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 Sanders et al. v. Bristol-Myers Squibb Co. et al., No. CV-14-2652 EDL (N.D. Cal.), and Defendants Bristol-Myers Squibb Company, Sanofi-Aventis U.S. LLC, Sanofi US Services Inc., and Sanofi-Synthelabo Inc.,1 (collectively "Defendants"), 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 June 6, 2014, Plaintiffs filed the Sanders action in the Superior Court of California, San Francisco County;

3. WHEREAS, on June 9, 2014, the Sanders action was removed to this Court by Defendants;

4. WHEREAS, on June 11, 2014, Defendants tagged this case for transfer to the Plavix® MDL and anticipates that the JPML will finalize a conditional transfer order for this case soon; and

5. WHEREAS, the Parties agree that the Sanders 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 Sanders 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.