPOSED] ORDER

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Pursuant to the parties' stipulation and good cause having been shown, it is hereby

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ordered that the case management conference c1.mently set for May 24, 2017 at 2PM is continued

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to June 21, 2017 at 2PM. The deadline to file the Joint Case Management Statement, Rule 26(±)

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STlPULATION AND [PROPOSED) ORDER CONTfNUJNG
CMC AND OTHER PENDING DEADUNES
CASE NO.3: 17-cv-00608 JS

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Report, complete initial disclosures, m· state objections in Rule 26(f) Report shall be continued to

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June7,2017.

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Dated: April 27,- - - - - 2017

THE HONORABLE JON S. TIGAR
UNITED STATES DISTRICT JUDGE

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STIPULATION AND [PROPOSED] ORDER CONTINUING
CMC AND OTHER PENDING DEADLINES
CASE NO.3: 17-cv-00608 JS