STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO RESPOND TO COMPLAINT

RICHARD SEEBORG, District Judge.

On December 11, 2015, several Plaintiffs, without opposition, moved the Judicial Panel on Multidistrict Litigation ("JPML") to transfer and coordinate 15 actions, including the instant action and any "tag-along" actions, in the United States District Court for the Northern District of California, pursuant to 28 U.S.C. §1407. Defendants agree that coordination is appropriate and that the Northern District of California is a suitable venue. See Case MDL No. 2691, Dkt. 1 through 1-4.

On December 28, 2015, with briefing essentially complete in support of Plaintiffs' unopposed motion to transfer, the parties jointly moved the JPML for expedited consideration of Plaintiffs' unopposed motion on the January 28, 2016 hearing session. See Case MDL No. 2691, Dkt. 16.

On December 29, 2015, the motion for expedited consideration was denied by the JPML. See Case MDL No. 2691, Dkt. 19. The next scheduled hearing session for the JPML is March 31, 2016.

Defendant Pfizer Inc.'s current deadline to respond to the complaint in this matter is February 2, 2016. The parties have not previously requested an extension of time for any deadlines in this matter.

To avoid unnecessary pleadings and provide the JPML with the time it requires to rule on the parties' pending motion to transfer, defendant Pfizer Inc. and Plaintiff Lance Warren wish to stipulate to extend Pfizer's deadline to respond to the Complaint until sixty (60) days after a ruling by the JPML on Plaintiffs' motion to transfer.

This stipulation will require the Court to reschedule the case management conference currently scheduled for April 14, 2016 at 10:00 A.M. in Courtroom 3 to a later date.

Based on the foregoing and pursuant to Local Rule 6-2 of the Northern District of California, the parties stipulate and agree to extend Pfizer's deadline to respond to Plaintiff's complaint in this matter until sixty (60) days after the JPML rules on Plaintiffs' motion to transfer, described above.

ORDER

PURSUANT TO STIPULATION OF THE PARTIES, IT IS ORDERED:

The time for Defendant Pfizer Inc. to respond to Plaintiff's complaint in this action is continued until sixty (60) calendar days after the Judicial Panel on Multidistrict Litigation ("JPML") issues its ruling on Plaintiffs' pending motion to transfer and coordinate 15 actions, including the instant action and any "tag-along" actions, in the United States District Court for the Northern District of California, pursuant to 28 U.S.C. §1407.

The case management conference currently scheduled in this case for April 14, 2016 at 10:00 A.M. in Courtroom 3 will be rescheduled to a date as determined and ordered by this Court.