Case 3:16-md VC Document 2391 Filed 12/31/18 Page 1 of 5

Similar documents
Case 3:16-md VC Document 2282 Filed 12/10/18 Page 1 of 17

Case 3:16-md VC Document 419 Filed 08/03/17 Page 1 of 5 UNITED STATES DISTRICT COURT

Case 3:16-md VC Document 2935 Filed 03/07/19 Page 1 of 11

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Case 3:16-md VC Document 1100 Filed 02/05/18 Page 1 of 5. February 5, In re Roundup Prod. Liab. Litig., No.

Case 3:16-md VC Document 1461 Filed 05/18/18 Page 1 of 3

Case 3:16-md VC Document 2866 Filed 02/28/19 Page 1 of 7

Case 3:16-md VC Document 2940 Filed 03/07/19 Page 1 of 16 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Case 3:16-md VC Document 2420 Filed 01/03/19 Page 1 of 41

Case4:13-cv JSW Document112 Filed05/05/14 Page1 of 3

Case: 1:14-cv Document #: 499 Filed: 12/04/14 Page 1 of 7 PageID #:6117

Case 3:15-cv HEH Document 64 Filed 09/18/15 Page 1 of 4 PageID# 445

Case 3:13-cv SC Document 39 Filed 01/09/14 Page 1 of 5

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Case3:12-cv VC Document77 Filed06/25/15 Page1 of 5

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON AT YAKIMA

Case 1:13-cv BB Document 42 Entered on FLSD Docket 05/18/2016 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA

Case 1:17-cv TCB-WSD-BBM Document 44 Filed 10/20/17 Page 1 of 8

Case: Document: 26-1 Filed: 12/04/2014 Pages: 6 NO IN THE UNITED STATES COURT OF APPEALS FOR THE SEVENTH CIRCUIT ) ) ) )

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION 3:14-cv-213 ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT. Petitioners, Real Parties in Interest.

Case 1:18-cv LY Document 43 Filed 09/17/18 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

Synchronoss Technologies, Inc. v. Funambol, Inc. Doc. 52

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case 2:17-cv JAR-JPO Document 94 Filed 11/27/17 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

1900 M Street, NW, Ste. 250, Washington, D.C

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION

Case 3:16-md FLW-LHG Document 115 Filed 02/17/17 Page 1 of 5 PageID: 1596 IN THE UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY MDL 2738

Case 1:13-cv RCL Document 77 Filed 03/02/18 Page 1 of 3 UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA

Case 2:12-md Document 174 Filed 06/14/12 Page 1 of 2 PageID #: 1222

Case3:12-cv VC Document70 Filed06/23/15 Page1 of 3

Hells Angels Motorcycle Corporation v. Alexander McQueen Trading Limited et al Doc. 16

Case 3:16-md VC Document 2634 Filed 02/01/19 Page 1 of 34

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Case 1:18-cv JFK Document 62 Filed 03/02/18 Page 1 of 6

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

CASE NOS , -1307, -1309, -1310, IN THE UNITED STATES COURT OF APPEALS FOR THE FEDERAL CIRCUIT

Case 4:08-cv SBA Document 180 Filed 03/03/2009 Page 1 of 5

Case 2:17-cv RAJ Document 36 Filed 07/21/17 Page 1 of 5

PlainSite. Legal Document

Case 1:13-cv MMS Document 77 Filed 10/04/18 Page 1 of 5 IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION. Case No. 5:07-CV-231

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) )

Case 2:08-cv MJP Document 345 Filed 01/29/16 Page 1 of 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE

Case 2:12-md CMR Document 806 Filed 04/24/14 Page 1 of 5 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF PENNSYLVANIA

