Chartis Specialty Insurance Company et al v. United States of America

Filing 75

STIPULATION AND ORDER re 73 STIPULATION WITH PROPOSED ORDER Joint Stipulation to Extend Deadline to Serve Rule 26(A) Initial Disclosures; [Proposed] Order filed by Chartis Specialty Insurance Company. Signed by Judge Edward M. Chen on 7/18/13. (bpf, COURT STAFF) (Filed on 7/19/2013)

1 DAVID F. WOOD (SBN 68063)
[e-mail]
2 GREGORY P. ARAKAWA (SBN 159023)
[e-mail]
3 Wood, Smith, Henning & Berman LLP
10960 Wilshire Boulevard, 18th Floor
4 Los Angeles, California 90024-3804
Phone: [phone] ♦ Fax: [phone]
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6 SCOTT L. DAVIS (TX SBN 05547030 (admitted pro hac vice)
[e-mail]
7 MATTHEW J. SCHROEDER (TX SBN 00791619 (admitted pro hac vice)
[e-mail]
8 COLIN G. MARTIN (TX SBN 24013105 (admitted pro hac vice)
[e-mail]
9 Gardere Wynne Sewell LLP
1601 Elm Street, Suite 3000
10 Dallas, TX 75201
Phone: [phone] / Fax: [phone]
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Attorneys for Plaintiff, CHARTIS SPECIALTY INSURANCE COMPANY
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO DIVISION

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16 CHARTIS SPECIALTY INSURANCE
COMPANY, an Illinois corporation, for itself
17 and as subrogee of Whittaker Corporation; and
WHITTAKER CORPORATION, a Delaware
18 corporation,
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Case No. 3:13-CV-01527-EMC
JOINT STIPULATION TO EXTEND
DEADLINE TO SERVE RULE 26(A)
INITIAL DISCLOSURES; [PROPOSED]
ORDER

Plaintiff,
Complaint Filed: 12/10/2012

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v.

21 UNITED STATES OF AMERICA,

[Assigned for All Purposes to Hon. Edward M. Chen, Ctrm. 5
– 17th Floor]

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Trial Date:

Defendant.

None Set

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3:13-CV-01527-EMC
-1JOINT STIPULATION TO EXTEND DEADLINE TO SERVE RULE 26(A) INITIAL DISCLOSURES;
[PROPOSED] ORDER

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JOINT STIPULATION TO EXTEND DEADLINE

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TO SERVE RULE 26 DISCLOSURES

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This stipulation is entered into by Plaintiffs Chartis Specialty Insurance Company

4 (“Chartis”) and Whittaker Corporation (“Whittaker”), and Defendant United States of America
5 (“United States”) (collectively, the “Parties”) to extend the deadline to serve Rule 26(a) initial
6 disclosures. On July 2, 2013, the Parties held their Federal Rule 26(f) conference in advance of
7 the currently-scheduled July 25, 2013 Case Management Conference. Because of the July 4
8 holiday and the time involved with the parties’ cooperative efforts to prepare the required Joint
9 Case Management Statement due on July 18, 2013, the Parties agreed and stipulated during the
10 July 2nd conference that they would have through and until July 23, 2013 to make their respective
11 Rule 26(a) initial disclosures. Accordingly, the Parties ask the Court to enter the proposed Order
12 submitted herewith granting such relief.
13 DATED: July 16, 2013

GARDERE WYNNE SEWELL LLP

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By: /s/ Matthew J. Schroeder
Matthew J. Schroeder
Attorneys for Plaintiff, CHARTIS SPECIALTY
INSURANCE COMPANY

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18 DATED: July 16, 2013

PILLSBURY WINTHROP SHAW PITTMAN LLP

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By: /s/ Stacey C. Wright
Stacey C. Wright
Attorneys for Plaintiff, WHITTAKER
CORPORATION

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3:13-CV-01527-EMC
-2JOINT STIPULATION TO EXTEND DEADLINE TO SERVE RULE 26(A) INITIAL DISCLOSURES;
[PROPOSED] ORDER

1 DATED: July 16, 2013
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ROBERT G. DREHER
Acting Assistant Attorney General
Environment & Natural Resources Division

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By: /s/ C. Scott Spear
Michael C. Augustini
John Thomas H. Do
C. Scott Spear
Attorneys for Defendant, UNITED STATES OF
AMERICA

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3:13-CV-01527-EMC
-3JOINT STIPULATION TO EXTEND DEADLINE TO SERVE RULE 26(A) INITIAL DISCLOSURES;
[PROPOSED] ORDER

[PROPOSED] ORDER

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The Court has considered the Parties’ Joint Stipulation to Extend Deadline to Serve Rule

3 26(a) Disclosures and, finding good cause, hereby orders that the deadline for the Parties to serve
4 their Rule 26(a) initial disclosures shall be July 23, 2013.
IT IS SO ORDERED.

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Edward D Chen
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United States District Judge
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3:13-CV-01527-EMC
-4JOINT STIPULATION TO EXTEND DEADLINE TO SERVE RULE 26(A) INITIAL DISCLOSURES;
[PROPOSED] ORDER