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STIPULATION AND ORDER CONTINUING CLASS CERTIFICATION BRIEFING SCHEDULE ?? ??Error! No property name supplied.?? ?? ?? ??

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WATERS KRAUS & PAUL 

INGRID M. EVANS (179094) 

ievans@waterskraus.com

SUNDEEP PATEL (242284) 

spatel@waterskraus.com 

711 Van Ness Avenue, Suite 220 

San Francisco, CA 94102 

Telephone: (415/296-6060 or 

800/226-9880

214/777-0470 (fax) 

BONNETT, FAIRBOURN, FRIEDMAN & BALINT P.C. 

ANDREW S. FRIEDMAN (Pro Hac Vice admission)

afriedman@bffb.com 

KIMBERLY C. PAGE (Pro Hac Vice admission)

kpage@bffb.com 

2901 N. Central Avenue, Suite 1000 

Phoenix, AZ 85012 

Telephone: 602/274-1100 

602/274-1199 (fax) 

Attorneys for Plaintiff and the Putative Class 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

DAPHNE P. RAND, by and through DEBRA 

J. DOLCH, as Conservator of the Person and 

Estate of DAPHNE P. RAND, Conservatee, 

on Behalf of Themselves and All Others 

Similarly Situated. 

Plaintiff, 

vs.

AMERICAN NATIONAL INSURANCE 

COMPANY, a Texas corporation. 

Defendant.

Case No. CV 09 0639 SI 

CLASS ACTION

STIPULATION AND [PROPOSED] 

ORDER MODIFYING THE COURT’S 

SCHEDULING ORDER 

Judge Susan Illston 

Action Filed: 02/12/09 

This stipulation is made between Plaintiff DAPHNE P. RAND, by and through DEBRA J. 

DOLCH, as Conservator of the Person and Estate of DAPHNE P. RAND, Conservatee, 

(“Plaintiff”) and Defendant American National Insurance Company (“ANICO” or “Defendant”), 

Case 3:09-cv-00639-SI Document 87 Filed 02/23/10 Page 1 of 3
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STIPULATION AND ORDER CONTINUING CLASS CERTIFICATION BRIEFING SCHEDULE ?? ??Error! No property name supplied.?? ?? ?? ??

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by and through their respective counsel of records, with respect to the following facts: 

WHEREAS, the Court’s Civil Pretrial Minute Order dated November 13, 2009 (Docket 

No. 78) sets forth the current scheduling order.

WHEREAS, the parties stipulated to a one week extension of time for ANICO to respond 

to the Court’s February 9, 2010 Discovery Order concerning contact information for absent class 

members. 

WHEREAS, the parties are still conducting discovery and believe that the current 

scheduling order should be modified to allow for completion of discovery, resolution of any 

discovery disputes and any other matters; 

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and among the 

parties, through their undersigned counsel, that the parties request a revised schedule as follows:

Current Date Proposed Date 

Hearing on Motion for Class Certification June 9, 2010 September 1, 2010 

Motion due May 5, 2010 June 24, 2010 

Opposition due May 19, 2010 August 9, 2010 

Reply due May 26, 2010 August 23, 2010 

The parties agree to vacate the expert designation and rebuttal expert designation deadlines as well 

as the expert discovery cut-off. Instead, Plaintiff will designate experts concurrently with the 

filing of her motion for class certification and Defendant will designate its rebuttal experts 

concurrently with the filing of its opposition. 

DATED: February 19, 2010 BONNETT, FAIRBOURN, FRIEDMAN & BALINT P.C. 

By: /s/Andrew S. Friedman 

 ANDREW S. FRIEDMAN 

Attorneys for Plaintiff DAPHNE P. RAND, by and 

through DEBRA J. DOLCH, as Conservator of the 

Person and Estate of DAPHNE P. RAND, Conservatee

Case 3:09-cv-00639-SI Document 87 Filed 02/23/10 Page 2 of 3
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STIPULATION AND ORDER CONTINUING CLASS CERTIFICATION BRIEFING SCHEDULE ?? ??Error! No property name supplied.?? ?? ?? ??

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DATED: February 19, 2010 WATERS KRAUS & PAUL 

 By: /s/Ingrid M. Evans 

 INGRID M. EVANS 

Attorneys for Plaintiff DAPHNE P. RAND, by and 

through DEBRA J. DOLCH, as Conservator of the 

Person and Estate of DAPHNE P. RAND, Conservatee

DATED: February 19, 2010 WILSON ELSER MOSKOWITZ EDELMAN & DICKER

 By: /s/Thomas M. Herilhy with permission 

 THOMAS M. HERILHY 

Attorneys for Defendant AMERICAN NATIONAL 

INSURANCE COMPANY 

IT IS SO ORDERED. 

DATED: ____________________ 

 By 

The Honorable Susan Illston 

 District Court Judge 

Case 3:09-cv-00639-SI Document 87 Filed 02/23/10 Page 3 of 3