JOINT STIPULATION AND [PROPOSED] ORDER TO TRANSFER CASE TO THE SOUTHERN DISTRICT OF CALIFORNIA PURSUANT TO 28 U.S.C. § 1404(a)

LAUREL BEELER, District Judge.

Plaintiff Tatiana Korolshteyn ("Plaintiff") and Defendant Costco Wholesale Corporation ("Defendant"), by and through their respective counsel, hereby stipulate as follows:

A. As set forth in the Notice filed by Defendant on January 26, 2015, on January 9, 2015, Defendant filed a Notice of Related Action in connection with a pending motion to transfer and consolidate with the Judicial Panel on Multidistrict Litigation ("Panel"), MDL 2608. The MDL motion seeks to transfer and consolidate this and other related Gingko Biloba class actions in the United States District Court for the Southern District of California.

B. As set forth in that same Notice, Plaintiff joined in Defendant's MDL motion seeking transfer and consolidation.

C. The Panel heard oral argument on the MDL Motion on March 26, 2015 in San Diego, California.

D. In light of the agreement by all the parties that the various pending matters should be heard by the same judge in the United States District Court for the Southern District of California, the Panel ordered the parties to simply proceed via stipulation to transfer pursuant to 28 U.S.C. § 1404.

NOW, THEREFORE, PLAINTIFF AND DEFENDANT STIPULATE THAT:

This case be transferred to Judge Cathy Ann Bencivengo of the United States District Court for the Southern District of California.

PURSUANT TO STIPULATION, IT IS SO ORDERED.