Opinion
Case No. 3:13-cv-00543-MMC
03-19-2013
MIRIAM CRUZ, Plaintiff, v. BAYER HEALTHCARE PHARMACEUTICALS, INC., Defendant.
Mark P. Robinson, Jr. (SBN: 054426) Daniel S. Robinson (SBN: 244245) Karen L. Karavatos (SBN: 131718) Shannon Lukei (SBN: 202868) ROBINSON CALCAGNIE ROBINSON SHAPIRO DAVIS, INC. 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 Attorneys for Plaintiff Miriam Cruz Alicia J. Donahue (SBN: 117412) SHOOK, HARDY & BACON L.L.P. Attorneys for Defendant Bayer Healthcare Pharmaceuticals, Inc.
Mark P. Robinson, Jr. (SBN: 054426)
Daniel S. Robinson (SBN: 244245)
Karen L. Karavatos (SBN: 131718)
Shannon Lukei (SBN: 202868)
ROBINSON CALCAGNIE ROBINSON SHAPIRO DAVIS, INC.
and 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
Attorneys for Plaintiff Miriam Cruz Alicia J. Donahue (SBN: 117412)
SHOOK, HARDY & BACON L.L.P.
Attorneys for Defendant
Bayer Healthcare Pharmaceuticals, Inc.
STIPULATION AND [PROPOSED] ORDER
EXTENDING BRIEFING SCHEDULE ON
BAYER HEALTHCARE
PHARMACEUTICALS, INC.’S MOTION TO
DISMISS AND MOTION TO STRIKE
Date: April 19, 2013
Complaint filed: February 7, 2013
IT IS HEREBY STIPULATED by and between, Plaintiff Miriam Cruz ("Plaintiff"), and Defendant Bayer Healthcare Pharmaceuticals, Inc. ("Bayer"), by and through their attorneys of record, that Plaintiff will take her pending Motion to Stay and all applicable briefing schedules related to that off calendar and that the briefing schedule on Bayer's Motion to Dismiss and Motion to Strike be extended as follows:
1. Good cause exists for extending the briefing schedule on Bayer's Motion to Dismiss and Motion to Strike. This case is potentially related to Multidistrict Litigation ("MDL") Docket No. 2434, In re: Mirena IUD Products Liability Litigation. The JPML is scheduled to hear a motion to transfer these cases on March 21, 2013.
2. Plaintiff's deadline to file an opposition to Bayer's Motion to Dismiss and Motion to Strike is currently March 19, 2013. Bayer's deadline to file a reply is currently March 26, 2013.
3. The parties respectfully request that the Court extend Plaintiff's deadline to file an opposition to Bayer's Motion to Strike and Motion to Dismiss to April 5, 2013.
4. The parties respectfully request that the Court extend Bayer's deadline to file a reply to its Motion to Strike and Motion to Dismiss to April 12, 2013.
By: _____________
MICHAEL K. JOHNSON
MARK P. ROBINSON, JR.
DANIEL S. ROBINSON
KAREN L. KARAVATOS
SHANNON LUKEI
Attorneys for Plaintiff MIRIAM CRUZ
By: _____________
ALICIA J. DONAHUE
Attorneys for Defendant BAYER
HEALTHCARE
PHARMACEUTICALS, INC.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
IT IS FURTHER ORDERED that the hearing on defendant's motion is continued to April 26, 2013. IT IS FURTHER ORDERED that plaintiff's Motion to Stay is deemed withdrawn without prejudice.
_____________
HONORABLE MAXINE M. CHESNEY