AMENDED STIPULATION AND ORDER STAYING DISCOVERY AND DISCLOSURES

RICHARD SEEBORG, District Judge.

Pursuant to Civil Local Rule 7-12, Plaintiff Sandoz Inc. ("Sandoz") and Defendants Amgen Inc. and Amgen Manufacturing, Limited (collectively, "Amgen"), through their undersigned counsel, hereby stipulate as follows:

WHEREAS, Sandoz filed a Complaint for Declaratory Judgment of Patent Noninfringement and Invalidity (ECF No. 1) with respect to Sandoz's biosimilar filgrastim and pegfilgrastim products on February 21, 2019;

WHEREAS, Amgen filed a Motion to Dismiss (ECF No. 22) on April 24, 2019;

WHEREAS, Sandoz intends to oppose the Motion to Dismiss;

WHEREAS, the parties agree that it would promote judicial economy and conserve the resources of the Court and the parties to defer discovery and disclosures until after the Motion to Dismiss is resolved;

NOW, THEREFORE, the parties hereby stipulate and request that the Court stay discovery and disclosures as follows:

1. While the Motion to Dismiss is pending, all deadlines shall be stayed for: (a) responding to discovery requests pursuant to Fed. R. Civ. P. 26 through 37; (b) initial disclosures pursuant to Fed. R. Civ. P. 26(a)(1); and (c) contentions and disclosures pursuant to Patent Local Rules 3-1 through 3-9.

2. If the Motion to Dismiss is denied, the parties shall promptly meet and confer on a schedule for completing the stayed discovery and disclosures, with the deadlines for disclosures and contentions beginning no later than 30 days after the ruling on the Motion to Dismiss. The parties shall submit their proposed schedule to the Court within 10 days after the ruling on the Motion to Dismiss.

SIGNATURE ATTESTATION

Pursuant to Civil Local Rule 5-1(i)(3), I hereby certify that concurrence in the filing of this document has been obtained from each of the other Signatories shown above.

PURSUANT TO STIPULATION, IT IS SO ORDERED.