Brownfield et al v. Bayer Corporation, et al.,

Filing 14

STIPULATION and ORDER signed by Judge John A. Mendez on 4/27/09 ORDERING the deadline for the parties to submit a Joint Status Report and Rule 26(f) Discovery Plan to the Court is EXTENDED until 30 days after the Court enters an order on dft's Motion to Dismiss 8 and Motion to Strike Complaint 9 . (Carlos, K) [Transferred from California Eastern on 10/13/2009.]

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LINDSAY & STONEBARGER

James M. Lindsay, State Bar No. 164758 [e-mail] Gene J. Stonebarger, State Bar No. 209461 [e-mail] Richard D. Lambert, State Bar No. 251148 [e-mail] LINDSAY & STONEBARGER A Professional Corporation 620 Coolidge Drive, Suite 225 Folsom, CA 95630 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiffs and the Class UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION NICHOLE BROWNFIELD, an individual; and ) KIERA CHAMBERS, an individual, on behalf ) of themselves and all others similarly situated, ) ) Plaintiffs, ) ) vs. ) ) BAYER CORPORATION; BAYER ) HEALTHCARE PHARMACEUTICALS, INC.; ) BAYER PHARMACEUTICALS ) CORPORATION; BAYER HEALTHCARE, ) LLC; BAYER HEALTHCARE A.G.; BERLEX ) LABORATORIES, INC.; and DOES 1 through ) 50, inclusive, ) ) Defendants. ) CASE NO. 2:09-CV-00444-JAM-GGH CLASS ACTION JOINT STIPULATION FOR MODIFICATION OF ORDER REQUIRING JOINT STATUS REPORT Judge: Hon. John A. Mendez

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2:09-CV-00444-JAM-GGH PDF created with pdfFactory trial version www.pdffactory.com

JOINT STIPULATION RE STATUS REPORT

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LINDSAY & STONEBARGER

Plaintiffs, Nichole Brownfield and Kiera Chambers, and Defendant, Bayer Healthcare Pharmaceuticals, Inc. (hereinafter collectively referred to as the "Parties"), by and through their respective attorneys, respectfully submit this Joint Stipulation and [Proposed] Order to Modify Order Requiring Joint Status Report, issued on February 13, 2009. Specifically, the Parties request that this Court issue an Order continuing the date by which the Parties were ordered to submit a Joint Status Report and Rule 26(f) Discovery Plan to the Court. The Parties have begun to meet and confer with regard to the Joint Status Report and Rule 26(f) Discovery Plan. The Parties believe, though, that modification is warranted so that the Parties can continue their meet and confer efforts; and because Defendant's Motion to Dismiss and Motion to Strike Complaint are currently pending before the Court, and are scheduled for hearing on May 6, 2009. Accordingly, the Parties stipulate, agree and respectfully request that the Court enter an order providing that: 1. The deadline for the Parties to submit a Joint Status Report and Rule 26(f)

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Discovery Plan to the Court be extended until thirty (30) days after the Court enters an Order on Defendant's Motion to Dismiss and Motion to Strike Complaint.

SO STIPULATED by Plaintiff. Dated: April 27, 2009 LINDSAY & STONEBARGER, APC By: /s/ Gene J. Stonebarger Gene J. Stonebarger E-mail: [e-mail] Richard D. Lambert E-mail: [e-mail] Attorneys for Plaintiffs and the Class

SO STIPULATED by Defendant. Dated: April 27, 2009 DLA PIPER LLP (US) By: /s/ Shirli F. Weiss Shirli F. Weiss E-mail: [e-mail] Ryan T. Hansen E-mail: [e-mail] Attorneys for Defendants JOINT STIPULATION RE STATUS REPORT

2:09-CV-00444-JAM-GGH

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LINDSAY & STONEBARGER

ORDER

IT IS SO ORDERED.

DATED: April 27, 2009

/s/ John A. Mendez___________ The Honorable John A. Mendez Judge of the U.S. District Court

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