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In Re Conseco Life Insurance

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


December 31, 2010

IN RE CONSECO LIFE INSURANCE

RAOUL D. KENNEDY (STATE BAR NO. 40892) SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP Four Embarcadero Center, Suite 3800 San Francisco, California 94111 Telephone: (415) 984-6400 Facsimile: (415) 984-2698 Email: Raoul.Kennedy@skadden.com JAMES R. CARROLL (PRO HAC VICE) DAVID S. CLANCY (PRO HAC VICE) CHRISTOPHER A. LISY (PRO HAC VICE) SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP One Beacon Street, 31st Floor Boston, Massachusetts 02108 Telephone: (617) 573-4800 Facsimile: (617) 573-4822 Email: James.Carroll@skadden.com Email: David.Clancy@skadden.com Email: Christopher.Lisy@skadden.com Attorneys for Defendant Conseco Life Insurance Company

STIPULATION AND PROPOSED COMPANY LIFETREND INSURANCE ORDER CONCERNING THE SALES AND MARKETING LITIGATION BRIEFING SCHEDULE OF AND HEARING ON PLAINTIFFS' MOTIONS TO COMPEL

Pursuant to Civil Local Rule 7-12, plaintiffs Cedric Brady, Dr. Charles Hovden, Dr. Marion Hovden, Dr. Eugene Kreps, Dr. John McNamara, Dr. Hisaji Sakai and Bill W. McFarland ("Plaintiffs") and defendant Conseco Life Insurance Company ("Conseco Life") respectfully submit this Stipulation And Proposed Order Concerning The Briefing Schedule Of And Hearing On Plaintiffs' Motions to Compel.

certain discovery requests (Docket Nos. 140, 141, 142 and 143) ("Motions") from defendant

WHEREAS, on December 23, 2010, Plaintiffs filed four motions to compel concerning Conseco Life Insurance Company ("Conseco Life");

WHEREAS, Conseco Life's oppositions to the Motions are due on January 7, 2011;

WHEREAS, for purposes of convenience and to conserve resources, Conseco Life may file a single consolidated opposition to the Motions as opposed to four separate oppositions;

memorandum of points and authorities filed in support of an opposition;

WHEREAS, Local Rule 7-4 imposes a page limit of twenty-five pages on a brief or

WHEREAS, Plaintiffs' replies are due on January 14, 2011;

WHEREAS, theMotions arecurrentlyscheduledtobeheard, and a Further Case Management Conference is scheduled to be held, on January 28, 2011; and

WHEREAS, because counsel for Conseco Life have certain significant conflicts with this schedule, counsel for Plaintiffs and Conseco Life have conferred and agree upon a modified briefing schedule and hearing date;

follows:

THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the undersigned as

1. Conseco Life may file its oppositions to Plaintiffs' Motion no later than January 21, 2011 and, if it chooses to file a consolidated opposition, may file one not to exceed forty-five pages in length;

2. Plaintiffs may file their replies no later than January 28, 2011;

3. A hearing on Plaintiffs' Motions and a Further Case Management Conference may be scheduled for February 11, 2011, or at another time as the Court's schedule may permit*fn1 ;and

4. The Parties may file a joint case management statement no later than seven days in advance of the Conference (February 4, 2011).

ATTESTATION PURSUANT TO GENERAL ORDER 45

I, Christopher A. Lisy, am the ECF User whose ID and password are being used to file this Stipulation And Proposed Order. 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 31st day of December, 2010, at Boston, Massachusetts.

By: /s/ Christopher A. Lisy Christopher A. Lisy

PURSUANT TO STIPULATION, IT IS SO ORDERED,

Dated:

By: Hon. Susan Illston


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