UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
February 19, 2009
CEDRIC BRADY, DR. CHARLES HOVDEN, MARION HOVDEN, DR. EUGENE KREPS, DR. JOHN MCNAMARA, DR. HISAJI SAKAI, AND JEAN SAKAI, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
CONSECO, INC. AND CONSECO LIFE INSURANCE COMPANY, DEFENDANTS.
STIPULATION AND PROPOSED ORDER EXTENDING TIME TO ANSWER, MOVE, OR OTHERWISE RESPOND TO THE COMPLAINT
WHEREAS on December 24, 2008, plaintiffs Cedric Brady, Dr. Charles Hovden, Marion Hovden, Dr. Eugene Kreps, Dr. John McNamara, Dr. Hisaji Sakai, and Jean Sakai (the "Plaintiffs") filed a Complaint against defendants Conseco, Inc. and Conseco Life Insurance Company (the "Defendants," referred to collectively with the Plaintiffs as the "Parties"), in the San Francisco Division of the United States District Court for the Northern District of California (the "Complaint");
WHEREAS on January 9, 2009, Plaintiffs served a summons and Complaint on each of the Defendants;
WHEREAS on January 29, 2009, the Parties filed with the Court a Stipulation Extending Time To Answer, Move, Or Otherwise Respond To The Complaint (Docket No. 15) requesting that the date by which Defendants must answer, move, or otherwise respond to the Complaint be extended to and including February 20, 2009, and the Court granted such relief by Order dated February 2, 2009 (Docket No. 23);
WHEREAS Defendants have requested and Plaintiffs have agreed to further extend the date by which Defendants shall be required to answer, move or otherwise respond to the Complaint to and including March 6, 2009;
IT IS THEREFORE STIPULATED AND AGREED, by and between the undersigned, that, subject to this Court's approval, Defendants shall have to and including March 6, 2009, within which to answer, move, or otherwise respond to the Complaint.
DATED: February 18, 2009
Millstein & Associates David J. Millstein Attorneys for Plaintiffs
Gilbert Oshinksy LLP August J. Matteis, Jr. Attorneys for Plaintiffs
Skadden, Arps, Slate, Meagher & Flom LLP Raoul D. Kennedy James R. Carroll (Admitted Pro Hac Vice) David S. Clancy (Admitted Pro Hac Vice) Cale P. Keable (Admitted Pro Hac Vice) Attorneys for Defendants Conseco, Inc. and Conseco Life Insurance Company
ATTESTATION PURSUANT TO GENERAL ORDER
I, David S. Clancy, am the ECF User whose ID and password are being used to file this Stipulation Extending Time To Answer, Move, Or Otherwise Respond To The Complaint. In compliance with General Order 45.X.B, I hereby attest that concurrence in the filing of this document has been obtained from each of the other signatories. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.
Executed this 18th day of February 2009, at Boston, Massachusetts.
By: David S. Clancy
PURSUANT TO STIPULATION IT IS SO ORDERED.
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