Build Group, Inc et al v. National Union Fire Insurance Company of Pittsburgh, PA

Filing 25

STIPULATION AND ORDER re 24 TO CONTINUE DATES filed by Build Group, Inc. Case Management Statement due by 5/24/2018. Initial Case Management Conference set for 5/31/2018 09:30 AM in San Francisco, Courtroom 05, 17th Floor. Signed by Judge Edward M. Chen on 3/27/18. (bpf, COURT STAFF) (Filed on 3/27/2018)

1 HANSON BRIDGETT LLP
MILES C. HOLDEN,SBN 263342
2 mholden hansonbridgett.com
CANDI P. SHIH, SBN 294251
3 cshih(a~hansonbridgett.com
425 Market Street, 26th Floor
4 San Francisco, California 94105
Telephone: [phone]
5 Facsimile:4153 541-9366
6 Attorneys for Plaintiffs BUILD GROUP
INC. and PACIFIC STRUCTURES,IN~.
7
8
9

UNITED STATES DISTRICT COURT

10

NORTHERN DISTRICT OF CALIFORNIA

11
12
13 BUILD GROUP,INC. and PACIFIC
STRUCTURES,INC.,
14
Plaintiffs,
15
v.
16
NATIONAL UNION FIRE
17 INSURANCE COMPANY OF
PITTSBURGH,PA; GREENWICH
18 INSURANCE COMPANY;and
NAVIGATORS SPECIALTY
19 INSURANCE COMPANY,
20

CASE NO. 3:18-cv-00331-EMC
STIPULATED RE VEST TO
CONTINUE DATE AND
PROPOSED] ORDER
Local Rule 6-2]

E

Defendants.

21
22

Plaintiffs BUILD GROUP,INC. and PACIFIC STRUCTURES (collectively,

23 "Plaintiffs") and Defendants NATIONAL UNION FIRE INSURANCE COMPANY
24 OF PITTSBURGH,PA; GREENWICH INSURANCE COMPANY;and
25 NAVIGATORS SPECIALTY INSURANCE COMPANY (collectively,
26 "Defendants"), by and through their respective attorneys of record, hereby submit
27 this stipulated request for a continuance of case management dates, as stated below:
28

WHEREAS,Plaintiffs filed this action on January 16, 2018;

14237396.2

STIPULATED REQUEST TO CONTINUE DATES AND [PROPOSED]ORDER

1

WHEREAS,this insurance coverage dispute concerns Defendants' alleged

2 duty to indemnify Plaintiffs and reach a settlement in connection with various
3 underlying actions filed against Plaintiffs and coordinated in California Superior
4 Court, San Francisco County ("Underlying Claims");
5

WHEREAS,the Court issued an Order Setting Initial Case Management

6 Conference and ADR Deadlines on January 18, 2018, which set the following
7 schedule for this action:
8
9
10
11
12
13
14

Last day to:
• meet and confer re: initial disclosures, early settlement,
ADR process selection, and discovery plan
• file ADR Certification signed by Parties and Counsel
• file either Stipulation to ADR Process or Notice of Need
for ADR Phone Conference

March 29, 2018

Last day to file Rule 26(~ Report, complete initial disclosures April 12, 2018
or state objection in Rule 26(~ Report and file Case
Management Statement per Standing Order re Contents of
Joint Case Management Statement

15

April 19, 2018
at 9:30 AM

Initial Case Management Conference
16
17
18

WHEREAS,Defendant NAVIGATORS SPECIALTY INSURANCE

19 COMPANY filed its Answer on February 12, 2018;
20

WHEREAS,Plaintiffs and Defendant GREENWICH INSURANCE

21 COMPANY stipulated to extend the time for Defendant GREENWICH
22 INSURANCE COMPANY to file its Answer to April 6, 2018;
23

WHEREAS,Plaintiffs and Defendant NATIONAL UNION FIRE

24 INSURANCE COMPANY OF PITTSBURGH,PA stipulated to extend the time for
25 Defendant NATIONAL UNION FIRE INSURANCE COMPANY OF
26 PITTSBURGH,PA to file its Answer to April 6, 2018;
27

WHEREAS,Plaintiffs and Defendants (collectively,"Parties") and the

28 litigants in the Underlying Claims recently reached a settlement in principle
14237396.2

2

STIPULATED REQUEST TO CONTINUE DATES AND [PROPOSED]ORDER

1 ("Proposed Settlement"), but need additional time to negotiate and confirm final
2 terms and execute a final written agreement;
3

THEREFORE,the Parties request a continuance of certain dates to allow

4 sufficient time for the finalization of the Proposed Settlement so that the Court and
5 the Parties can conserve resources in the meantime, and the Parties specifically
6 request that the Court:
7

1.

