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 BOLD, POLISNER, MADDOW,

 NELSON & JUDSON

 A PROFESSIONAL CORP.

 SUITE 325

 500 YGNACIO VALLEY ROAD

 WALNUT CREEK, CA 94596

 PHONE 925-933-7777

 FAX 925-933-7804

NSE v. Page Construction, et al.

Case No: C08-05171

Page 1

CRAIG L. JUDSON - 114926

SHARON M. NAGLE - 179124

Bold, Polisner, Maddow, Nelson & Judson

A Professional Corporation

500 Ygnacio Valley Road, Suite 325

Walnut Creek, CA 94596

(925) 933-7777 - telephone

(925) 933-7804 - facsimile

Attorneys for Plaintiff NORTHERN

STATES ELECTRIC

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

NORTHERN STATES ELECTRIC, a

California corporation, and the UNITED

STATES, for the use of NORTHERN

STATES ELECTRIC, a California

Corporation,

Plaintiffs

vs.

PAGE CONSTRUCTION COMPANY, a

California Corporation, ST. PAUL

TRAVELER’S, and DOES 1 through 10,

inclusive.

Defendants

 

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Case No. C08-05171

STIPULATION TO CONTINUE CASE

MANAGEMENT CONFERENCE

Plaintiff Northern States Electric and Defendants Page Construction Company and

St. Paul Traveler’s, by and between their respective counsel, hereby request a continuance of 

the April 23, 2010 Case Management Conference scheduled before the Honorable Charles

R. Breyer of the United States District Court.

The parties ask for this continuance because they recently attended a mediation in

this case, at which the parties agreed to pursue an alternative remedy and stay the litigation

Case 3:08-cv-05171-CRB Document 31 Filed 04/15/10 Page 1 of 2
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 BOLD, POLISNER, MADDOW,

 NELSON & JUDSON

 A PROFESSIONAL CORP.

 SUITE 325

 500 YGNACIO VALLEY ROAD

 WALNUT CREEK, CA 94596

 PHONE 925-933-7777

 FAX 925-933-7804

NSE v. Page Construction, et al.

Case No: C08-05171

Page 2

before this court. Page has agreed to file equitable adjustment claims with the United States

Government on behalf of NSE and with the assistance of NSE. 

Some claims have been submitted to the United States Government, which has

resulted in a revised change order and payment to NSE (thereby reducing the amount in

controversy). In addition, Page discovered an accounting error, which was rectified by an

additional payment to NSE. The parties are in the process of preparing additional equitable

adjustment claims and hope to have those submitted to the United States Government

shortly. In an effort to pursue this alternative remedy, the parties stipulate to continue the

Case Management Conference to a later date. The parties stipulate to continue the Case

Management Conference to June 25, July 2, or July 9, 1010. 

Date: April 7, 2010 BOLD, POLISNER, MADDOW, NELSON, &

JUDSON

By: /s/ 

 Sharon M. Nagle

 Attorneys for Northern States Electric

Date: April 7, 2010 MCINERNEY & DILLON

By: /s/ 

 LeCarie S. Whitfield

Attorneys for Page Construction and

Travelers Casualty and Surety Company

of America

ORDER

PURSUANT TO STIPULATION, the Case Management Conference set for April 23, 2010

is continued to , 2010. 

Dated: , 2010 By: 

United States District Judge

July 9

April 14

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORN

I

A

IT IS SO ORDERED

Judge Charles R. Breyer

Case 3:08-cv-05171-CRB Document 31 Filed 04/15/10 Page 2 of 2