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In Re Conseco Life Insurance Co.

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:dmillstein@millstein-law.com 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: gilberts@gotofirm.com Email: weisbrods@gotofirm.com Email: matteisa@gotofirm.com Email: halek@gotofirm.com 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;

memorandum;

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.

follows:

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

20110125

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