STIPULATION AND ORDER TO STAY CASE AND DEFER ALL DEADLINES PENDING MOTION TO TRANSFER ACTIONS TO THE DISTRICT OF NEW JERSEY PURSUANT TO 28 U.S.C. § 1407 FOR COORDINATED OR CONSOLIDATED PRETRIAL PROCEEDINGS

ERICA P. GROSJEAN, Magistrate Judge.

Plaintiffs, John Judson and Jo Ann Hamel, and Defendants, Prinston Pharmaceutical Inc. ("Prinston"), Solco Healthcare U.S., LLC ("Solco"), Huahai U.S., Inc. ("Huahai"), and Teva Pharmaceuticals USA, Inc. ("Teva") (collectively, "Defendants"),1 by and through their undersigned counsel, hereby stipulate and request that this Court stay all deadlines in this case pending a ruling by the Judicial Panel on Multidistrict Litigation ("JPML") on Plaintiff Robert Kruk's Motion to Transfer Actions to the District of New Jersey Pursuant to 28 U.S.C. § 1407 in In re: Valsartan N-Nitrosodimethylamine (NDMA) Prods. Liab. Litig., MDL No. 2875 (J.P.M.L. Oct. 22, 2018):

1. Plaintiff's Complaint was filed on October 11, 2018.

2. This case is one of at least eighteen putative federal class action lawsuits involving the medication Valsartan.

3. On October 22, 2018, Plaintiff in Kruk v. Zhejiang Huahai Pharmaceutical Co., Ltd., et al., No. 18-cv-005944 (N.D. Ill.) filed in the JPML a Motion to Transfer Actions to the District of New Jersey Pursuant to 28 U.S.C. § 1407 for Coordinated or Consolidated Pretrial Proceedings. See In re: Valsartan N-Nitrosodimethylamine (NDMA) Prods. Liab. Litig., MDL No. 2875 (J.P.M.L. Oct. 22, 2018) (the "Motion to Transfer," attached as Exhibit A).2

4. Plaintiff in the Kruk action seeks an order from the JPML transferring NDMA-related Valsartan litigation to the District of New Jersey, including this case, and consolidating those cases or coordinating their pretrial proceedings pursuant to § 1407(a).

5. In the interest of judicial economy, and to avoid the risk of inconsistent pretrial rulings, duplicative discovery obligations, inconsistent or overlapping class certification rulings, and to promote the just and efficient conduct of this litigation, the Parties wish to stay this case pending a ruling from the JPML on the Motion to Transfer.

6. The JPML is scheduled to hold a hearing on the Motion to Transfer on January 31, 2019.3 As such, a stay pending the JPML's ruling would be limited, would last for a brief, definite period, and will not result in undue prejudice to any of the Parties.

7. Plaintiffs and all served Defendants consent to this request, and no party will be prejudiced by a stay of the case.

NOW, THEREFORE, Plaintiff and Defendants, through their attorneys of record, request this Court stay this case and defer all deadlines. A proposed order is attached to this Motion.

IT IS SO STIPULATED

ORDER

This matter having come before the Court on the stipulation of Plaintiffs, John Judson and Jo Ann Hamel, and Defendants, Prinston Pharmaceutical Inc., Solco Healthcare U.S., LLC, Huahai U.S., Inc., and Teva Pharmaceuticals USA, Inc. IT IS HEREBY ORDERED:

1. The stipulated request is granted;

2. All deadlines are VACATED until further order of Court;

3. This action is STAYED pending the ruling by the Judicial Panel on Multidistrict Litigation on the Motion to Transfer Actions to the District of New Jersey Pursuant to 28 U.S.C. § 1407 in In re: Valsartan N-Nitrosodimethylamine (NDMA) Prods. Liab. Litig., MDL No. 2875 (J.P.M.L. Oct. 22, 2018); and

4. The Parties shall file a status report within seven days of the JPML's ruling, apprising the Court of the JPML's decision.

IT IS SO ORDERED.