Cruz v. Bayer HealthCare Pharmaceuticals Inc.

Filing 15

STIPULATION AND ORDER EXTENDING BRIEFING SCHEDULE ON BAYER HEALTHCARE PHARMACEUTICALS, INC.'S MOTION TO DISMISS AND MOTION TO STRIKE. The hearing on defendant's motion is continued to April 26, 2013. Plaintiff's motion to stay is deemed withdrawn without prejudice. Signed by Judge Maxine M. Chesney on March 19, 2013. (mmclc2, COURT STAFF) (Filed on 3/19/2013)

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Mark P. Robinson, Jr. (SBN: 054426)
[e-mail]
Daniel S. Robinson (SBN: 244245)
[e-mail]
Karen L. Karavatos (SBN: 131718)
[e-mail]
Shannon Lukei (SBN: 202868)
[e-mail]
ROBINSON CALCAGNIE ROBINSON SHAPIRO DAVIS, INC.
19 Corporate Plaza Drive
Newport Beach, California 92660
Telephone: [phone]
Facsimile:
949-720-1292

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and

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Michael K. Johnson (MN #258696) (Admitted Pro Hac Vice)
Timothy J. Becker (MN #256663) (Pro Hac Vice Pending)
Rolf T. Fiebiger (MN #391138) (Pro Hac Vice Pending)
JOHNSON BECKER, PLLC
33 South Sixth Street
Suite 4530
Minneapolis, Minnesota 55402
[phone]
[e-mail]
[e-mail]
[e-mail]

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Attorneys for Plaintiff Miriam Cruz

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Alicia J. Donahue (SBN: 117412)
[e-mail]
SHOOK, HARDY & BACON L.L.P.
One Montgomery, Suite 2700
San Francisco, California 94104-4505
Telephone: [phone]
Facsimile:
415-391-0281

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Attorneys for Defendant
Bayer Healthcare Pharmaceuticals, Inc.

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STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING SCHEDULE ON BAYER’S MOTION TO
DISMISS AND MOTION TO STRIKE - CASE NO. 3:13-cv-00543-MMC
249200 V1

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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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MIRIAM CRUZ,

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Plaintiff,
v.
BAYER HEALTHCARE
PHARMACEUTICALS, INC.,
Defendant.

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Case No. 3:13-cv-00543-MMC
STIPULATION AND [PROPOSED] ORDER
EXTENDING BRIEFING SCHEDULE ON
BAYER HEALTHCARE
PHARMACEUTICALS, INC.’S MOTION TO
DISMISS AND MOTION TO STRIKE
Date:
Time:
Ctrm:

April 19, 2013
9:00 a.m.
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Complaint filed: February 7, 2013

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IT IS HEREBY STIPULATED by and between, Plaintiff Miriam Cruz (“Plaintiff”), and

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Defendant Bayer Healthcare Pharmaceuticals, Inc. (“Bayer”), by and through their attorneys of

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record, that Plaintiff will take her pending Motion to Stay and all applicable briefing schedules

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related to that off calendar and that the briefing schedule on Bayer’s Motion to Dismiss and Motion

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to Strike be extended as follows:

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1. Good cause exists for extending the briefing schedule on Bayer’s Motion to Dismiss and

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Motion to Strike. This case is potentially related to Multidistrict Litigation (“MDL”)

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Docket No. 2434, In re: Mirena IUD Products Liability Litigation. The JPML is

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scheduled to hear a motion to transfer these cases on March 21, 2013.

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2. Plaintiff’s deadline to file an opposition to Bayer’s Motion to Dismiss and Motion to

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Strike is currently March 19, 2013. Bayer’s deadline to file a reply is currently March

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26, 2013.

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3. The parties respectfully request that the Court extend Plaintiff’s deadline to file an

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opposition to Bayer’s Motion to Strike and Motion to Dismiss to April 5, 2013.

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STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING SCHEDULE ON BAYER’S MOTION TO
DISMISS AND MOTION TO STRIKE - CASE NO. 3:13-cv-00543-MMC
249200 V1

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4. The parties respectfully request that the Court extend Bayer’s deadline to file a reply to

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its Motion to Strike and Motion to Dismiss to April 12, 2013.

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Dated: March 18, 2013

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By: /s/ Michael K. Johnson
MICHAEL K. JOHNSON
MARK P. ROBINSON, JR.
DANIEL S. ROBINSON
KAREN L. KARAVATOS
SHANNON LUKEI

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Attorneys for Plaintiff MIRIAM CRUZ

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Dated: March 18, 2013

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Attorneys for Defendant BAYER
HEALTHCARE
PHARMACEUTICALS, INC.

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By: /s/ Alicia J. Donahue
ALICIA J. DONAHUE

PURSUANT TO STIPULATION, IT IS SO ORDERED.
IT IS FURTHER ORDERED that the hearing on defendant’s motion is continued to April 26, 2013.

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IT IS FURTHER ORDERED that plaintiff’s Motion to Stay is deemed withdrawn without prejudice.
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DATED: ___March 19, 2013____________

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HONORABLE MAXINE M. CHESNEY

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STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING SCHEDULE ON BAYER’S MOTION TO
DISMISS AND MOTION TO STRIKE - CASE NO. 3:13-cv-00543-MMC
249200 V1