1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JONATHAN A. SHAPIRO (257199) WILMER CUTLER PICKERING HALE AND DORR LLP 950 Page Mill Road Palo Alto, CA 94304 Tel: (650) 858-6101 Fax: (650) 858-6100 jonathan.shapiro@wilmerhale.com ANDREA J. ROBINSON (PRO HAC VICE) TIMOTHY J. PERLA (PRO HAC VICE) WILMER CUTLER PICKERING HALE AND DORR LLP 60 State Street Boston, MA 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 SOUTHERN DIVISION JOYCE WALKER, KIM BRUCE HOWLETT, and MURIEL SPOONER, on behalf of themselves and all others similarly situated, Plaintiffs, vs. LIFE INSURANCE COMPANY OF THE SOUTHWEST, a Texas corporation, and DOES 1-50 Defendant. CLASS ACTION CASE NO.: CV 10-9198 JVS (RNBx) Formerly Case No.: 3:10-cv -04852 JSW from Northern District of California JOINT STIPULATION REQUESTING CONTINUATION OF HEARING ON PLAINTIFFS’ MOTION FOR REVIEW OF MARCH 20, 2012 DISCOVERY ORDER TO MAY 8, 2012 Judge James V. Selna Courtroom: 10C Discovery Cutoff: November 5, 2012 Pretrial Conference: January 14, 2013 Trial Date: January 22, 2013 Case 2:10-cv-09198-JVS -RNB Document 192 Filed 04/05/12 Page 1 of 3 Page ID #:7973 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -1- Application to Continue Hearing WHEREAS on April 3, 2012, Plaintiffs filed a Motion for Review of the Magistrate Judge’s March 20, 2012 Discovery Order and set that Motion to be heard on Monday, May 7, 2012; WHEREAS lead counsel for Life Insurance Company of the Southwest would have a scheduling conflict on May 7, 2012, if the Court requires oral argument on Plaintiffs’ Motion; WHEREAS Plaintiffs desire that their Motion for Review be heard before Monday, May 14, 2012, the date on which their motion for class certification is due; IT IS THEREFORE JOINTLY AND RESPECTFULLY REQUESTED, by and between Plaintiffs Joyce Walker, Kim Bruce Howlett, and Muriel Spooner, and defendant Life Insurance Company of the Southwest, through their respective attorneys of record, that the hearing on Plaintiffs’ Motion for Review of the March 20, 2012 Discovery Order, which was noticed for Monday, May 7, 2012, be specially set for Tuesday, May 8, 2012 at a time to be determined by the Court. Dated: April 5, 2012 Respectfully requested, WILMER CUTLER PICKERING HALE AND DORR LLP By: /s/ Jonathan Shapiro Jonathan A. Shapiro Attorneys for Defendant LIFE INSURANCE COMPANY OF THE SOUTHWEST KASOWITZ, BENSON, TORRES & FRIEDMAN LLP By: /s/ Brian P. Brosnahan Brian P. Brosnahan Charles N. Freiberg Jacob N. Foster Case 2:10-cv-09198-JVS -RNB Document 192 Filed 04/05/12 Page 2 of 3 Page ID #:7974 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- Application to Continue Hearing Attorneys for Plaintiffs JOYCE WALKER, KIM BRUCE HOWLETT, and MURIEL SPOONER, on behalf of themselves and all others similarly situated ACTIVEUS 94393519v1 Case 2:10-cv-09198-JVS -RNB Document 192 Filed 04/05/12 Page 3 of 3 Page ID #:7975