STIPULATION AND [PROPOSED] ORDER FOR VOLUNTARY DISMISSAL PURSUANT TO F.R.C.P. 41(a)(1)(A)(ii) AS MODIFIED Complaint Filed: December 12, 2014

VINCE CHHABRIA, District Judge.

Undersigned Plaintiff's counsel: (1) having failed to receive documentation necessary to continue the prosecution of this action despite repeated and reasonable efforts to obtain such documentation from Plaintiff; (2) having lost contact with Plaintiff despite reasonable and substantial efforts; and (3) having informed Plaintiff by letter of the intent to cease representation as her legal counsel;

IT IS HEREBY STIPULATED AND AGREED by Plaintiff Windy Garland, by and through her undersigned counsel, and Defendants Johnson & Johnson, Janssen Research & Development, LLC (formerly known and incorrectly named as "Johnson & Johnson Pharmaceutical Research & Development, L.L.C."), Janssen Pharmaceuticals, Inc. (formerly known and incorrectly named as "Ortho-McNeil-Janssen Pharmaceuticals, Inc."), and McKesson Corporation, by and through their undersigned counsel, that the above-captioned action is voluntarily dismissed without prejudice as to the Defendants without costs or fees to any party. It is further stipulated and agreed between the undersigned that if Plaintiff refiles this action in this Court (or a California state court if plaintiff's change of residence to California destroys diversity jurisdiction in the future) prior to January 1, 2019, the action will be deemed filed as of December 12, 2014 for statute of limitations purposes.

[PROPOSED] ORDER AS MODIFIED

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Counsel for the plaintiff must transmit this order to the plaintiff through every available means, and must file a declaration with the Court, within 5 days of the date of this order, documenting the ways in which the order was transmitted to the plaintiff.