JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE AND OTHER PENDING DEADLINES

JON S. TIGAR, District Judge.

This Stipulation is entered into by and among Plaintiff Kirlin Builders, LLC ("Kirlin") and Defendant/Cross-Plaintiff North American Specialty Insurance Company ("NAS") (collectively "the Parties"), by and through their respective counsel;

WHEREAS, Kirlin filed a complaint in the above-entitled action in the United States District Court for the Northern District of California, on February 7, 2017 (the "Complaint") and served the Complaint on NAS on March 7, 2017;

WHEREAS, on February 23, 2017, the Clerk continued the date of the 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 Cross-Defendants on April 12, 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 April 21, 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 (Dkt. 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;

WHEREAS, the Parties agree that a twenty-eight (28) day continuance of the Case Management Conference and related pending deadlines will permit more efficient case management, will serve the interests of judicial economy, and will conserve Party and Court resources;

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 twenty-eight (28) days to June 21, 2017 at 2PM, or another date thereafter that is convenient for the Court.

2. The deadline to file the Joint Case Management Statement, Rule 26(f) Report, complete initial disclosures, or state objections in Rule 26(f) Report shall be continued to and including fourteen (14) days prior to the new date for the Case Management Conference.

IT IS SO STIPULATED.

[PROPOSED] ORDER

Pursuant to the parties' stipulation and good cause having been shown, it is hereby ordered that the case management conference currently 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(f) Report, complete initial disclosures, or state objections in Rule 26(f) Report shall be continued to June 7, 2017.