Extend the deadline for Defendant GREENWICH INSURANCE

8 COMPANY and Defendant NATIONAL UNION FIRE INSURANCE COMPANY
9 OF PITTSBURGH,PA to file their respective Answers to and including Apri130,
10 2018 and,
11

2.

Continue the dates in the Court's Order Setting Initial Case

12 Management Conference and ADR Deadlines by approximately 40 days, as follows:
13

Dates From
Court's Order

Event

14
15
16
17
18
~ c~
20
21
22
23
24
25
26

March 29, 2018
Last day to:
• meet and confer re: initial
disclosures, early settlement, ADR
process selection, and discovery plan
• file ADR Certification signed by
Parties and Counsel
• file either Stipulation to ADR
Process or Notice of Need for ADR
Phone Conference

Proposed New
Dates
May 10, 2018

Last day to file Rule 26(~ Report,
complete initial disclosures or state
objection in Rule 26(~ Report and file
Case Management Statement per
Standing Order re Contents of Joint
Case Management Statement

April 12, 2018

May 24, 2018.

Initial Case Management Conference

April 19, 2018 at
9:30 AM

May 31, 2018

~~
,'~
1423396.2

STIPULATED REQUEST TO CONTINUE DATES AND [PROPOSED]ORDER

1

IT IS SO STIPULATED.

2
3 DATED: March 23. 2018

HANSON BRIDGETT LLP

4
/,c/ Candice P..S'hih
Bv:
MILES C. HOLDEN
CANDICE P. SHIH
Attorneys for Plaintiffs BUILD GROUP,
INC. and PACIFIC STRUCTURES,INC.

5
6
7
8
9 DATED: March 23.2018

WOLKIN CURRAN.LLP

10
/.r/ T~avid F. Mvers
Bv:
BRANDY L. WOLKIN
DAVID F. MYERS
Attorneys for Defendant NAVIGATORS
SPECIALTY INSURANCE COMPANY

11
12
13
14
15 DATED: March 23.2018

DUANE MORRIS LLP

16
/,s/.Ie,c.sica F,. T,a Lnnde
Bv:
MAX H. STERN
JESSICA E. LA LONDE
Attorneys for Defendant GREENWICH
INSURANCE COMPANY

17
18
19
20
21 DATED: March 23.2018

SACRO &WALKER LLP

22
23
24
25
26

/.s/ Richa~^d D. Bremer^
Bv:
JENNIFER YU SACRO
RICHARD D. BREMER
Attorneys for Defendant NATIONAL
UNION FIRE INSURANCE COMPANY
OF PITTSBURGH,PA

~~
fig .
142373962

4

STIPULATED REQUEST TO CONTINUE DATES AND [PROPOSED]ORDER

PURSUANT TO STIPULATION,IT IS ORDEREll that:
2

The Court hereby extends the deadline for Defendant GREENWICH

3 INSURANCE COMPANY and Defendant NATIONAL UNION FIRE
4 INSURANCE COMPANY OF PITTSBURGH,PA to file their respective Answers
5 to and including Apri130, 2018; and
6

The Court further hereby vacates the dates set in the Court's Order Setting

7 Initial Case Management Conference, and the Court sets the following dates for this
8 action:
9
10
11
12
l3
14
15
16
17

Event

New Date

Last day to:
• meet and confer re: initial disclosures, early settlement,
ADR process selection, and discovery plan
• file ADR Certification signed by Parties and Counsel
• file either Stipulation to ADR Process or Notice of Need
for ADR Phone Conference

May 10, 2018

Last day to file Rule 26(~ Report, complete initial disclosures May 24, 2018
or state objection in Rule 26(~ Report and file Case
Management Statement per Standing Order re Contents of
Joint Case Management Statement
May 3 l , 20l 8

Initial Case Management Conference

18
19 IT IS SO ORDEIZEll.
3/27/18

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EDWARD M. CHEN
U.S. District Court Judge

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UNIT
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14237396.2

STIPULATED REQUEST TO CONTINUE DATES AND [PROPOSED]ORDER