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IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
`
`
`In re
`APPRAISAL OF FEDERAL-MOGUL
`HOLDINGS LLC
`
`
`
`
` CONSOLIDATED
`C.A. NO. 2017-0158-AGB
`
`
`STIPULATION AND [PROPOSED] ORDER
`GOVERNING STAY OF DISCOVERY DURING MEDIATION AND NEW
`DEADLINE FOR SUBSTANTIAL COMPLETION OF
`DOCUMENT PRODUCTION
`
`WHEREAS, the parties to this action have agreed to mediate this case on or
`
`about August 16, 2018;
`
`IT IS HEREBY STIPULATED AND AGREED, by the parties hereto,
`
`through their undersigned counsel, subject to the approval of the Court, that:
`
`1.
`
`All discovery, including third-party discovery, is stayed through
`
`August 22, 2018;
`
`2.
`
`The date for XMS Capital to respond to the subpoena issued to it is
`
`extended to September 7, 2018;
`
`3.
`
`The deadline for substantial completion of document production in
`
`response to outstanding discovery requests, currently set for October 31, 2018,
`
`shall now be November 30, 2018; and
`
`4.
`
`Privilege logs, currently due November 21, 2018, shall now be
`
`provided January 7, 2019.
`
`
`
`
`
`EFiled: Jul 19 2018 02:25PM EDT
`Transaction ID 62256594
`Case No. 2017-0158-AGB
`
`
`
`
`
`
`
`

`

`IT IS SO STIPULATED
`
`Dated: July 19, 2018
`
`
`
`
`Of Counsel:
`
`ENTWISTLE & CAPPUCCI LLP
`Vincent R. Cappucci
`Arthur V. Nealon
`Andrew M. Sher
`299 Park Avenue, 20th Floor
`New York, NY 10171
`Phone: (212) 894-7200
`Facsimile: (212) 894-7272
`vcappucci@entwistle-law.com
`anealon@entwistle-law.com
`asher@entwistle-law.com
`
`
`
`
`
`Of Counsel:
`
`HERBERT BEIGEL & ASSOCIATES, LLC
`Herbert Beigel
`38237 S. Arroyo Way
`Tucson, AZ 85739
`Phone: (520) 825-1995
`Facsimile: (212) 894-7272
`hbeigel@me.com
`
`
`
`
`
`
`
`2
`
`
`ROSENTHAL, MONHAIT &
`GODDESS, P.A.
`
`/s/ Norman Monhait
`Norman Monhait (No. 1040)
`919 N. Market Street, Suite 1401
`Wilmington, DE 19801
`Phone: (302) 656-4433
`Facsimile: (302) 658-7567
`nmonhait@rmgglaw.com
`
`
`Counsel for Petitioner
`
`
`
`ASHBY & GEDDES
`
` /s/ Richard D. Heins
`Stephen E Jenkins (No. 2152)
`Richard D. Heins (No. 3000)
`Marie M. Degnan (No. 5602)
`500 Delaware Avenue
`Wilmington, DE 19801
`Phone: (302) 654-1888
`Facsimile: (302) 654-2067
`sjenkins@ashby-geddes.com
`rheins@ashby-geddes.com
`mdegnan@ashby-geddes.com
`
`Counsel for Respondent
`
`
`

`

`IT IS SO ORDERED, this __ day of _______ 2018.
`
`
`
`
`
`
`Andre G. Bouchard
`Chancellor
`
`
`
`3
`
`

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