United States of America v. Zurich Insurance Company et al

Filing 41

STIPULATION AND ORDER re 40 Stipulation, filed by Zurich American Insurance Company, Steadfast Insurance Company. Signed by Magistrate Judge Elizabeth D. Laporte on June 28, 2010. (edllc2, COURT STAFF) (Filed on 6/28/2010)

Case3:08-cv-05005-MMC Document40

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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: [phone] Facsimile: +1.415.393.9887 Email: [e-mail] Email: [e-mail] Email: [e-mail] 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

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SQUIRE, SANDERS & DEMPSEY L.L.P.
One Maritime Plaza, Suite 300 San Francisco, California 941113492

STEADFAST INSURANCE COMPANY, Counter-claimant, vs. THE PRESIDIO TRUST, a Wholly-Owned Corporation of the UNITED STATES OF AMERICA, Counter-defendant.

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)

Case3:08-cv-05005-MMC Document40

Filed06/25/10 Page2 of 3

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SQUIRE, SANDERS & DEMPSEY L.L.P.
One Maritime Plaza, Suite 300 San Francisco, California 941113492

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 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)

Case3:08-cv-05005-MMC Document40

Filed06/25/10 Page3 of 3

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SQUIRE, SANDERS & DEMPSEY L.L.P.
One Maritime Plaza, Suite 300 San Francisco, California 941113492

PURSUANT TO STIPULATION, IT IS SO ORDERED. DATED: June 28, 2010 ________________________ ELIZABETH D. LAPORTE United States Magistrate Judge

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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)