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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: (704) 338-6004 

Facsimile: (704) 338-6096 

PILLSBURY WINTHROP SHAW PITTMAN LLP 

JOHN R. HEISSE (SBN 134964) 

john.heisse@pillsburylaw.com 

WILLIAMS. HALE (SBN 260414) 

william.hale@pillsburylaw.com 

LAURA C. HURTADO (SBN 267044) 

laura.hurtaclo@pillsburylaw .com 

Four Embarcadero Center, 22nd Floor 

San Francisco, CA 94111-5998 

Telephone: ( 415) 983-1000 

Facsimile: (415) 983-1200 

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 

(714) 480-8500 I Fax: (714) 480-8533 

Counsel for Defendant North American 

Specialty Insurance Company 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

KIRLIN BUILDERS, LLC, f/k/a JOHN J. Case No.3: 17-cv-00608 JST 

20 KIRLIN SPECIAL PROJECTS, LLC, 

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Plaintiff, 

v .. 

NORTH AMERICAN SPECIALTY 

INSURANCE COMPANY, 

Defendant. 

AND RELATED CROSS-CLAIM 

JOINT STIPULATION AND 

[PROPOSED] ORDER CONTINUING 

CASE MANAGEMENT CONFERENCE 

AND OTHER PENDING DEADLINES 

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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 

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

served the Complaint on NASon March 7, 2017; 

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

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

May 12, 2017 to May 24, 2017; 

WHEREAS, NAS filed its answer to the Complaint and cross-claim (the "Cross-Claim") 

against Cross-Defendants, Federal Solutions Group, Inc, d/b/a Federal Construction, Bara 

Infoware, Inc., Selina Sing & Manjindar P. Singh on March 28, 2017 and served CrossDefendants on April12, 2017; 

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

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

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

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

WHEREAS, a Joint Case Management Statement is currently due by May 15, 2017 and 

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 

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

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 

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

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 

re~ources; 

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

stipulate and agree, through their respective counsel, as follows: 

1. The May 24, 2017 Case Management Conference shall be continued by twenty9 eight (28) days to June 21, 2017 at 2PM, or another date thereafter that is convenient for the 

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2. 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 

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

IT IS SO STIPULATED. 

16 Dated: April 26, 2017 By: 

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Dated: ()l-r! ~ (; 7 By: 

/s/ Laura C. Hurtado ~-·--·---LAURA C. HUR1"ADO 

Counsel for Plaintiff KIRLIN BUILDERS, LLC 

Counsel for D~fendant NORTH AMERICAN 

SPECIALTY INSURANCE COMPANY 

[PRbPOSED] ORDER 

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

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

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

2 June7,2017. 

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4 Dated: ------ THE HONORABLE JON S. TIGAR 

5 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 

April 27, 2017