Case 2:

-cv-09198-JVS-RNB Document 486 Filed 01/02/14 Page1lof4 Page ID #:21778

MINTZ LEVIN COHN FERRIS GLOVSKY AND POPEO PC Jonathan A. Shapiro (257199)

44 Montgomery Street

San Francisco, California 94104

Tel: (415) 432-6000

Fax: (415) 432-6001

JAShapiro @ mintz.com

WILMER CUTLER PICKERING HALE AND DORR LLP Andrea J. Robinson (pro hac vice)

Timothy J. Perla (pro hac vice)

60 State Street

Boston, Massachusetts 02109

Tel: (617) 526-6000

Fax: (617) 526-5000

andrea.robinson @ wilmerhale.com

timothy.perla@ wilmerhale.com

Attorneys for Defendant Life Insurance Company of the Southwest UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

JOYCE WALKER, KIM BRUCE CLASS ACTION

HOWLETT, and MURIEL SPOONER, on behalf of themselves CASE NO.: CV 10-9198 JVS (RNBx)

and all others similarly situated, Formerly Case No.: 3:10-cv -04852 - JSW from Northern District of CA Plaintiffs, JOINT STIPULATION Vv. REGARDING PROPOSED FIFTH AMENDED PRETRIAL

LIFE INSURANCE COMPANY OF | SCHEDULING ORDER THE SOUTHWEST, a Texas corporation,

Defendant.

JOINT STIPULATION REGARDING PROPOSED FIFTH AMENDED PRETRIAL SCHEDULING ORDER

Case No. CV 10-9198 JVS (RNBx)

Case 2:

-cv-09198-JVS-RNB Document 486 Filed 01/02/14 Page2of4 Page ID #:21779

Pursuant to Local Rule 7-1, Plaintiffs Joyce Walker, Kim Bruce Howlett, and Muriel Spooner (“Plaintiffs”) and Defendant Life Insurance Company of the Southwest (“LSW’’) (collectively, the “parties’), by and between their undersigned counsel, submit the following stipulation:

WHEREAS, on December 17, 2013, the Court held a telephonic status conference with the parties and set a final pretrial conference for March 24, 2014 and trial for April 8, 2014;

WHEREAS, the Court instructed the parties to confer and agree upon pretrial deadlines;

WHEREAS, the parties thereafter conferred and agreed upon pretrial deadlines;

WHEREAS, good cause exists to modify the dates in the Fourth Amended Pretrial Scheduling Order in order to conform pretrial deadlines to the dates for the final pretrial conference and the trial;

WHEREAS, the proposed new deadlines conform to the Trial Order and Local Rule 16;

IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel for the parties:

1. All of the dates in the Fourth Amended Pretrial Scheduling Order shall be modified as set forth below.

2 Pursuant to the Trial Order and in compliance with Local Rule 16, all motions in limine shall be filed and served no later than February 24, 2014, four weeks (28 days) prior to the amended pretrial conference date.

3. Pursuant to and in compliance with Local Rule 16, the parties’ Pretrial Conference Order shall be lodged no later than March 13, 2014, 11 days before the amended pretrial conference date.

4. All Memoranda of Contentions of Fact and Law, Exhibit Lists, and Witness Lists shall be submitted no later than March 3, 2014, 21 days prior to the

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JOINT STIPULATION REGARDING PROPOSED FIFTH AMENDED PRETRIAL SCHEDULING ORDER Case No. CV 10-9198 JVS (RNBx)

Case 2:110-cv-09198-JVS-RNB Document 486 Filed 01/02/14 Page 3of4 Page ID #:21780

1]/ amended pretrial conference date.

2 oF Any rebuttal expert disclosures shall be served no later than December 3} 31, 2013.

4 6. Any reply expert disclosures shall be served no later than January 28, 5}) 2014.

6 ie Expert discovery shall close on February 11, 2014. All expert

7|| depositions shall commence no later than February 11, 2014. 8 8. Pursuant to and in compliance with Local Rule 16, the parties’ Trial 9|| Briefs shall be submitted no later than April 1, 2014, seven (7) days before the 10]/ amended trial date. 11 a, The timing and procedures for proposed jury instructions, special 12) verdicts and voir dire questions are set forth in Docket No. 61, pp. 5-6. 13 10. The parties may seek modification of this Order at any time and for

14] good cause shown.

16|| DATED: January 2, 2014 KASOWITZ BENSON TORRES & ‘s FRIEDMAN LLP

18 By: /s/ Charles N. Freiberg

19 Charles N. Freiberg

Attorneys For Plaintiffs 21 JOYCE WALKER, KIM BRUCE HOWLETT, and MURIEL SPOONER, on behalf of

a themselves and all others similarly situated

24 WILMER CUTLER PICKERING HALE AND 25 DORR LLP

26 By: _/s/ Timothy J. Perla

27 Timothy J. Perla

JOINT STIPULATION REGARDING PROPOSED FIFTH AMENDED PRETRIAL SCHEDULING ORDER Case No. CV 10-9198 JVS (RNBx)

Case 2:110-cv-09198-JVS-RNB Document 486 Filed 01/02/14 Page 4of4 Page ID #:21781

Attorneys For Defendant LIFE INSURANCE COMPANY OF THE SOUTHWEST

Nn Nn BP WW WN

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JOINT STIPULATION REGARDING PROPOSED FIFTH AMENDED PRETRIAL SCHEDULING ORDER Case No. CV 10-9198 JVS (RNBx)