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

RICHARD SEEBORG, District Judge.

Plaintiff and Defendant stipulate that the date for Defendant to respond to the Complaint shall be extended to April 30, 2016. In support of this request, the parties state:

This is one of a number of lawsuits filed in various federal courts alleging that the plaintiff's use of Viagra caused him to develop melanoma. On December 11, 2015, several of these plaintiffs filed a petition with the Judicial Panel on Multidistrict Litigation ("JPML"), requesting that all such lawsuits be coordinated for pretrial purposes in an MDL proceeding, and suggesting that the MDL be established in the Northern District of California.

On December 22, 2015, Defendant responded to the petition, agreeing that an MDL proceeding would be appropriate and that the Northern District of California would be an appropriate venue for the MDL.

Plaintiff's petition will be heard at the next JPML hearing, on March 31, 2016 in Santa Barbara.

To ensure that the Court and the parties do not needlessly expend resources before the JPML decides which court and judge will preside over the expected MDL proceeding, the parties believe it is sensible to extend the time for Defendant to respond to Plaintiff's Complaint to April 30, 2016. By that date, the parties expect that an MDL proceeding will be established, and that the MDL court will later establish a global process for the filing of and responses to complaints.

I, Matthew A. Holian, am the ECF user whose identification and password are being used to file the foregoing Stipulation And [Proposed] Order Continuing Deadline To Respond To Complaint. I hereby attest that the above-referenced signatory to this stipulation has concurred in this filing.

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 April 30, 2016.