KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 101 CALIFORNIA STREET, SUITE 2300 SAN FRANCISCO, CALIFORNIA 94111 Case :10-cv-09198-JVS -RNB Document 358-1 Filed 12/12/12 Page1of3 Page ID #:15520 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA JOYCE WALKER, KIM BRUCE CASE NO.: CV 10-9198 JVS (RNBx) HOWLETT, and MURIEL SPOONER, on behalf of themselves and all others similarly situated, [PROPOSED] ORDER GRANTING bcd PLAINTIFFS’ MOTION TO Plaintiffs, COMPEL AND ENTERING AN ORDER REGARDING Vv. DEPOSITIONS LIFE INSURANCE COMPANY OF THE SOUTHWEST, a Texas corporation, Defendant. [PROPOSED] ORDER GRANTING PLAINTIFFS’ MOTION TO COMPEL AND ENTERING AN ORDER REGARDING DEPOSITIONS The Court hereby GRANTS Plaintiffs Joyce Walker’s, Kim Bruce Howlett’s, and Muriel Spooner’s (‘Plaintiffs’) Motion to Compel and Motion for an Order Regarding Depositions (the “Motion’’). Accordingly, the Court: (1) Orders Defendant Life Insurance Company of the Southwest (“Defendant” or “LSW’’) to produce, by no later than three weeks from the date of the hearing of this Motion, documents responsive to Document Request No. 125. (2) Orders LSW to provide a corporate designee to testify as to Deposition Topic Nos. 5 and 33. LSW shall identify and produce for deposition, by no later than January 10, 2013, the corporate designees who will testify as to the above topics. (3) Orders that the “end date” for documents to be produced in this matter will be 60 days prior to the operative close of non-expert fact discovery. If the [PROPOSED] ORDER GRANTING PLAINTIFFS’ MOTION TO COMPEL AND ENTERING AN ORDER REGARDING DEPOSITIONS Case No. CV 10-9198 JVS (RNBx) 1 KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 101 CALIFORNIA STREET, SUITE 2300 SAN FRANCISCO, CALIFORNIA 94111 Case NH NN BB W N :10-cv-09198-JVS -RNB Document 358-1 Filed 12/12/12 Page2of3 Page ID #:15521 deadline for non-expert fact discovery is extended by the Court, the “end date” shall be correspondingly extended to 60 days prior to the new operative close of non-expert fact discovery. Prior to the close of non-expert fact discovery, LSW shall make at least one additional supplemental production, which supplementation shall include any responsive documents not previously produced that were created on or before the “end date.” (4) Enters Plaintiffs’ proposed order concerning deposition conduct. Accordingly, with respect to any future depositions in this matter: (a) All objections, except those which would be waived if not made at the deposition under Federal Rule of Civil Procedure 32(d)(3)(B), and those necessary to assert a privilege, to enforce a limitation on evidence directed by the Court, or to present a motion pursuant to Federal Rule of Civil Procedure 30(d), shall be preserved. Therefore, those objections need not and shall not be made during the course of depositions. (b) Counsel shall not make objections or statements which might suggest an answer to a witness. Counsel’s statements when making objections should be succinct, verbally economical, and non-suggestive, stating the basis of the objection and nothing more. (c) Counsel shall not direct or request that a witness not answer a question, unless that counsel has objected to the question on the ground that the answer is protected by a privilege or a limitation on evidence directed by the Court. (d) Counsel shall not engage in colloquy with the witness while a question is pending. Any conferences that occur in violation of this guideline are a proper subject for inquiry by deposing counsel to ascertain whether there has been any witness-coaching and, if so, what. [PROPOSED] ORDER GRANTING PLAINTIFFS’ MOTION TO COMPEL AND ENTERING AN ORDER REGARDING DEPOSITIONS Case No. CV 10-9198 JVS (RNBx) 2 KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 101 CALIFORNIA STREET, SUITE 2300 SAN FRANCISCO, CALIFORNIA 94111 Case P:10-cv-09198-JVS -RNB Document 358-1 Filed 12/12/12 Page 3of3 Page ID #:15522 1], IT IS SO ORDERED. Honorable Robert N. Block United States Magistrate Judge 28 [PROPOSED] ORDER GRANTING PLAINTIFFS’ MOTION TO COMPEL AND ENTERING AN ORDER REGARDING DEPOSITIONS Case No. CV 10-9198 JVS (RNBx) 3