Opinion
Case No. 13-cv-01031-JCS
05-06-2013
TECNOGLASS, S.A., a Columbian Corporation, Plaintiff, v. MOOS DISTRIBUTING, INC.; WEBCOR CONSTRUCTION dba WEBCOR BUILDERS; SAFECO INSURANCE COMPANY OF AMERICA; CITY & COUNTY OF SAN FRANCISCO, PUBLIC UTILITY COMMISSION; THE INSURANCE COMPANY OF THE STATE OF PENNSYLVANIA; and DOES 1 through 100, inclusive, Defendants. MOOS DISTRIBUTING, INC., dba SADEV USA, a Iowa corporation, Counter-claimant, v. C.E. TOLAND & SON, a California corporation, WEBCOR CONSTRUCTION, LP dba Webcor Builders, a California limited partnership, TECNOGLASS, S.A., a Colombian Corporation, SAFECO INSURANCE COMPANY OF AMERICA, a New Hampshire corporation, THE INSURANCE COMPANY OF THE STATE OF PENNSYLVANIA, a Pennsylvania corporation, Counter-defendants.
CITY AND COUNTY OF FRANCISCO (Specially Appearing) MICHEL S. DEEB Attorneys for Defendant CITY AND COUNTY OF SAN FRANCISCO ABRAMSON & BROWN AARON SCOTT BROWN Attorney For Plaintiff TECNOGLASS, S.A., A COLUMBIAN CORPORATION
DENNIS J. HERRERA, State Bar #139669
City Attorney
RONALD P. FLYNN, State Bar #184186
Team Leader
MICHEL S. DEEB, State Bar #268629
Deputy City Attorneys
Fox Plaza
1390 Market Street, 4th Floor
San Francisco, California 94102-5408
Telephone: (415) 554-3820
Facsimile: (415) 255-0733
ronald.flynn@sfgov.org
michel.deeb@sfgov.org
Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO
STIPULATION TO EXTEND TIME TO
RESPOND TO COMPLAINT [CIVIL LOCAL
RULE 6-1(A)]
Hon. Joseph C. Spero
STIPULATION EXTENDING TIME TO RESPOND
Pursuant to Northern District Civil Local Rule 6-1(a), Defendant City and County of San Francisco, including its Public Utilities Commission (collectively "San Francisco") and Plaintiff Tecnoglass, S A., a Columbian Corporation ("Tecnoglass") and, by and through their respective counsel of record, hereby stipulate as follows:
WHEREAS, Tecnoglass served its Complaint stating a cause of action for Enforcement of Stop Notice against San Francisco on April 11, 2013;
WHEREAS, San Francisco currently has until May 2, 2013 to answer or otherwise respond to the Tecnoglass Complaint;
WHEREAS, an additional 22 days for San Francisco's answer or other response to the Tecnoglass Complaint will not alter the date of any event or any deadline already fixed by Court order;
WHEREAS, San Francisco is specially appearing by this Stipulation and does not waive any affirmative defenses through this Stipulation;
NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the parties through their respective counsel, that San Francisco shall have until, on or before May 24, 2013, to answer or otherwise respond to the Tecnoglass Complaint.
CITY AND COUNTY OF FRANCISCO
(Specially Appearing)
By: __________
MICHEL S. DEEB
Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO
ABRAMSON & BROWN
By: __________
AARON SCOTT BROWN
Attorney For Plaintiff
TECNOGLASS, S.A., A COLUMBIAN
CORPORATION