• 

Jonathan M. Kom 

BLANK ROME LLP 

301 Carnegie Center, 3rd Floor 

Princeton, NJ 08540 

(609) 750-7700 (Phone) 

(609) 750-7701 (Fax) 

Korn(d)B I an kRome.com 

James N. Benedict (Pro Hac Vice) 

Sean M. Murphy (Pro Hac Vice) 

Robert C. Hora (Pro Hac Vice) 

MILBANK, TWEED, HADLEY & MCCLOY LLP 

1 Chase Manhattan Plaza 

New York, NY. 10005 

(212) 530-5000 (Phone) 

(212) 530-5219 (Fax) 

Attorneys for Defendants 

RECEIVED 

JUN 1 0 2014 

t\' ~:3r. M 'tl;-\:\1~ T WALSH CLERK 

UNITED STATES DISTRICT COURT 

DISTRICT OF NEW JERSEY 

MARY ANN SIVOLELLA, for the use and benefit of the 

EQ/Common Stock Index Portfolio, the EQ/Equity Growth PLUS 

Portfolio, the EQ!Equity 500 Index Portfolio, the EQ/Large Cap 

Value PLUS Portfolio, the EQ/Giobal Multi-Sector Equity 

Portfolio, the EQ/Mid Cap Value PLUS Portfolio, the 

EQ/GAMCO Small Company Value, and the EQ/Intermediate 

Government Bond Index Portfolio, Civil Action No. 3: 11-cv-04194 (PGS DEA) 

Plaintiff, and 

vs. Civil Action No. 3: 13-cv-00312 (PGS) 

AXA EQUITABLE LIFE INSURANCE COMPANY and AXA 

EQUITABLE FUNDS MANAGEMENT GROUP, LLC, 

Defendants. 

GLENN D. SANFORD, et al., 

Plaintiffs, 

vs. 

AXA EQUITABLE FUNDS MANAGEMENT GROUP, LLC 

Defendant. 

CONSENT ORDER EXTENDING EXPERT 

DEADLINES 

ELECTRON! CALLY FILED 

Case 3:13-cv-00312-PGS-DEA Document 44 Filed 06/10/14 Page 1 of 3 PageID: 974
_) 

THIS MATTER having been brought before the Court by consent of the parties, as 

appears from the signature of their respective counsel of record below, and for good cause 

having been shown: 

WHEREAS, on November 16, 2012 (the "November 2012 Order"), the. Court entered a 

Pretrial Scheduling Order [Docket No. 33] setting deadlines relating to expert discovery; 

WHEREAS, on April 9, 2014, the Court entered a subsequent Pretrial Sch~duling Order 

[Docket No. 80] extending certain of the deadlines relating to expert discovery; 

WHEREAS, the parties stipulate and agree that the deadline for Plaintiffs to serve expert 

disclosures and reports may be extended to June 11, 20 14; 

WHEREAS, the parties stipulate and agree that the deadline for Defendants to serve 

expert disclosures and reports may be extended to August 8, 2014, which is consistent with the 

60-day timeframe for Defendants' expert disclosures and reports in the November 2012 Order; 

WHEREAS, the parties further stipulate and agree that Plaintiffs may serve rebuttal 

expert disclosures and reports that respond to the matters raised in Defendants' expert 

disclosures and reports and do not raise new issues by August 29, 2014; 

WHEREAS, the parties further stipulate and agree that the deadline for completing 

expert depositions may be extended to October 28, 20 14; 

IT IS on this _9'!-ctay of June, 2014; 

ORDERED that Plaintiffs must serve expert disclosures and reports by June 11, 20 14; 

FURTHER ORDERED that Defendants shall serve expert disclosures and reports by 

August 8; 2014; 

FURTHER ORDERED that Plaintiffs shall serve any rebuttal expert disclosures and 

reports, which are responsive to Defendants' disclosures and reports and do not raise new issues, 

by August 29, 2014; - 1 

i>I.JeA~~- FuRTHER ORDERED that expert depositions shall be completed by Oet~bet 28, 2814. / 

Case 3:13-cv-00312-PGS-DEA Document 44 Filed 06/10/14 Page 2 of 3 PageID: 975
• 

The undersigned counsel for Plaintiffs and Defendants hereby consent to the entry of this 

Order. 

Sl DANIELS. SWEETSER 

Daniel S. Sweetser, Esquire 

Szaferman, Lakind, Blumstein & Blader 

I 0 I Gravers Mill Road, Suite 200 

Lawrenceville, NJ 08648 

Phone: (609) 275-0400 

Fax: (609) 275-45II 

E-Mail: DSweetser@Szaferman.com 

Attorneys for Plaintiffs 

Dated: June 5, 2014 

s/ JoNATHAN M KoRN 

Jonathan M. Korn, Esquire 

Blank Rome LLP 

30 I Carnegie Center, 3rd Floor 

Princeton, NJ 08540 

Phone: (609) 750-7707 

Fax: (609) 897-7395 

E-Mail: Korn@BlankRome.com 

Attorneys for Defendants 

Dated: June 5, 2014 

Case 3:13-cv-00312-PGS-DEA Document 44 Filed 06/10/14 Page 3 of 3 PageID: 976