Case 4:07-cv CW Document 39 Filed 12/07/2007 Page 1 of 5

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION CASE NO: 5:07-CV-231

Case M:06-cv VRW Document 424 Filed 02/04/2008 Page 1 of 5

Case3:15-cv VC Document25 Filed06/19/15 Page1 of 8

Case 3:16-md VC Document 279 Filed 05/05/17 Page 1 of 10

Case 1:15-mc CKK Document 188 Filed 09/21/17 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION ) ) ) ) ) ) ) )

Case 3:15-cv HEH Document 34 Filed 08/14/15 Page 1 of 3 PageID# 134

IN THE UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS. MDL No

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

Case 2:18-cv R-AGR Document 7 Filed 02/05/18 Page 1 of 2 Page ID #:26

Case 3:16-md VC Document Filed 08/14/17 Page 1 of 15

Case4:10-cv CW Document205 Filed11/02/12 Page1 of 6

Case 3:17-cv VC Document 48 Filed 09/29/17 Page 1 of 17

Case 1:12-cv GBL-JFA Document 17 Filed 09/10/12 Page 1 of 4 PageID# 185

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION ) ) ) ) ) ) ) )

No IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT DOTCONNECTAFRICA TRUST,

Case3:12-cv VC Document88 Filed06/09/15 Page1 of 2

Case 1:13-cv RCL Document 89 Filed 10/29/18 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 5:11-cv OLG-JES-XR Document 1036 Filed 06/02/14 Page 1 of 10

Case: 1:13-cv Document #: 35 Filed: 09/13/13 Page 1 of 5 PageID #:130

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Case 1:09-md LAK Document 333 Filed 08/30/10 Page 1 of 3

Case 1:18-cv RC Document 46 Filed 02/26/19 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 2:11-cv JEM Document 38 Entered on FLSD Docket 04/18/2011 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case 3:17-cv RS Document 380 Filed 04/19/18 Page 1 of 5

Case5:11-cv LHK Document1777 Filed08/15/12 Page1 of 19 UNITED STATES DISTRICT COURT

Case 2:14-cv R-RZ Document 52 Filed 08/27/14 Page 1 of 9 Page ID #:611

Case: 2:15-cv MHW-NMK Doc #: 20 Filed: 07/01/15 Page: 1 of 10 PAGEID #: 143

Microsoft Corporation v. Motorola, Inc, et al Doc. 8 Case 2:10-cv JLR Document 319 Filed 05/16/12 Page 1 of 5

Defendant and Counterclaim Plaintiff.

Case 3:17-cv VC Document Filed 09/06/18 Page 1 of 6

Case 1:15-cv TSE Document 116 Filed 09/28/17 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ROME DIVISION

Case 3:10-cv BR Document 77 Filed 12/10/12 Page 1 of 6 Page ID#: 998

Case M:06-cv VRW Document 160 Filed 02/08/2007 Page 1 of 5

Case 1:17-cv RDM Document 16 Filed 06/13/17 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case: LTS Doc#:111 Filed:05/25/17 Entered:05/25/17 13:40:50 Document Page 1 of 6

Case 1:15-cv JLK Document 31 Filed 03/07/16 USDC Colorado Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

PlainSite. Legal Document. Arizona District Court Case No. 4:11-cv Carreon v. Toyota Financial Services Corporation et al.

- UNITED STATES DISTRICT COURT,_. SOUTHERN DISTRICT OF NEW YORK

Case 5:12-cv EJD Document 1134 Filed 01/27/16 Page 1 of 8

Case4:11-cv PJH Document65 Filed08/31/12 Page1 of 8

Case 2:17-ap BB Doc 50 Filed 05/04/17 Entered 05/04/17 14:14:01 Desc Main Document Page 1 of 6

Charles Edward Lincoln, pro se 603 Elmwood Place, Suite #6 Austin, Texas Tel:

Case 0:17-cv BB Document 89 Entered on FLSD Docket 07/19/2018 Page 1 of 4

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

Case 1:18-cv RC Document 23 Filed 12/03/18 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Transcription:

