Free Stipulation - District Court of California - California

Case 3:07-cv-02564-CRB Document 3 Filed 06/28/2007 Page 1 of 4
1 RICHARD T. BOWLES #46234
KENNETH G. J ONES #196868
2 BOWLES & VERNA LLP
3 2121 N. California Boulevard, Suite 875
Walnut Creek, Califomia 94596
.4 Telephone: (925) 9356300
Facsimile: (925) 935~037l
5 [email protected]
6 [email protected]
Attorneys for Plaintiff `
7 WEBCOR CONSTRUCTION, INC. dba `WEBCOR BUILDERS
8 UNITED STATES DISTRICT COURT
9 NORTHERN DISTRICT OF CALIFORNIA — SAN FRANCISCO DIVISION
1 0
UNITED STATES of AMERICA for the Use and Case No. C07—2564 CRB
ll Benefit of WEBCOR CONSTRUCTION, INC.
dba WEBCOR BUILDERS, and VVEBCOR STIPULATION AND [PROPOSED]
12 CONSTRUCTION, INC. dba WEBCOR S ORDER T0 EXTEND RESPONSE
13 BUILDERS, DEADLINE
14 Plaintiffs,
I5 v. . _
16 DICK/MORGANTI, a joint venture, DICK I
17 CORPORATION, THE MORGANTI GROUP,
AMERICAN CASUALTY COMPANY OF
18 READING, PA, NATIONAL UNION FIRE
19 INSURANCE COMPANY OF PITTSBURGH,
PA, and DOES 1 through 10, inclusive,
20
Defendants.
21 I .
22 ‘ . ‘
2 The parties hereto stipulate that good cause exists to extend the time for all defendants to
I 24 respond to Webcor’s Complaint herein to and including September 17, 2007. The parties herein are
25 currently involved in good faith efforts to resolve this complex construction dispute involving the
26 newly constructed GSA Federal Building in San Francisco. By allowing the defendants herein to have
27 until September 17, 2007 to respond to Webcofs Complaint, signincant judicial resources will be
00236696
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suse sn I -
Walnut Creek 945 96

Case 3:07-cv-02564-CRB Document 3 Filed 06/28/2007 Page 2 of 4
{ conserved in that defendants may have received a response back from the Owner regarding the items
2 contained in the Complaint.
3 There have been no previous time modifications in this case and the current Case Management
4 Conference is scheduled for August 24, 2007. The parties herein request that this Case Management
5 Conference be rescheduled in November 2007.
6 mann; ,2007 nowtns at vienna LLP
’ &}0,/—\._./
0 1
KENNETH G. JONES
9 Attorneys for Plaintiff Webcor
10 Construction, Inc. dba Webcor Builders
I I J
12 02-\T0I>= __;’i·_;L...» 2007 Pncro-ta & Ann/tmsou, nc;
*3 azéal
By _
14 RA OND . BUDDIE_ _
A _ rneys for Defendant Dick Morganti,
15 ick Corporation, The Morganti Group
16 J -
17 DA'FBD= 2007 Pncxnn & AnaAMsoN,1>.c. 0
*8 4,26;;
By _
19 OND . BUDDIE ·
20 omeys for Defendant American Casualty
Company of Reading, Pennsylvania
21
22 ¤ATBD= 2007 PECKAR & nannmson, ac.
23 ,
24 By ji ,
OND M. BUDDIE
25 ttomeys for Defendant National Union
6 Fire Insurance Company of Pittsburgh,
2 Pennsylvania
27 _
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Case 3:07-cv-02564-CRS Document 3 Filed 06/28/2007 Page 3 of 4
1 WROPOSED] ORDER
2 The Court has considered the Stipulation submitted by the parties, and good cause appearing, it
3 is hereby Ordered that the deadline for all defendants to respond to Webcor’s Complaint herein shall
` 4 be extended to and include September 17, 2007i
5 It is further ordered that the Case Management Conference scheduled for August 24, 2007 be
6 continued to , 2007.
p 7
8 PURSUANT TO STIPULATION, IT IS SO ORDERED.
9 Dated: ,2007 7
United States District Court Judge
I0 Northern District Court of California
1 1
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Case 3:07-cv-02564-CRB Document 3 Filed 06/28/2007 Page 4 of 4
1 PROOF OF SERVICE
USDC Northern District of California, Case No. C0'/»2564 CRB ‘
2
I, the undersigned, declare as follows: I am a citizen ofthe United States, over the age of IS years, and not a party
3 to, or interested inthe within entitled action. I am an employee of BOWLES & VERNA LLP, and my business address is
2121 N. California Blvd., Suite 875, Walnut Creek, California 94596.
4
On June 28, 2007, I served the following docurnent(s):
5
STIPULATION ANI) {PROPOSED] ORDER TO EXTEND RESPONSE DEADLINE
6
on the following parties in this action addressed as follows;
7
Raymond M. Buddie
8 PECKAR & ABRAMSON, P.C.
250 Montgomery Street
9 l.6tl1 Floor
San Francisco, CA 94104
I0 tel. +1 415.837.%*68
fax +1415.8%*.1320
l l
I 2
WXXX BY MAIL.: I caused each such envelope, with postage thereon fully paid, to be placed in thc United States mail at
13 Walnut Creek, California. I am readily familiar with the business practice for collection and processing of mail in
this oftlce. That in the ordinary course of business said docurnent(s) would be deposited with the U.S. Postal
14 Service in Walnut Creek on that same day. I understand that service shall be presumed invalid upon motion of a
party served if the postal cancellation date or postage meter date on the envelope is more than one day after the
15 date of deposit for mailing contained on this affidavit.
16 ___ BY YERSONAL SERVICE: I delivered each such envelope by hand to each party addressee above.
17 _____ BY OVERNIGHT DELIVERY: I caused each envelope, with delivery fees provided for, to be deposited in a
box regularly maintained by UPS/Federal Express. I ani readily familiar with Bowles & Venia's practice for
IS collection and processing of correspondence for overnight delivery and know that in the ordinary course of
Bowles & Verna's business practice the document(s) described above will be deposited in a box or other facility
19 regularly maintained by UPS/Federal Express or delivered to an authorized courier or driver authorized by
UFS/Federal Express to receive documents on the same date that it is placed at Bowles & Verna for collection.
20 `
BY FACSIMILE: By use of facsimile machine number (925) 935»037l , I served a copy ofthe within .
2i docurnent(s) on the above interested parties at the facsimile numbers listed above. The transmission was reported
as complete and without error. The transmission report was properly issued by the transmitting facsimile .
22 machine.
23 I declare under penalty of perjury under the laws ofthe State of California that the foregoing is true and correct.
Executed on June 28, 2007, at Walnut Creek, California.
24 ,/
25 ` O
rica L. ington `
26
27
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Bowies & Verna LLP
2l 21 N. California Blvd.
Suite 875
Walnut Creek 94596 .

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