UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA NORTHERN DIVISION
January 25, 2011
IN RE CONSECO LIFE INSURANCE CO.
LIFE TREND INSURANCE MARKETING AND SALES PRACTICE LITIGATION
The opinion of the court was delivered by: The Honorable Susan Illston United States District Court Judge
David J. Millstein (CSB #87878) MILLSTEIN & ASSOCIATES 100 The Embarcadero Suite 200 San Francisco, California 94105 Telephone: (415) 348-0348 Facsimile: (415) 348-0336 4 E-mail:firstname.lastname@example.org 5 Scott D. Gilbert (ADMITTED PRO HAC VICE) Stephen A. Weisbrod (ADMITTED PRO HAC VICE) August J. Matteis Jr. (ADMITTED PRO HAC VICE) Kathleen Hale (ADMITTED PRO HAC VICE) GILBERT LLP 1100 New York Avenue, NW, Suite 700 Washington, DC 20005 Telephone: (202) 772-2200 Facsimile: (202) 772-3333 Email: email@example.com Email: firstname.lastname@example.org Email: email@example.com Email: firstname.lastname@example.org Counsel for Plaintiffs
STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR
PLAINTIFFS TO REPLY TO DEFENDANT'S OPPOSITION TO
PLAINTIFFS' MOTIONS TO COMPEL
Hovden, Eugene Kreps, John McNamara, Hisaji Sakai, and Bill W. McFarland ("Plaintiffs") and [Proposed] Order to Extend Time for Plaintiffs to Reply to Defendant's Opposition to Plaintiffs'
WHEREAS, on December 23, 2010, Plaintiffs filed four Motions to Compel, ECF Nos. 140, 141, 142, and 143; on Plaintiffs' Motions to Compel, ECF No. 149, Defendant filed its Opposition on January 21, 10
WHEREAS, Plaintiffs' response to Defendant's Opposition is due on January 28, 2011;
WHEREAS, Local Rule 7-4 impose a page limit of fifteen (15) pages on a reply brief or Pursuant to Civil Local Rule 7-12, Plaintiffs Cedric Brady, Charles Hovden, Marion Defendant Conseco Life Insurance Company ("Conseco") respectfully submit this Stipulation and Motions to Compel.
WHEREAS, pursuant to the Stipulation Concerning the Briefing Schedule of and Hearing 2011;
on Plaintiffs' Motion to Compel, ECF No. 149, the Motions to Compel are currently scheduled to 16 be heard on February 11, 2011;
Motions to Compel and Conseco's Opposition, and because several members of Plaintiffs' 19 litigation team are travelling this week, counsel for Plaintiffs and Defendant have conferred and 20 agree to extend the time for Plaintiffs' response from January 28, 2011 until January 31, 2011.
Compel no later than January 31, 2011; and or memorandum not to exceed thirty (30) pages in length.
WHEREAS, pursuant to the Stipulation Concerning the Briefing Schedule of and Hearing
WHEREAS, because of the number and complexity of issues raised in Plaintiffs' four
IT THEREFORE IS STIPULATED AND AGREED, by and between the undersigned, as
1. Plaintiffs may file their Reply to Defendant's Opposition to Plaintiffs' Motions to
2. If Plaintiffs choose to file a consolidated Reply, Plaintiffs may file one Reply brief
Dated: January 25, 2011
Respectfully submitted, 2 3
ATTESTATION PURSUANT TO GENERAL ORDER 45
I, Stephen A. Weisbrod am the ECF User whose ID and password are being
used to file
this Stipulation Extending Time to Reply to Defendant's Opposition
to Plaintiffs' Motions to Compel. In compliance with General Order 45.X.B, I hereby attest that
the concurrence in the 5 filing of this document has been obtained
from each of the other signatories. I declare under 6 penalty of
perjury under the laws of the United States of America that the
foregoing is true and 7 correct.
Executed this 25th day of January 2011 at Washington, DC 9
delivered on the following counsel via electronic filing:
/s/ Stephen A. Weisbrod (Admitted pro hac vice)
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Four Embarcadero Center, Suite 3800 San Francisco, California 94111
Email: Raoul.Kennedy@skadden.com James R. Carroll David S. Clancy Christopher A. Lisy SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP One Beacon Street, 31st Floor Boston, Massachusetts 02108 Email: James.Carroll@skadden.com Email: David.Clancy@skadden.com Email: Cale.Keable@skadden.com Raoul D. Kennedy SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP /s/ Stephen A. Weisbrod
CERTIFICATE OF SERVICE
I hereby certify that on January 25, 2011, a true and correct copy of the foregoing was
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