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In Re Conseco Life Insurance Co.

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 ...


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