Opinion
CASE NO. C 12-6490 SI
05-02-2013
GREENMARC, LLC, Mark Green, Manager Member, Plaintiff, v. JOSEPH B. IFFLA, et al., Defendants.
Karl R. Morthole (CA Bar No. 112565) LAW OFFICES OF KARL R. MORTHOLE Attorney for Plaintiff GREENMARC, LLC Mark Green, Manager Member BARG COFFIN LEWIS & TRAPP LLP Joshua A. Bloom, Attorney for Defendant CARL R. HEINEMANN, individually HARRELSON & ASSOCIATES Thomas M. Harrelson, Attorney for Defendants JOSEPH B. IFFLA, individually and dba PERFORMEX MACHINING COMPANY, and PERFORMEX MACHINING, INC. PIERCE & SHEARER LLP Stacy Y. North, Attorney for Defendants HOFFMAN METAL PRODUCTS, INC., and HARRY W. HOFFMAN, individually and as an officer, director and owner of HOFFMAN METAL PRODUCTS
Karl R. Morthole (CA Bar No. 112565)
LAW OFFICES OF KARL R. MORTHOLE
Attorney for Plaintiff
GREENMARC, LLC
Mark Green, Manager Member
STIPULATION RE: EXTENSION OF
TIME FOR RESPONSE TO
COMPLAINT AND OTHER PRE-
CMC DEADLINES
The undersigned parties ("Parties"), by and through their attorneys, hereby stipulate as follows:
1. The Parties, in addition to their meet and confer obligations, have engaged in informal settlement discussions and document exchange. A technical report documenting assessment of environmental conditions and remedy alternatives with regard to the subject property at 1007 and 1011 Bransten Road in San Carlos, California is imminent, and will provide a foundation for further settlement discussions, cost allocation, and formulation of a case discovery plan. In order to afford the Parties proper time to evaluate and discuss the forthcoming report and in the interest of judicial economy, the Parties agree that continuance of various case deadlines is in the interests of the Parties and the Court. The Parties believe that such considerations are more properly made prior to an initial case management conference ("CMC").
2. Accordingly, the Parties agree to the following extensions of upcoming Court deadlines:
A. the initial CMC currently scheduled for May 10, 2013 shall be extended to June 28, 2013, at 2:30 p.m. in Courtroom No. 10 on the Nineteenth Floor of the Federal Building;
B. the time to answer or otherwise respond to the Complaint (ECF No. 1) shall be extended from May 28, 2013 to July 17, 2013;
C. the last day to file the Rule 26(f) Report, complete initial disclosures (except as set forth in paragraph 2.D. below) and/or state objection in a Rule 26(f) Report and file the first Case Management Statement shall be extended from May 3, 2013 to June 21, 2013; and
D. the last day to complete initial disclosures on those subjects agreed by the parties, during their meet and confer conference on April 18, 2013, to be useful to continued settlement discussions, shall be extended from May 3, 2013 to May 22, 2013.
3. The terms of the Case Management Conference Order filed February 28, 2013 (ECF No. 10) and the Stipulation filed on March 27, 2013 (ECF No. 12) will otherwise remain in effect. IT IS SO STIPULATED.
LAW OFFICES OF KARL R. MORTHOLE
_______________
Karl R. Morthole, Attorney for
Plaintiff GREENMARC, LLC
BARG COFFIN LEWIS & TRAPP LLP
_______________
Joshua A. Bloom, Attorney for Defendant
CARL R. HEINEMANN, individually
HARRELSON & ASSOCIATES
_______________
Thomas M. Harrelson, Attorney for
Defendants JOSEPH B. IFFLA, individually
and dba PERFORMEX MACHINING
COMPANY, and PERFORMEX
MACHINING, INC.
PIERCE & SHEARER LLP
by _______________
Stacy Y. North, Attorney for Defendants
HOFFMAN METAL PRODUCTS, INC.,
and HARRY W. HOFFMAN, individually
and as an officer, director and owner of
HOFFMAN METAL PRODUCTS
IT IS SO ORDERED.
_______________
Hon. Susan Illston,
UNITED STATES DISTRICT JUDGE
Karl R. Morthole (CA Bar No. 112565)
LAW OFFICES OF KARL R. MORTHOLE
57 Post Street, Suite 804
San Francisco, California 94104
Tele: (415) 986-0227
Fax: (415) 986-1734
E-mail: karl@mortholelaw.com
Attorney for Plaintiff
GREENMARC, LLC
Mark Green, Manager Member
GREENMARC, LLC, Mark Green, Manager Member, Plaintiff,
v.
JOSEPH B. IFFLA, et al., Defendants.
CASE NO. C 12-6490 SI
CERTIFICATE OF SERVICE
I declare that on the date set forth below, I served the following document:
1. STIPULATION RE: EXTENSION OF TIME FOR RESPONSE TO COMPLAINT AND OTHER PRE-CMC DEADLINESon two Defendants listed below, whom I served by regular U.S. Mail, postage pre-paid, at the following addresses, c/o counsel, and to whom notice was electronically mailed, to:
Joseph B. Iffla, individually and dba Performex Machining Company, and as registered agent of Performex Machining, Inc., 963 Terminal Way San Carlos, CA 94070, c/o Thomas M. Harrelson, Esq., Harrelson & Associates, 533 Airport Blvd Ste 325, Burlingame, CA 94010, tharrelson@harrelsonlaw.com, authorized to accept service; andAnd on one Defendant listed below, whom I served by E-Filing through the Northern District ECF site, c/o counsel, and to whom notice was electronically mailed, to:
Hoffman Metal Products, Inc. and Harry W. Hoffman, individually and as an officer, director and owner of Hoffman Metal Products, Inc., 1011C Bransten Road, San Carlos, CA 94070, c/o Stacey Y. North, Esq., PIERCE & SHEARER LLP, 2200 Geng Road, Suite 230, Palo Alto, CA 94303, stacy@pierceshearer.com, authorized to accept service;
Carl R. Heineman. individually, 1515 El Verano Way, Belmont, CA 94002. c/o Joshua A. Bloom, Esq., at jab@bcltlaw.com, jff@bcltlaw.com, and Sherry E. Jackman, Esq., at sej@bcltlaw.com, fmc@bcltlaw.com, Barg Coffin Lewis & Trapp, LLP, 350 California Street 22nd Floor, San Francisco,CA 94104-1435, authorized to accept service.I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed on the date hereinafter set forth. San Francisco, CA
Date: May 1, 2013
_______________
Karl R. Morthole