Filed: Mar. 24, 2014
Latest Update: Mar. 24, 2014
Summary: STIPULATION PURSUANT TO LOCAL RULE 6-2 TO EXTEND DEFENDANT'S TIME TO FILE OPPOSITIONS TO PLAINTIFFS' DISCOVERY MOTIONS TO MARCH 31, 2014, AND TO EXTEND PLAINTIFFS' TIME TO FILE REPLIES TO DEFENDANT'S OPPOSITIONS TO APRIL 14, 2014 AND MODIFIED ORDER ELIZABETH D. LAPORTE, Magistrate Judge. WHEREAS, pursuant to Civil Local Rule 6-2, Plaintiffs William Burnett and Joe Camp ("Plaintiffs") and Defendant Conseco Life Insurance Company ("Conseco Life" and with Plaintiffs, "the Parties") respectfully r
Summary: STIPULATION PURSUANT TO LOCAL RULE 6-2 TO EXTEND DEFENDANT'S TIME TO FILE OPPOSITIONS TO PLAINTIFFS' DISCOVERY MOTIONS TO MARCH 31, 2014, AND TO EXTEND PLAINTIFFS' TIME TO FILE REPLIES TO DEFENDANT'S OPPOSITIONS TO APRIL 14, 2014 AND MODIFIED ORDER ELIZABETH D. LAPORTE, Magistrate Judge. WHEREAS, pursuant to Civil Local Rule 6-2, Plaintiffs William Burnett and Joe Camp ("Plaintiffs") and Defendant Conseco Life Insurance Company ("Conseco Life" and with Plaintiffs, "the Parties") respectfully re..
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STIPULATION PURSUANT TO LOCAL RULE 6-2 TO EXTEND DEFENDANT'S TIME TO FILE OPPOSITIONS TO PLAINTIFFS' DISCOVERY MOTIONS TO MARCH 31, 2014, AND TO EXTEND PLAINTIFFS' TIME TO FILE REPLIES TO DEFENDANT'S OPPOSITIONS TO APRIL 14, 2014 AND MODIFIED ORDER
ELIZABETH D. LAPORTE, Magistrate Judge.
WHEREAS, pursuant to Civil Local Rule 6-2, Plaintiffs William Burnett and Joe Camp ("Plaintiffs") and Defendant Conseco Life Insurance Company ("Conseco Life" and with Plaintiffs, "the Parties") respectfully request that the Court enter an Order extending the time for Conseco Life to file Oppositions to the following six discovery motions (the "Discovery Motions") filed by Plaintiffs to March 31, 20141:
• Plaintiffs' Motion to Compel Production of Information Showing Inter-Company Payments (D.I. 556);
• Plaintiffs' Motion to Compel Production of Actuarial Consultant Information (D.I. 557);
• Plaintiffs' Motion to Compel Production of Information Regarding Committees, Task Forces, and Other Groups (D.I. 558);
• Plaintiffs' Motion to Compel Production of Actuarial Memoranda (D.I. 559);
• Plaintiffs' Motion to Compel Production of Information Concerning Regulatory Negotiations (D.I. 560);
• Plaintiffs' Motion to Compel Documents and Information Withheld Pursuant to Brady Stipulation, Including All Relevant Documents Supplied to Wilton Reassurance Company (D.I. 561);
WHEREAS, pursuant to Civil Local Rule 6-2, the Parties also respectfully request pursuant to Local Rule 6-2 that the Court enter an order extending the time for Plaintiffs to file Reply briefs to Conseco Life's Oppositions to the Discovery Motions be extended to April 14, 2014;
WHEREAS, on March 18, 2014, the Court entered an Order continuing the hearing date on the Discovery Motions to May 7, 2014, at 9:30 a.m.;
WHEREAS, given that Plaintiffs filed the six Discovery Motions simultaneously, the volume of the papers and the discovery issues to which Conseco Life must respond is considerable;
WHEREAS, the additional days will allow Conseco Life more time to prepare responses aimed at assisting this Court in resolving these issues;
WHEREAS, Conseco Life may be able to produce additional documents and supplement interrogatory answers in the near future relating to matters raised in the Discovery Motions, which could serve to reduce or eliminate issues Plaintiffs have raised in those Motions;
WHEREAS, this stipulation and request also allows additional time for Plaintiffs to file their Replies in support of the Discovery Motions;
WHEREAS, the Court's calendar will not be impacted as the May 7, 2014 hearing date for these Motions is not affected by this stipulation and request;
WHEREAS, the Declaration of John M. Aerni in support of this stipulation is being filed herewith;
WHEREAS, the filer of this document hereby attests that the concurrence to the filing of this document has been obtained from the other signatory hereto.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
MODIFIED [PROPOSED] ORDER
Upon consideration of the Joint Stipulation Pursuant to Local Rule 6-2 to Extend Defendant's Time to File Oppositions to Plaintiffs' Discovery Motions to March 31, 2014, and to Extend Plaintiffs' Time to File Replies to Defendant's Oppositions to April 14, 2014, and the supporting Declaration of John M. Aerni, THE COURT HEREBY ORDERS THAT:
1. Defendant's time to file its Oppositions to Plaintiffs' Discovery Motions will be extended to March 31, 2014. at 9:00 a.m.
2. Plaintiffs' time to file their Replies in support of the Discovery Motions will be extended to April 14, 2014. at 9:00 a.m.
IT IS SO ORDERED.
