Document for Ben Aronson 2020 Insurance Trust, Ester Aronson I Tr, Ester Aronson 2020 Insurance Trust, Baruch Aronson I Tr v. Brave Strategies Llc, Penn Mutual Life Insurance Co, Massmutual Life Insurance Co, New York Life Insurance Co

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                                FILED: ROCKLAND COUNTY CLERK 01/31/2024 10:12 AM                                            INDEX NO. 032514/2023
NYSCEF DOC. NO. 29                                                                   RECEIVED NYSCEF: 01/31/2024




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF ROCKLAND

          ESTER ARONSON, ESTER ARONSON in her
          capacity as Trustee for the BEN ARONSON 2020                 Index No. 032514/2023
          INSURANCE TRUST, BARUCH ARONSON, and
          BARUCH ARONSON in his capacity as Trustee for
                                                                       Justice Christie L. D’Alessio
          the ESTER ARONSON 2020 INSURANCE TRUST,

                                         Plaintiffs,                   Stipulation Extending New York
                                                                       Life Insurance Company, Penn
                                    -against-                          Mutual Life Insurance Company,
                                                                       and MassMutual Life Insurance
                                                                       Company’s Time to Respond to
          BRAVE STRATEGIES, LLC, PENN MUTUAL                           the Amended Complaint
          LIFE INSURANCE COMPANY, MASSMUTUAL
          LIFE INSURANCE COMPANY, and NEW YORK
          LIFE INSURANCE COMPANY,

                                         Defendants.



                  WHEREAS, Plaintiffs initially filed this Action on June 6, 2023 in the New York State

          Supreme Court for Rockland County;

                  WHEREAS, Plaintiffs filed an Amended Complaint on January 5, 2024 (“Amended

          Complaint”), which named additional defendants New York Life Insurance Company (“NY

          Life”), The Penn Mutual Life Insurance Company (“Penn Mutual”), and MassMutual Life

          Insurance Company (“MassMutual”) (collectively the “Insurer Defendants”);

                  WHEREAS, NY Life was served with a copy of the Amended Complaint on January 11,

          2024; Penn Mutual was served with a copy of the Amended Complaint on January 10, 2024; and

          MassMutual was served with a copy of the Amended Complaint on January 8, 2024;

                  WHEREAS, the Insurer Defendants acknowledge proper and effective service of the

          summons and Amended Complaint;

                  WHEREAS, pursuant to CPLR §320(a), NY Life’s time to respond to the Amended

          Complaint is January 31, 2024; Penn Mutual’s time to respond to the Amended Complaint is


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FILED: ROCKLAND COUNTY CLERK 01/31/2024 10:12 AM                                               INDEX NO. 032514/2023
NYSCEF DOC. NO. 29                                                                     RECEIVED NYSCEF: 01/31/2024




          February 9, 2024; and MassMutual’s time to respond to the Amended Complaint is February 7,

          2024;

                  WHEREAS, there have been no previous requests for adjournment or extension of the

          Insurer Defendants’ time to respond to the Amended Complaint;

                  IT IS HEREBY STIPULATED AND AGREED, that Plaintiffs and the Insurer

          Defendants shall abide by the following schedule to respond to the Amended Complaint:

                            Event                            Deadlines

                            Deadline To File Answer or       February 23, 2024
                            Motion to Dismiss
                            Response to Motion to            March 25, 2024
                            Dismiss (if any)
                            Reply Brief to Motion to         April 17, 2024
                            Dismiss (if any)
                            Return Date for Motion to        April 19, 2024
                            Dismiss (if any)


                  IT IS FURTHER STIPULATED AND AGREED, that this stipulation may be executed

          in counterparts and that a facsimile or electronic signature shall have the same binding effect on

          all parties hereto as an original signature.




          STIPULATED AND AGREED:




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FILED: ROCKLAND COUNTY CLERK 01/31/2024 10:12 AM                                        INDEX NO. 032514/2023
NYSCEF DOC. NO. 29                                                               RECEIVED NYSCEF: 01/31/2024




           Dated: January 31, 2024

           SWEETNAM, SCHUSTER &                          DENTONS US LLP
           SCHWARTZ LLC
                                                          /s/ T. Carter White
             /s/ Jared Siegel                            T. Carter White
           Jared Siegel                                  DENTONS US LLP
           Daniel Fleming                                1221 Avenue of the Americas, 26th Fl.
           SWEETNAM, SCHUSTER & SCHWARTZ                 New York, New York 10020
           LLC                                           Telephone: (212) 768-6700
           200 Vesey Street                              Fax: (212) 768-6800
           Brookfield Place, 24th Floor                  carter.white@dentons.com
           New York, New York 10281
           Telephone: (646) 952-8600                     Attorneys for Defendant New York Life
           jsiegel@sweetnamlaw.com                       Insurance Company
           dfleming@sweetnamlaw.com

           Attorneys for Plaintiffs

           FISHKIN LUCKS LLP                             STEVENS & LEE, P.C.

           /s/ Zachary W. Silverman                      /s/ Stephanie Lopez
           Zachary W. Silverman                          Stephanie Lopez
           500 7th Avenue, 8th Floor                     669 River Drive
           New York, NY 10018                            Suite 201
           Telephone: (646) 755-9200                     Elmwood Park, New Jersey 07407
           zsilverman@fishkinlucks.com                   Telephone: (201) 857-6768
                                                         Facsimile: (201) 797-2090
           MCDOWELL HETHERINGTON LLP                     Stephanie.lopez@stevenslee.com

           Kendall Burr                                  Attorneys for Defendant Massachusetts
           1001 Fannin, Suite 2400                       Mutual Life Insurance Company
           Houston, Texas 77002
           Telephone: (713) 337-5580
           Kendall.Burr@mhllp.com

           Attorneys for Defendant The Penn Mutual
           Life Insurance Company




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