STIPULATION RE FILING OF FIRST AMENDED COMPLAINT AND DISMISSAL OF CLAIMS AGAINST NOVARTIS AG AND NOVARTIS CORPORATION

MATTHEW B. GEORGE, District Judge.

Plaintiffs Julie Winkelmann and Michelle Cruz and Defendants Novartis Consumer Health, Inc. ("NCH") and Novartis Corporation, by and through their undersigned counsel, stipulate as follows:

WHEREAS Plaintiffs' complaint was served on NCH and Novartis Corporation on January 27, 2014.

WHEREAS Plaintiffs' complaint has not been served on Novartis AG.

WHEREAS the parties previously stipulated (Dkt No. 13) to extend the date for the Defendants that were served, NCH and Novartis Corporation, to answer, move or otherwise plead until March 20, 2014. On March 20, NCH filed an Answer (Dkt. No. 14) and Novartis Corporation filed a Motion to Dismiss (Dkt. No. 15).

WHEREAS NCH and Novartis Corporation consent, pursuant to Federal Rule of Civil Procedure 15(a)(2), to Plaintiffs filing a First Amended Complaint which will include an additional plaintiff, Thamar S. Cortina.

WHEREAS NCH and Novartis Corporation consent, pursuant to Federal Rule of Civil Procedure 41(a)(1), to Plaintiffs' dismissal of defendants Novartis Corporation and Novartis AG without prejudice. Plaintiffs' First Amended Complaint will not name Novartis Corporation or Novartis AG as a defendant.

WHEREAS, pursuant to Local Rule 6-1(a), the parties agree to extend the time within which NCH shall answer, move, or otherwise plead in response to the First Amended Complaint.

WHEREAS, pursuant to Local Rules 6-1(b) and 6-2, the parties agree to modify the time within which Plaintiffs must file an opposition, if appropriate, to NCH's responsive pleading. The parties also agree to modify the time within which NCH must file a reply brief in support of its responsive pleading.

WHEREAS this stipulation does not waive any defenses including without limitation challenges to jurisdiction or venue.

PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 15(a)(2) AND LOCAL RULE 6-1(a), IT IS STIPULATED AND AGREED THAT:

PURSUANT TO LOCAL RULE 6-1(b), IT IS STIPULATED AND AGREED THAT:

Pursuant to Local Rule 6-2, a declaration is submitted with this stipulation.

PURSUANT TO STIPULATION, IT IS SO ORDERED

Attestation Statement

Pursuant to the Local Rule 5-1(i)(3), I hereby attest that I have received permission from all signatories listed in this document to enter a conformed signature, and have obtained their concurrence in the filing of this document. I further attest that I have on file and will maintain all records to support this concurrence.