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In Re Conseco Life Insurance Co.

January 18, 2013

IN RE CONSECO LIFE INSURANCE CO.
LIFETREND INSURANCE MARKETING AND SALES PRACTICES LITIGATION



The opinion of the court was delivered by: Hon. Elizabeth D. Laporte Judge: United States Magistrate Judge

STIPULATION AND [PROPOSED] ) ORDER TO FILE UNDER SEAL ) PLAINTIFFS' MOTION TO REMOVE 22 ) CONFIDENTIALITY DESIGNATIONS ) FROM DEPOSITIONS ) ) Date: January 29, 2013 24 Time: 9:00 a.m. )

Courtroom E, 15th Floor

Marion Hovden, Dr. John McNamara, Dr. Hisaji Sakai, and Bill W. McFarland ("Plaintiffs") will 4 file their Motion for to Remove Confidentiality Designations from Depositions ("Motion"); 5

WHEREAS, the Stipulation and [Proposed] Order for the Protection and Exchange of Confidential Information (submitted on October 16, 2009 in Brady v. Conseco, Inc., No. 3:08-7

Parties in this MDL (Brady ECF No. 77; Brady ECF No. 127; MDL ECF No. 13) (the "Proposed 10

STIPULATION

WHEREAS, on December 21, 2012, Plaintiffs Cedric Brady, Dr. Charles Hovden, Dr. CV-5746 (N.D. Cal.), entered as an Order by the Court on May 14, 2012, and adopted by the Protective Order")) permits a party to designate as "Confidential" documents or information that 11 contain "confidential or proprietary business, commercial, personal or financial information, trade 12 secrets, confidential research or development, and/or credit, compliance personnel and 13 administrative information;" 14

WHEREAS, page 5 of the Motion and Exhibit 5 to the Declaration of Andrea Hopkins in Support of Plaintiffs' Motion reference materials that a third party, PricewaterhouseCoopers, has 16 designated as confidential (the "Designated Materials); 17

WHEREAS, the Court previously granted the Parties' motions for leave to file the Designated Materials under seal in this matter and the Brady matter (Brady ECF Nos. 85, 115; 19 MDL ECF Nos. 16, 29, 41, 44, 82, 148, 202, 275, and 289); and 20

WHEREAS, the Parties agree that good cause exists now for filing the Designated Materials under seal, although Plaintiffs reserve their rights to challenge the confidentiality of the 22 Designated Materials in a future proceeding or at trial; 23

THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the undersigned Parties as follows: 25

26 this case, including any appeals; 27

(1) Plaintiffs may file the Designated Materials under seal until the final disposition of

(2) At the conclusion of the litigation, after any appeals have been exhausted, the Designated Materials shall be returned to the party that ...


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