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Brownfield v. Bayer Corp.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION


April 27, 2009

NICHOLE BROWNFIELD, AN INDIVIDUAL; AND KIERA CHAMBERS, AN INDIVIDUAL, ON BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
v.
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.

The opinion of the court was delivered by: Judge Hon. John A. Mendez

CLASS ACTION

JOINT STIPULATION FOR MODIFICATION OF ORDER REQUIRING JOINT STATUS REPORT

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) 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

SO STIPULATED by Defendant.

ORDER

IT IS SO ORDERED.

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

20090427

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