Case :-md-0-vc Document Filed // Page of 0 WILKINSON WALSH + ESKOVITZ LLP Brian L. Stekloff (pro hac vice (bstekloff@wilkinsonwalsh.com Rakesh Kilaru (pro hac vice (rkilaru@wilkinsonwalsh.com 0 M St. NW 0 th Floor Washington, DC 0 Tel: --00 Fax: --00 HOLLINGSWORTH LLP Eric G. Lasker (pro hac vice (elasker@hollingsworthllp.com 0 I St. NW Washington, DC 00 Tel: -- Fax: -- Attorneys for Defendant MONSANTO COMPANY ARNOLD & PORTER KAYE SCHOLER Pamela Yates (CA Bar No. 0 (Pamela.Yates@arnoldporter.com South Figueroa St., th Floor Los Angeles, CA 00 Tel: -- Fax: -- IN RE: ROUNDUP PRODUCTS LIABILITY LITIGATION Hardeman v. Monsanto Co., et al., :-cv-0-vc Stevick v. Monsanto Co., et al., :-cv--vc Gebeyehou v. Monsanto Co., et al., :-cv--vc UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA MDL No. Case No. :-md-0-vc MONSANTO COMPANY S MOTION TO EXCEED PAGE LIMIT FOR SPECIFIC-CAUSATION SUMMARY JUDGMENT AND DAUBERT MOTION - - :-md-0-vc

Case :-md-0-vc Document Filed // Page of 0 Defendant Monsanto Company ( Monsanto hereby respectfully moves for leave to exceed the page limits for its specific causation Daubert and summary judgment briefs to pages for Monsanto s opening brief and pages for its reply brief. Plaintiffs oppose this limited page extension, and have also made clear that they oppose other aspects of Monsanto s briefing strategy. Monsanto stated its position on this issue in the parties December, Joint Case Management Statement (ECF No., or CMC Statement but now moves separately given the importance of the issue and to update the Court on further correspondence with Plaintiffs since the CMC statement was filed. In support of this request, Monsanto states as follows:. In the parties October, Joint Case Management Statement (ECF No., Plaintiffs requested that the Court set page limits for the specific causation Daubert and summary judgment briefs in advance of the Group trial. In a section of the statement titled Specific Causation Daubert Briefing and Summary Judgment Page Limits, Plaintiffs proposed the following page limits: Monsanto s specific causation Daubert and summary judgment brief: pages Plaintiffs opposition and affirmative specific causation Daubert and summary judgment brief: 0 pages Monsanto s opposition and reply brief: 0 pages Plaintiffs reply brief: pages Monsanto did not object at time to the page limitations proposed by Plaintiffs, in part because it was unclear whether the briefing would address only the first case the Court elected to set for trial or all of the Group cases.. In the ten weeks that have elapsed since that filing, however, the scope of the briefing has become clearer. The Court made clear in its November, PTO No. (ECF No. that the parties were to continue preparing all three Group cases for trial and ordered that all three cases be ready for trial by February,. Further, it became clear at the December, Case Management Conference that the upcoming Daubert hearing would - - :-md-0-vc

