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 Caddell et al. v. Bristol-Myers Squibb Co. et al., No. CV-14-3482 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 July 31, 2014, Plaintiffs filed the Caddell action in the Superior Court of California, San Francisco County;

3. WHEREAS, on August 1, 2014, the Caddell action was removed to this Court by Defendant BMS;

4. WHEREAS, on August 12, 2014, 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 Caddell 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 Caddell 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.