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United States Ex Rel Strom v. Scios Inc. and Johnson & Johnson

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION


October 7, 2011

UNITED STATES EX REL STROM, PLAINTIFFS,
v.
SCIOS INC. AND JOHNSON & JOHNSON,
DEFENDANTS.

The opinion of the court was delivered by: Hon. Jacqueline Scott Corley United States Magistrate Judge

QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP John M. Potter (Bar No. 165843) johnpotter@quinnemanuel.com Diane M. Doolittle (Bar No. 142046) dianedoolittle@quinnemanuel.com Elizabeth A. Morgan (Bar No. 270824) elizabethmorgan@quinnemanuel.com 50 California Street, 22nd Floor San Francisco, California 94111 Telephone: (415) 875-6600 6 Facsimile: (415) 875-6700 Christopher Tayback (Bar No. 145532) christayback@quinnemanuel.com Ashley E. Martabano (Bar No. 236357) ashleymartabano@quinnemanuel.com 865 South Figueroa Street, 10th Floor Los Angeles, California 90017-2543 Telephone: (213) 443-3000 Facsimile: (213) 443-3100 Attorneys for Defendants JOHNSON & JOHNSON AND SCIOS, INC.

STIPULATION AND [PROPOSED] ORDER EXTENDING TIME IN WHICH THE PARTIES MUST MOVE TO COMPEL FACT-RELATED DISCOVERY AND FOR EXPERT DISCOVERY

Trial Date: None Set compel on any fact-discovery related issues is currently October 7, 2011; and 5 6 five pages in place of traditional discovery motions; and

WHEREAS, the United States filed its Complaint in this matter on June 11, 2009; and

WHEREAS, the fact-discovery cutoff in this case was September 30, 2011; and

WHEREAS, pursuant to Local Rule 37-3, the deadline by which the parties must move to

WHEREAS, the court requires the party to submit joint discovery letters no longer than

WHEREAS, the United States sought an extension of time in which to respond to Defendants' Fourth Set of Interrogatories; and 9 10 stipulate and agree to extend Defendants' deadline to seek relief regarding the United States' 11

WHEREAS, the United States has agreed to supplement its Responses to Defendants' Fourth Set of Interrogatories, Nos. 10-13, by Friday, October 7, 2011; and 14 15 assertion of the deliberative process privilege; and 16 17 shall have until seven calendar days after the United States provides such additional information to 18 notify the United States that they intend to ask the Court to overturn the privilege; upon 19 notification, Defendants will then have seven calendar days to provide their portion of the joint 20 discovery letter relating to the deliberative process privilege; the United States will then have 21 seven calendar days to provide its responsive portion; and the parties will have an additional seven 22 calendar days to make any final revisions; and 23

WHEREAS, the parties, through their undersigned counsel, met and conferred about all 24 outstanding discovery issues on October 3, 2011, including the parties' September 30, 2011 25 responses to various discovery requests, and have further agreed to the following briefing schedule 26 for any discovery letters to be filed with the court on any issues about which the parties met and 27 conferred on October 3, 2011:

WHEREAS, the Defendants agreed to such extension on the condition that the parties Responses to Defendants' Fourth Set of Interrogatories until October 28, 2011; and 12

WHEREAS, the United States has agreed to provide further information relating to its

WHEREAS, the parties, through their undersigned counsel, have agreed that Defendants Moving Party to provide its portion to Opposing Party by October 12, 2011;

by October 25, 2011; 4

discovery deadlines, through their undersigned counsel, have agreed and stipulated to change the 7 expert disclosure deadlines to the following:

Opposing Party to provide its responsive portion to Moving Party by October 21, 2011; Moving Party to make any final revisions and provide to Opposing Party for finalization Moving Party shall file with the Court by October 28, 2011.

WHEREAS, the parties, recognizing the impact of this schedule on the pending expert Designation of Experts November 30, 2011 Designation of Rebuttal Experts January 6, 2012 Expert discovery cut-off February 3, 2012

IT IS HEREBY ORDERED THAT:

Defendants shall have until October 28, 2011 to seek relief relating to the United States' Responses to Defendants' Fourth Set of Interrogatories, Nos. 10-13; and 16 shall have until seven calendar days after the United States provides States provides additional 17 information to notify the United States that they intend to ask the Court to overturn the privilege; 18 upon notification, Defendants will then have seven calendar days to provide their portion of the 19 joint discovery letter relating to the deliberative process privilege; the United States will then have 20 seven calendar days to provide its responsive portion; and the parties will have an additional seven 21 calendar days to make any final revisions; and 22 24 about which the parties met and conferred on October 3, 2011, according to the schedule set forth 25 above. 26

IT IS FURTHER ORDERED THAT:

With respect to the United States' assertions of deliberative process privilege, Defendants

IT IS FURTHER ORDERED THAT:

The Parties shall file any outstanding motions to compel fact-related discovery on issues

IT IS FURTHER ORDERED THAT:

The expert disclosure deadlines in the case shall be the following:

Designation of Experts November 30, 2011

Designation of Rebuttal Experts January 6, 2012

Expert discovery cut-off February 3, 2012

IT IS SO ORDERED.

20111007

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