Health Care Service Corporation v. Brown et al

Filing 39

ORDER extending time fo file motion to dismiss re (38 in 3:11-cv-00310-CRB) STIPULATION WITH PROPOSED ORDER Extending Time for Defendants to File Motion to Dismiss Plaintiff's Second Amended Complaint filed by Inc Pfizer, (3601 in 3: 05-md-01699-CRB) STIPULATION WITH PROPOSED ORDER Extending Time for Defendants to File Motion to Dismiss Plaintiff's Second Amended Complaint filed by Pfizer Inc.. Motion to Dismiss due by 5/14/2012. Signed by Judge Charles R. Breyer on 5/1/2012. (beS, COURT STAFF) (Filed on 5/2/2012)

Case3:11-cv-00310-CRB Document38 Filed04/30/12 Page1 of 2

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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IN RE: BEXTRA AND CELEBREX
MARKETING SALES PRACTICES AND
PRODUCT LIABILITY LITIGATION

Master Case No. 05-CV-01699 CRB
Individual Case No. 11-CV-00310 CRB
MDL No. 1699

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This Document Relates To:

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HEALTH CARE SERVICE CORPORATION, a
MUTUAL LEGAL RESERVE COMPANY,

STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME FOR
DEFENDANTS TO FILE MOTION
TO DISMISS PLAINTIFF’S
SECOND AMENDED COMPLAINT

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Plaintiff,

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v.
PHARMACIA & UPJOHN, INC., and PFIZER,
INC.,
Defendants.

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WHEREAS Plaintiff filed a Second Amended Complaint (“SAC”) on April 23, 2012;

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WHEREAS Defendants’ deadline to answer or move to dismiss the SAC ordinarily would

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be May 7, 2012; and
WHEREAS the parties agree that the complexity of the legal issues raised in Defendants’

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anticipated motion to dismiss the SAC warrant additional time for Defendants to complete their

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brief in support of their motion to dismiss;

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/////
-1STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS TO FILE MOTION TO
DISMISS PLAINTIFF’S SECOND AMENDED COMPLAINT – 11-CV-00310 CRB

Case3:11-cv-00310-CRB Document38 Filed04/30/12 Page2 of 2

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THEREFORE, the parties hereby stipulate and respectfully request that the Court extend

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the time for Defendants to file its motion to dismiss the SAC by seven (7) days, to May 14, 2012.

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IT IS SO STIPULATED.

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Dated: April 30, 2012

SCOTT YUNG LLP

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/s/
Andrew Yung
208 N. Market St., Suite 200
Dallas, TX 75202
Telephone: [phone]
Fax: [phone]
Email: [e-mail]

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Counsel for Plaintiff Health Care Service
Corporation

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Dated: April 30, 2012

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/s/
John H. Beisner
Jessica D. Miller
1440 New York Avenue, N.W.
Washington, D.C. 20005-2111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]

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Counsel for Defendants Pfizer Inc and Pharmacia
& Upjohn, Inc.

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PURSUANT TO THE PARTIES’ STIPULATION, IT IS SO ORDERED.

RT

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reyer

les R. B

har
Judge C

ER

H

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OO
IT IS S

R NIA

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FO

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NO

HONORABLE CHARLES R. BREYER
D
UNITED STATES DISTRICT JUDGE
RDERE
UNIT
ED

May 1
Dated: ____________, 2012

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SKADDEN, ARPS, SLATE, MEAGHER &
FLOM LLP

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-2STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS TO FILE MOTION TO
DISMISS PLAINTIFF’S SECOND AMENDED COMPLAINT – 11-CV-00310 CRB