Eesa et al v. Johnson & Johnson et al

Filing 12

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr., on 11/14/23 EXTENDING the deadline to 12/15/23 for defendants to respond to Plaintiffs' Complaint. (Kastilahn, A)

1 ALEXANDER G. CALFO (SBN 152891)
[e-mail]
2 JULIA E. ROMANO (SBN 260857)
[e-mail]
3 KING & SPALDING LLP
633 West 5th Street, Suite 1600
4 Los Angeles, CA 90071
5 Telephone: [phone]
Facsimile:
[phone]
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Attorneys for Defendants
7 JOHNSON & JOHNSON; JOHNSON &
JOHNSON HOLDCO (NA) INC.;
8 JANSSEN PHARMACEUTICALS,
INC.; KENVUE, INC.; and LTL
9 MANAGEMENT LLC
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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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AFRAA AL EESA, Individually and as
13 Successor-in-Interest to ABBAS AL
KHALIDI, Deceased, A.A.K., A.A.K., and
14 Y.A.K.
Plaintiffs,

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v.

17 JOHNSON & JOHNSON; JOHNSON &
JOHNSON HOLDCO (NA) INC. f/k/a
18 JOHNSON & JOHNSON CONSUMER
INC. (sued individually and as successor-in19 interest to Johnson & Johnson subsidiary
“Old JJCI”); JANSSEN
20 PHARMACEUTICALS, INC. (sued
individually and as successor-in-interest to
21 Johnson & Johnson subsidiaries named
JOHNSON & JOHNSON CONSUMER
22 INC. both prior to and after its 2021
restructurings and colloquially knows as
23 “Old JJCI and New JJCI”); KENVUE INC.
(sued individually and as successor-in24 interest to JOHNSON & JOHNSON
CONSUMER INC.); LTL
25 MANAGEMENT LLC; and DOES 1-450,
inclusive
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Defendants.
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Case No. 2:23-cv-02183-MCE-JDP
JOINT STIPULATION TO EXTEND
DEFENDANTS’ TIME TO RESPOND
TO PLAINTIFFS’ COMPLAINT;
ORDER
Complaint Filed:
Trial Date:
Current Rep. Date.
Proposed Resp. Date

Oct. 2, 2023
None Set
Nov. 16, 2023
Dec. 15, 2023

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JOINT STIPULATION TO EXTEND DEFENDANTS’ TIME TO RESPOND TO PLAINTIFFS’
COMPLAINT; ORDER

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Plaintiffs Afraa Al Eesa, Individually and as Successor-in-Interest to Abbas Al

2 Khalidi, Deceased, A.A.K. (a minor), A.A.K. (a minor), and Y.A.K. (a minor)
3 (“Plaintiffs”) and Defendants Johnson & Johnson, Johnson & Johnson Holdco (NA) Inc.,
4 Janssen Pharmaceuticals, Inc., Kenvue Inc., and LTL Management LLC (“Defendants”),1
5 by and through the undersigned counsel, hereby submit this Stipulation pursuant to Local
6 Rule 144 as follows:
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1.

WHEREAS Plaintiffs filed this Complaint for Wrongful Death and a Survival

8 Action – Asbestos (“Plaintiffs’ Complaint”) against Defendants on October 2, 2023.
9 Plaintiffs’ Complaint names five defendants and contains five causes of action and 121
10 paragraphs;
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2.

WHEREAS the Parties previously agreed that Defendants’ last day respond

12 to Plaintiffs’ Complaint was extended by 20 or 21 days respectively to November 16, 2023
13 pursuant to Local Rule 144(a) (Dkt. No. 10); and
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3.

WHEREAS the Parties agree that good cause exists for an additional

15 extension of time for Defendants to respond to Plaintiffs’ Complaint until December 15,
16 2023 given the number of parties, the length of Plaintiffs’ complaint, the complexity of the
17 factual and legal issues presented in Plaintiffs’ Complaint, and the fact that the undersigned
18 counsel, Julia Romano, is currently in trial.
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1 Upon information and belief, Defendant Johnson & Johnson Consumer Inc. has not yet been
27 served with Plaintiffs’ Complaint.
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1
JOINT STIPULATION TO EXTEND DEFENDANTS’ TIME TO RESPOND TO PLAINTIFFS’
COMPLAINT; ORDER

1 DATED: November 13, 2023

Respectfully submitted,

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By: /s/Julia E. Romano
Alexander G. Calfo
Julia E. Romano
King & Spalding LLP

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Attorneys for Defendants
JOHNSON & JOHNSON; JOHNSON &
JOHNSON HOLDCO (NA) INC.;
JANSSEN PHARMACEUTICALS,
INC.; KENVUE, INC.; and LTL
MANAGEMENT LLC

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9 DATED: November 13, 2023
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Respectfully submitted,
By: /s/Mark A. Linder
Mark A. Linder
The Lanier Law Firm

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Attorneys for Plaintiffs
AFRAA AL EESA, INDIVIDUALLY AND
AS SUCCESSOR-IN-INTEREST TO
ABBAS AL KHALIDI, DECEASED,
A.A.K., A.A.K., and Y.A.K.

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JOINT STIPULATION TO EXTEND DEFENDANTS’ TIME TO RESPOND TO PLAINTIFFS’
COMPLAINT; ORDER

ATTESTATION

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I, Julia E. Romano, am the ECF User whose ID and password are being used to file

3 this Joint Stipulation. I hereby attest that the other signatories to this Joint Stipulation
4 concur in this filing.
5 DATED: November 13, 2023

Respectfully submitted,

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By: /s/Julia E. Romano
Julia E. Romano

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JOINT STIPULATION TO EXTEND DEFENDANTS’ TIME TO RESPOND TO PLAINTIFFS’
COMPLAINT; ORDER

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ORDER
The Court, having considered the stipulation submitted herewith, IT IS SO

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ORDERED that:
Defendants Johnson & Johnson, Johnson & Johnson Holdco (NA) Inc., Janssen

6 Pharmaceuticals, Inc., Kenvue Inc., and LTL Management LLC’s deadline to respond to
7 Plaintiffs’ Complaint in the above-captioned matter is extended to December 15, 2023.
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IT IS SO ORDERED.
Dated: November 14, 2023

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JOINT STIPULATION TO EXTEND DEFENDANTS’ TIME TO RESPOND TO PLAINTIFFS’
COMPLAINT; ORDER