SF/1709967v1 -1- Case No. CV 09-0983 MMC

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

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

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 JULY 30, 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 

Case 3:09-cv-00983-MMC Document 33 Filed 07/20/10 Page 1 of 4
SF/1709967v1 -2- Case No. CV 09-0983 MMC

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

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

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

Pursuant to a Stipulated Order dated June 11, 2010, the Court approved the parties’ 

agreement to participate in a further mediation session with Hon. Ronald M. Sabraw (Ret.) at 

JAMS, on Friday, July 16, 2010, and scheduled a case management conference for July 30, 2010. 

See Document No. 31. Since a prior case management conference on March 12, 2010, the parties 

have continued to exchange information and documents to narrow the issues for mediation. As the 

July 16 mediation date approached, however, the parties realized that it would be necessary to 

exchange additional information to improve the prospects that the mediation session would be 

productive. As such, the parties rescheduled the mediation session with Judge Sabraw to take place 

on August 16, 2010. This date was the earliest feasible date, in light of the parties’ efforts to 

exchange information, and the conflicting calendars of Judge Sabraw, the parties’ representatives, 

and the parties’ counsel. 

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 future 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 July 30, 2010 case management conference be continued to September 10, 2010, or 

a convenient date thereafter, that the case be stayed 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. 

\\\

Case 3:09-cv-00983-MMC Document 33 Filed 07/20/10 Page 2 of 4
SF/1709967v1 -3- Case No. CV 09-0983 MMC

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

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

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

(1) The further case management conference scheduled for July 30, 2010, shall be 

continued to September 10, 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: July 15, 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: July 15, 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 33 Filed 07/20/10 Page 3 of 4
SF/1709967v1 -4- Case No. CV 09-0983 MMC

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

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

ORDER

PURSUANT TO THE FOREGOING STIPULATION, IT IS ORDERED THAT: 

(1) The further case management conference scheduled for July 30, 2010, is 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 

September 10

July 20

/s/ Vaughn R Walker for

Case 3:09-cv-00983-MMC Document 33 Filed 07/20/10 Page 4 of 4