Cheap

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF CALIFORNIA

SACRAMENTO DIVISION

PASQUALINA CHEAP and JAMES

CHEAP,

Plaintiffs, Case No. 1:21-cv-00226-DAD-BAM v.

C. R. BARD, INC. AND BARD

PERIPHERAL VASCULAR, INC.,

Defendants.

JOINT MOTION TO STAY DISCOVERY AND ALL PRETRIAL DEADLINES

Pursuant to Federal Rule of Civil Procedure 26(c) and (d), Plaintiffs in the above-titled action and Defendants C. R. Bard, Inc. and Bard Peripheral Vascular, Inc. (collectively, “Bard”) (Plaintiffs and Bard are collectively referred to herein as “the Parties”), respectfully request that this Court temporarily stay discovery and all pretrial deadlines in this case for 90 days after entry of the [Proposed] Order while the Parties finalize settlement terms. In support of this Motion, the Parties state as follows: 1. This case was originally filed in In re: Bard IVC Filters Products Liability Litigation, MDL 2641 (the “MDL”). The case was subsequently remanded to this District and assigned to this Court. [Doc. 5]. Plaintiffs’ counsel has approximately 900 Bard IVC filter cases, including this case, pending in federal courts across the country, that are settled in principle…