600 New Hampshire Ave. NW, 10th Floor Washington, DC 20037 Telephone: 202.333.4562 Facsimile: 214.523.6600 *admitted only in California Attorney for Plaintiff-Relator Additional Counsel Listed on Signature Block
ADVENTIST HEALTH SYSTEM/WEST, and on behalf of the STATES of CALIFORNIA,
WHEREAS, on October 12, 2023, the Court entered an Order re: Briefing and Hearing Schedule for Relator’s Amended Complaint and Defendants’ Motion(s) to Dismiss Relator’s Amended Complaint, which set the scheduling conference for February 12, 2024 (Dkt. 104); WHEREAS, on November 7, 2023, Relator Adventist Health System/West (“Relator”) filed a First Amended Complaint (“FAC”); WHEREAS, on December 13, 2023, Defendants AbbVie Inc., Allergan Sales, LLC, Allergan USA, Inc., AstraZeneca LP, AstraZeneca Pharmaceuticals LP, Genzyme Corporation, Novartis Pharmaceuticals Corporation, Sandoz Inc., Sanofi US Services Inc., and Sanofi-Aventis U.S. LLC (collectively, “Defendants”) filed motions to dismiss Relator’s FAC; WHEREAS, on December 22, 2023, the parties filed a Notice of Motion and Joint Stipulation of the Parties Pursuant to Local Rule 37-2.1 Regarding Defendants’ Motion to Stay Discovery (“the Motion”); WHEREAS, the current deadline for the parties to conduct the Rule 26(f) conference is January 22, 2024; WHEREAS, on that same date, January 22, 2024, a hearing is set regarding the Motion; WHEREAS, the parties agree that conducting the Rule 26(f) conference will be more efficient after the Court has decided the Motion; WHEREAS, if the Motion is granted, the need for a Rule 26(f) conference is mooted subject to further notice from the Court; WHEREAS, subject to the Court’s approval, the parties hereby stipulate to the following deadlines for holding the Rule 26(f) conference: • If the Court denies the Motion, the parties are to conduct the Rule 26(f) conference within 7 days of the Court’s ruling; and • If the Court grants the Motion, the parties are not required to conduct the Rule 26(f) conference until further notice from the Court.
1501 M Street NW, 7th Floor Washington, DC 20005 Telephone: 202.872.6765 Facsimile: 202.785.1756 *admitted only in California Attorneys for Plaintiff-Relator
5-4.3.4(a)(2)(i), I, Kenneth D. Capesius, attest that all signatories identified above, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing.