-1- Case No. CV 09-0983 MMC

STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC AND RULE 26(A) DISCLOSURES 

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SEDGWICK, DETERT, MORAN & ARNOLD LLP 

BRUCE D. CELEBREZZE Bar No. 102181 

bruce.celebrezze@sdma.com 

MATTHEW C. LOVELL Bar No. 189728 

matthew.lovell@sdma.com 

DEAN J. MCELROY Bar. No. 213132 

dean.mcelroy@sdma.com 

One Market Plaza 

Steuart Tower, 8th Floor 

San Francisco, California 94105 

Telephone: (415) 781-7900 

Attorneys for defendant and counterclaimant 

HARTFORD UNDERWRITERS INSURANCE COMPANY 

BOWLES & VERNA LLP 

MICHAEL P. CONNOLLY Bar No. 238478 

mconnolly@bowlesverna.com 

ROBERT I. WESTERFIELD Bar No. 112183 

rwesterfield@bowlesverna.com 

2121 N. California Blvd, Suite 875 

Walnut Creek, California 94596 

Telephone: (925) 935-3300 

Attorneys for plaintiff and counterdefendant 

CONTRA COSTA WATER DISTRICT 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

CONTRA COSTA WATER DISTRICT, 

Plaintiff, 

v.

HARTFORD UNDERWRITERS 

INSURANCE COMPANY; and Does 1 

through 10, inclusive, 

Defendants.

 CASE NO. CV 09-0983 MMC 

STIPULATION AND [PROPOSED] 

ORDER TO CONTINUE JUNE 18, 2010 

FURTHER CASE MANAGEMENT 

CONFERENCE AND DATES FOR RULE 

26(A) INITIAL DISCLOSURES AND 

EXCHANGE OF DOCUMENTS 

HARTFORD UNDERWRITERS 

INSURANCE COMPANY, 

Counterclaimant, 

v.

CONTRA COSTA WATER DISTRICT, 

 Counterdefendant

Courtroom: 7 

Judge: Hon. Maxine M. Chesney 

AND ORDER THEREON

Case 3:09-cv-00983-MMC Document 31 Filed 06/11/10 Page 1 of 4
 -2- Case No. CV 09-0983 MMC

STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC AND RULE 26(A) DISCLOSURES 

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Per Northern District Local Rule 16-2(d) and (e), plaintiff and counterdefendant Contra 

Costa Water District (“CCWD”) and defendant and counterclaimant Hartford Underwriters 

Insurance Company (“Hartford”), by and through their counsel of record, stipulate as follows: 

RECITALS

The Court held the initial case management conference in this matter on March 12, 2010. 

The parties informed the Court at the conference and in their joint case management statement filed 

March 5, 2010 (Document No. 28), that they desire to continue the mediation they began on 

October 8, 2009, and that they were trying to schedule a continued mediation session with the Hon. 

Ronald M. Sabraw (Ret.) at JAMS for a date in April 2010.

The Court continued the matter for a further case management conference on June 18, 2010 

(Document No. 29), but did not set any discovery deadlines or pretrial or trial dates. The Court 

also allowed the parties to defer making their respective Rule 26(a) initial written disclosures and 

initial exchange of documents until after they return to mediation. 

Due to conflicting calendars of Judge Sabraw, the parties’ representatives, and the parties’ 

counsel, the parties have not yet returned to mediation. However, the parties have agreed to 

participate in a further mediation session with Judge Sabraw on Friday, July 16, 2010. Moreover, 

although the parties have not yet been able to return to mediation, they have continued to exchange 

information and documents in order to narrow the issues for mediation. 

At the March 12, 2010 case management conference, the Court advised the parties that if 

they needed more time to try to resolve this matter, they should submit a stipulation requesting a 

continuance of the June 18, 2010 case management conference. Although the parties do not wish 

in any way to unnecessarily delay the litigation of this matter, they believe it is prudent to return to 

mediation in an effort to settle their disputes before substantial resources are expended in making 

Rule 26(a) initial disclosures, conducting other discovery, and otherwise preparing the case for 

trial.

Therefore, in the interest of saving time, money, and the Court’s resources, the parties 

request that the June 18, 2010 case management conference be continued to July 30, 2010 (two 

weeks after the further mediation session) or a convenient date thereafter, that the case be stayed 

Case 3:09-cv-00983-MMC Document 31 Filed 06/11/10 Page 2 of 4
 -3- Case No. CV 09-0983 MMC

STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC AND RULE 26(A) DISCLOSURES 

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SF/1702846v1

until that time, and that the parties’ Rule 26(a) disclosures and exchange of documents be 

postponed until after the date of the next case management conference. 

STIPULATION

Based on the foregoing Recitals, CCWD and Hartford agree and stipulate as follows: 

(1) The further case management conference scheduled for June 18, 2010, shall be 

continued to July 30, 2010 or a convenient date thereafter; 

(2) The parties shall submit a joint case management statement one week before the date of 

the further case management conference; 

(3) All discovery and law and motion practice in this case shall be stayed until after the 

further case management conference, including the parties’ Rule 26(a) initial written disclosures 

and exchange of documents. 

IT IS SO STIPULATED. 

DATED: June 10, 2010 SEDGWICK, DETERT, MORAN & ARNOLD LLP 

By:_/s/ Matthew C. Lovell_________________________

Bruce D. Celebrezze 

Matthew C. Lovell 

Dean J. McElroy 

Attorneys for Defendant and Counterclaimant HARTFORD 

UNDERWRITERS INSURANCE COMPANY 

DATED: June 10, 2010 BOWLES & VERNA LLP 

By: /s/ Robert I. Westerfield 

Robert I. Westerfield 

Michael P. Connolly 

Attorneys for plaintiff and counterdefendant CONTRA 

COSTA WATER DISTRICT 

ATTESTATION OF FILING

Pursuant to General Order 45.X.B, I attest that I have obtained concurrence in the filing of 

this document from the parties listed above. 

 /s/ Matthew C. Lovell 

 Matthew C. Lovell 

Case 3:09-cv-00983-MMC Document 31 Filed 06/11/10 Page 3 of 4
 -4- Case No. CV 09-0983 MMC

STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC AND RULE 26(A) DISCLOSURES 

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ORDER

PURSUANT TO THE FOREGOING STIPULATION, IT IS ORDERED THAT: 

(1) The further case management conference scheduled for June 18, 2010, shall be 

continued to __________________, 2010; 

(2) The parties shall submit a joint case management statement one week before the date of 

the further case management conference; 

(3) All discovery and law and motion practice in this case shall be stayed until after the 

further case management conference, including the parties’ Rule 26(a) initial written disclosures 

and exchange of documents. 

DATED: _____________, 2010 

HON. MAXINE M. CHESNEY 

UNITED STATES DISTRICT JUDGE 

July 30

June 11

Case 3:09-cv-00983-MMC Document 31 Filed 06/11/10 Page 4 of 4