SQUIRE, SANDERS & 

DEMPSEY L.L.P. 

One Maritime Plaza, Suite 300 

San Francisco, California 94111-

3492

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO FILE OPPOSITION AND REPLY PAPERS 

CONCERNING MOTION TO QUASH/MOTION FOR PROTECTIVE ORDER - CASE NO. CV08-5005 (MMC) 

Ethan A. Miller (State Bar No. 155965) 

David A. Gabianelli (State Bar No. 158170) 

Ethan H. Seibert (State Bar No. 232262) 

SQUIRE, SANDERS & DEMPSEY L.L.P. 

One Maritime Plaza, Suite 300 

San Francisco, CA 94111-3492 

Telephone: +1.415.954.0200 

Facsimile: +1.415.393.9887 

Email: eamiller@ssd.com 

Email: dgabianelli@ssd.com 

Email: eseibert@ssd.com 

Attorneys for Defendants and Counter-Claimant 

ZURICH AMERICAN INSURANCE COMPANY 

and STEADFAST INSURANCE COMPANY 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

(SAN FRANCISCO DIVISION) 

UNITED STATES OF AMERICA, 

Plaintiff, 

vs.

ZURICH INSURANCE COMPANY, 

ZURICH AMERICAN INSURANCE 

COMPANY and STEADFAST 

INSURANCE COMPANY, 

Defendants.

CASE NO. CV08-5005-MMC (EDL) 

STIPULATION AND [PROPOSED] 

ORDER EXTENDING TIME TO FILE 

OPPOSITION AND REPLY PAPERS 

CONCERNING MOTION TO 

QUASH/MOTION FOR PROTECTIVE 

ORDER

Trial Date: February 28, 2011 

STEADFAST INSURANCE COMPANY, 

Counter-claimant, 

vs.

THE PRESIDIO TRUST, a Wholly-Owned 

Corporation of the UNITED STATES OF 

AMERICA, 

Counter-defendant. 

Case 3:08-cv-05005-MMC Document 41 Filed 06/28/10 Page 1 of 3 Case3:08-cv-05005-MMC Document40 Filed06/25/10 Page1 of 3
SQUIRE, SANDERS & 

DEMPSEY L.L.P. 

One Maritime Plaza, Suite 300 

San Francisco, California 94111-

3492

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1

STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO FILE OPPOSITION AND REPLY PAPERS 

CONCERNING MOTION TO QUASH/MOTION FOR PROTECTIVE ORDER - CASE NO. CV08-5005 (MMC) 

WHEREAS, on May 27, 2010 the Department of Interior, National Park Service (“NPS”), 

a third party to this action represented by counsel for the Plaintiff, filed a Motion to 

Quash/Motion for Protective Order (“Motion to Quash”) regarding a subpoena served on NPS by 

Defendants and Counter-Claimant Zurich American Insurance Company and Steadfast Insurance 

Company in this action (Dkt. No. 33); 

WHEREAS, counsel for Defendants and Counter-Claimant and NPS have been in 

communication regarding the subject matter at issue in the Motion to Quash and have filed a joint 

letter with The Honorable Elizabeth M. Laporte in an attempt to resolve the dispute at issue; 

WHEREAS, the parties seek to briefly extend the date to file any papers in opposition to 

or in further support of the Motion to Quash and in reply to any opposition; 

WHEREAS, the oppositions and reply papers, as well as the entire Motion to Quash, will 

become moot if the dispute is resolved through the submission of the joint letter to the Court; 

The parties STIPULATE as follows: 

1. Any papers submitted in opposition to the Motion to Quash, currently due June 29, 

2010, shall be due on July 2, 2010; 

2. Any papers submitted in response to an opposition, currently due July 6, 2010, 

shall be due on July 9, 2010. 

IT IS SO STIPULATED. 

DATED: July 24, 2010 JOSEPH P. RUSSONIELLO 

United States Attorney 

By: /s/ Charles M. O’Connor 

CHARLES M. O’CONNOR 

Assistant U.S. Attorneys 

COUNSEL FOR PLAINTIFF 

DATED: July 24, 2010 SQUIRE, SANDERS & DEMPSEY L.L.P. 

By: /s/ David A. Gabianelli 

DAVID A. GABIANELLI 

Attorneys for Defendants and Counter-Claimant 

ZURICH AMERICAN INSURANCE COMPANY 

and STEADFAST INSURANCE COMPANY 

Case 3:08-cv-05005-MMC Document 41 Filed 06/28/10 Page 2 of 3 Case3:08-cv-05005-MMC Document40 Filed06/25/10 Page2 of 3
SQUIRE, SANDERS & 

DEMPSEY L.L.P. 

One Maritime Plaza, Suite 300 

San Francisco, California 94111-

3492

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

2

STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO FILE OPPOSITION AND REPLY PAPERS 

CONCERNING MOTION TO QUASH/MOTION FOR PROTECTIVE ORDER - CASE NO. CV08-5005 (MMC)

PURSUANT TO STIPULATION, IT IS SO ORDERED. 

DATED: ________________________ 

 ELIZABETH D. LAPORTE 

United States Magistrate Judge 

Case3:08-cv-05005-MMC Document40 Filed06/25/10 Page3 of 3

June 28, 2010

Case 3:08-cv-05005-MMC Document 41 Filed 06/28/10 Page 3 of 3