JOINT STIPULATION AND [PROPOSED] ORDER TO STAY LITIGATION PENDING TRANSFER TO THE PLAVIX® MDL

RICHARD SEEBORG, District Judge.

This Joint Stipulation is made by and between Plaintiffs in Bustamante et al. v. Bristol-Myers Squibb Co. et al., No. CV-13-5586 RS (N.D. Cal.), and Defendant Bristol-Myers Squibb Company ("BMS") (collectively "the Parties"), by and through the undersigned counsel of record, with reference to the following facts:

1. WHEREAS, on February 12, 2013, the Judicial Panel on Multidistrict Litigation ("JPML") established a multidistrict Plavix® litigation in the District of New Jersey, assigned to Judge Freda Wolfson;

2. WHEREAS, on November 27, 2013, Plaintiffs filed the Bustamante action in the Superior Court of California, San Francisco County;

3. WHEREAS, on December 3, 2013, the Bustamante action was removed to this Court by Defendant BMS;

4. WHEREAS, on December 9, 2013, Defendant BMS tagged this case for transfer to the Plavix® MDL and anticipates that the JPML will issue a conditional transfer order for this case soon; and

5. WHEREAS, the parties agree that the Bustamante action should be stayed pending its anticipated transfer to the Plavix® MDL in the District of New Jersey.

THEREFORE, IT IS HEREBY STIPULATED AND AGREED, subject to the Court's approval, that the Bustamante action should be stayed pending its anticipated transfer to the Plavix® MDL in the District of New Jersey.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, IT IS SO ORDERED. I, Jeremy M. McLaughlin, am the ECF User whose ID and password are being used to file this Stipulation and [Proposed] Order to Stay Litigation Pending Transfer to the Plavix® MDL. In compliance with General Order 45, X.B, I hereby attest that Joshua C. Ezrin has concurred in this filing.