Case :-md-0-vc Document Filed // Page of 0 address all three of the Group cases. Accordingly, Monsanto requests 0 additional pages for its opening brief and additional pages for the reply brief on specific causation to account for all three cases, rather than just the Hardeman case. Monsanto does not oppose reciprocal page extensions for Plaintiffs specific causation Daubert and summary judgment briefs.. Monsanto met and conferred with Plaintiffs several times in relation to this request. Plaintiffs made clear that they not only oppose the page extension, but understand the scope of the prior agreement to encompass all of Monsanto s Daubert and summary judgment arguments, even on matters completely unrelated to specific causation.. For several weeks now, Monsanto has anticipated filing Daubert briefs as to Dr. Sawyer (Plaintiffs exposure expert, Dr. Benbrook (Plaintiffs regulatory expert, and Mr. Mills (Plaintiffs punitive damages experts. Those motions are based in substantial part on the experts recent depositions and could not have been filed before now. In addition, Monsanto has anticipated filing a summary judgment brief on other legal grounds unrelated to specific causation. These briefs and arguments could materially advance the termination of this litigation and streamline the issues before the Court if these cases proceed to trial. As Monsanto has made clear to Plaintiffs, it intends to abide by the Court s existing page limits on these briefs ( pages for Daubert and pages for all non-causation summary judgment arguments.. To address Plaintiffs recently raised claims of prejudice based on these additional briefs, Monsanto offered to agree to an extension of time (without altering the time for completion of all briefing for Plaintiffs oppositions to Monsanto s motions unrelated to specific causation in exchange for Plaintiffs agreement not to oppose Monsanto s briefing plan. At the time the CMC Statement was filed, Plaintiffs indicated that they would be willing to consider Monsanto s proposal. This afternoon, Plaintiffs stated that they will not consent and oppose any briefing being filed over pages.. In light of the foregoing, Monsanto requests that the Court grant its motion to extend the page limits for its specific causation Daubert and summary judgment opening brief and reply brief. In addition, unless directed otherwise by the Court, Monsanto intends to file the other - - :-md-0-vc

Case :-md-0-vc Document Filed // Page of Daubert and summary judgment briefs it has long contemplated filing. Monsanto remains willing to agree to page and time extensions for Plaintiffs, if the Court deems them appropriate. 0 DATED: December, Respectfully submitted, /s/ Brian L. Stekloff Brian L. Stekloff (pro hac vice (bstekloff@wilkinsonwalsh.com Rakesh Kilaru (pro hac vice (rkilaru@wilkinsonwalsh.com WILKINSON WALSH + ESKOVITZ LLP 0 M St. NW 0 th Floor Washington, DC 0 Tel: --00 Fax: --00 Pamela Yates (CA Bar No. 0 (Pamela.Yates@arnoldporter.com ARNOLD & PORTER KAYE SCHOLER South Figueroa St., th Floor Los Angeles, CA 00 Tel: -- Fax: -- Eric G. Lasker (pro hac vice (elasker@hollingsworthllp.com HOLLINGSWORTH LLP 0 I St. NW Washington, DC 00 Tel: -- Fax: -- Attorneys for Defendant MONSANTO COMPANY - - :-md-0-vc

Case :-md-0-vc Document Filed // Page of CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this st day of December, a copy of the foregoing was filed with the Clerk of the Court through the CM/ECF system which sent notice of the filing to all appearing parties of record. /s/ Brian L. Stekloff 0 :-md-0-vc

Case :-md-0-vc Document - Filed // Page of IN RE: ROUNDUP PRODUCTS LIABILITY LITIGATION Hardeman v. Monsanto Co., et al., :-cv-0-vc Stevick v. Monsanto Co., et al., :-cv--vc Gebeyehou v. Monsanto Co., et al., :-cv--vc UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA MDL No. Case No. :-md-0-vc [PROPOSED] ORDER GRANTING MONSANTO COMPANY S MOTION TO EXCEED PAGE LIMIT FOR SPECIFIC CAUSATION SUMMARY JUDGMENT AND DAUBERT MOTION 0 Upon consideration of Monsanto Company s Motion to Exceed Page Limits for Specific-Causation Summary Judgment and Daubert Motion, IT IS HEREBY ORDERED THAT the motion is GRANTED; and it is hereby FURTHER ORDERED that Monsanto Company shall be permitted to file: A specific-causation opening brief not to exceed pages; A specific-causation reply brief not to exceed pages; Daubert briefs on issues unrelated to specific causation not to exceed pages each; A summary judgment brief on issues unrelated to causation not to exceed pages. Date: HONORABLE VINCE CHHABRIA UNITED STATES DISTRICT COURT [PROPOSED] ORDER GRANTING :-md-0-vc