Filing 6

MEMORANDUM re 4 MOTION to Compel Production of Documents filed by SEAN LAMAR SMITH, BRUCE SCHWAGER, PIO SAGAPOLUTELE by PIO SAGAPOLUTELE, SEAN LAMAR SMITH, BRUCE SCHWAGER. (Attachments: # 1 Exhibit Exhibit A, # 2 Exhibit Exhibit B, # 3 Exhibit Exhibit C, # 4 Exhibit D, # 5 Exhibit Exhibit E, # 6 Exhibit Exhibit F)(Smith, Cyril)

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND (Northern Division) PIO SAGAPOLUTELE, et al., Plaintiffs v. THE BERT BELL/PETE ROZELLE NFL PLAYER RETIREMENT PLAN, et al., Defendants. * * * * * * * * * * Civil Action No. WMN -08-01870 * * * * * * * * * * STIPULATION AND ORDER The parties, by their undersigned counsel, stipulate and agree as follows: 1. Subject to the provisions of paragraph 2 and the Court's ruling on Defendants' Motion for Protective Order (D.E. # 13) (the "Motion"), the time for Defendants to respond to Plaintiffs' Interrogatories and Requests for Production of Documents is extended to ten business days after the Court's ruling on the Motion. 2. No later than October 20, 2008, Defendants shall produce to Plaintiffs a copy of the complete administrative records for each of the three Plaintiffs. 3. Defendants shall forthwith withdraw their Motion to Stay Discovery (D.E. # 15). Dated: October 3, 2008 EXHIBIT C 1995175.1 /s/ Cyril V. Smith Federal Bar No. 07332 William K. Meyer Federal Bar No. 01214 Zuckerman Spaeder LLP 100 East Pratt Street, Suite 2440 Baltimore, MD 21202 (410) 332-0444 Attorneys for Plaintiffs /s/ Douglas W. Ell Admitted pro hac vice Edward A. Scallet Federal Bar No. 08479 Hisham M. Amin Federal Bar No. 15570 Groom Law Group, Chartered 1701 Pennsylvania Avenue, N.W. Suite 1200 W ashington, DC 20006 (202) 857-0620 Attorneys for Defendants SO ORDERED: ______________________________________ William M. Nickerson, District Judge 1995175.1

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