STIPULATION AND [P ROPOSED] ORDER TO CONTINUE THE CASE MANAGEMENT CONFERENCE TO NOVEMBER 1, 2013 OR AT THE COURT'S CONVENIENCE THEREAFTER

SUSAN ILLSTON, District Judge.

Pursuant to Civil Local Rule 7-12, Plaintiffs and Defendants respectfully submit this Stipulation And [Proposed] Order To Continue The Initial Case Management Conference To November 1, 2013 Or At The Court's Convenience Thereafter:

WHEREAS, the Burnett action (Burnett v. Conseco Life Insurance Co. et al.) was initially filed in the U.S. District Court for the Central District of California, subsequently transferred to this Court on November 20, 2012 by the Judicial Panel on Multidistrict Litigation and incorporated into the pending multidistrict litigation captioned In Re Conseco Insurance Company Lifetrend Insurance Sales And Marketing Litigation, No. 3:10-md-2124-SI ("Lifetrend MDL");

WHEREAS, an initial case management conference was scheduled in the Burnett action for April 26, 2013 (Docket No. 453), and, pursuant to prior stipulations of the parties (Docket No. 480, 484) was rescheduled for July 19, 2013 (Docket No. 485);

WHEREAS, a further case management conference was scheduled in the Burnett action for September 27, 2013 (Docket No. 502);

WHEREAS, on August 15, 2013, counsel for the Defendants produced the documents that were previously produced in the Brady action, which total roughly 820,000 pages, and Plaintiffs' counsel is still in the process of reviewing these documents;

WHEREAS, counsel for all parties in the Burnett action agree that they will be in a better position to make proposals to the Court concerning additional discovery in the Burnett action after Plaintiffs' counsel has completed an initial review documents previously produced in the Brady action; and

WHEREAS, counsel for all parties in the Burnett action have conferred and agree that to ensure that the upcoming case management conference in the Burnett action is as productive as possible, the case management conference in the Burnett action should take place on or after November 1, 2013 at 3:00 p.m.

IT IS THEREFORE STIPULATED AND AGREED, by and between the undersigned, as follows:

1. Subject to Court approval, the case management conference in the Burnett action shall be held on November 18, 2013 at 3:00 p.m. or at a date and time thereafter that is convenient for the Court; and

2. The case management conference scheduled for September 27, 2013 shall be vacated.

[PROPOSED]ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-1

I, John M. Aerni, am the ECF User whose ID and password are being used to file this Stipulation And Proposed Order. In compliance with Civil L.R. 5-1, 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.