STIPULATION & [PROPOSED] ORDER TO MODIFY BRIEFING SCHEDULE AND HEARING DATE FOR MOTION TO COMPEL ARBITRATION AND TO STAY STIPULATION & [PROPOSED] ORDER TO MODIFY BRIEFING SCHED. & HEARING DATE FOR MOTION TO COMPEL

EDWARD M. CHEN, District Judge.

Plaintiff AbbVie Inc. ("AbbVie"), Defendant Novartis Vaccines and Diagnostics, Inc. ("Novartis") and Defendant Grifols Worldwide Operations Ltd. ("Grifols") file this stipulated request and respectfully ask the Court to modify the briefing schedule for Defendant Novartis's Motion to Compel Arbitration and to Stay ("Motion to Compel Arbitration"). As grounds, the parties state as follows:

On June 5, 2017, Novartis filed its Motion to Compel Arbitration (ECF No. 48) in this case. In view of the schedules of counsel and with consideration to the Court's schedule over the coming months, the undersigned counsel met, conferred and agreed to extend the briefing schedule and hearing date as follows:

In addition, on June 5, 2017, the parties also filed a stipulated request to stay the proceedings in this case pending resolution of the Motion To Compel Arbitration and to Stay, which the Court granted on June 6, 2017. (ECF No. 53) ("Pursuant to Stipulation, all scheduling requirements are stayed until the Court issues its ruling on Novartis' Motion To Compel Arbitration and to Stay"). On that same date, however, a Clerk's Notice was entered stating that the Case Management Conference is reset to August 24, 2017 with the Case Management Statement due on August 17, 2017. (ECF No. 54) Given the Court's June 6, 2017 Order staying "all scheduling requirements" in this case "until the Court issues its ruling on Novartis' Motion To Compel Arbitration and to Stay," the parties respectfully request that the June 6, 2017 Clerk's Notice setting the Case Management Conference be vacated.

Grifols respectfully continues to reserve its right to challenge service of process in this case.

WHEREFORE, the parties respectfully request that, for good cause shown, the Court grant this stipulated request.

SIGNATURE ATTESTATION

Pursuant to General Order 45.X(B), I hereby attest that concurrence has been obtained from Gregory K. Sobolski and Andrea Meghrouni-Brown indicated by the "conformed" signatures (/s/) within this e-filed document.

[PROPOSED] ORDER

Pursuant to Stipulation, the briefing schedule for Novartis' Motion to Compel Arbitration and to Stay has been modified as follows:

In addition, the Clerk's Notice dated June 6, 2017 (ECF No. 54) setting a date for the Case Management Conference is hereby VACATED.

IT IS SO ORDERED.