EXHIBIT “A”

Case 1:20-cv-23287-DPG Document 86-1 Entered on FLSD Docket 03/30/2021 Page 1 of 4
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case No.: 1:20-cv-23287-DPG 

LUIS MANUEL RODRIGUEZ, et al., 

Plaintiffs, 

v. 

IMPERIAL BRANDS PLC, et al., 

Defendants. 

[PROPOSED] ORDER GRANTING DEFENDANTS’ 

UNOPPOSED JOINT MOTION FOR AN ORDER SETTING 

COORDINATED MOTION TO DISMISS PROCEDURE AND BRIEFING SCHEDULE 

THIS CAUSE having come before the Court on Defendants Imperial Brands plc 

(“Imperial”), WPP plc, Young & Rubicam LLC, BCW LLC (the “WPP Defendants”), and 

Corporación Habanos, S.A. (“Habanos”) (collectively, the “Moving Defendants”) Unopposed 

Motion for an Order Setting Coordinated Motion to Dismiss Procedure and Briefing Schedule (the 

“Motion”), and good cause appearing therefore, it is ORDERED AND ADJUDGED that the 

Motion is GRANTED. The Parties shall adhere to the following deadlines and procedures: 

1. The Amended Complaint filed March 22, 2021 [D.E. 82] will be treated as though 

it had been filed no later than March 19, 2021 as required by Federal Rule of Civil Procedure 

15(a)(1)(B), and will therefore be treated as the operative complaint. 

2. The Moving Defendants’ deadline to answer or otherwise respond to the Amended 

Complaint shall be April 28, 2021. 

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a. Moving Defendants shall file a Consolidated Motion to Dismiss, making 

arguments common to all Moving Defendants, not to exceed twenty-five (25) 

pages. 

b. While Moving Defendants will work collaboratively to consolidate briefing on 

as many relevant issues as possible, Imperial (individually), the WPP 

Defendants (together), and Habanos (individually) shall have the option of 

filing separate motions and memoranda of law on their individualized 

arguments, not to exceed twenty (20) pages each, to address any additional 

arguments that Moving Defendants wish to raise that are not contained in the 

Consolidated Motion arguments, including, but not limited to, particularized 

arguments relating to jurisdiction. 

3. Plaintiffs’ deadline to file a Response to the Consolidated Motion to Dismiss and 

the Individual Briefs set forth in Paragraph 2 above shall be May 28, 2021. Plaintiffs’ Responses 

to such briefing shall not exceed the number of permissible pages of the respective opening briefs: 

twenty-five (25) pages to respond to the Consolidated Motion to Dismiss and twenty (20) pages to 

respond to the Individual Briefs. 

4. Moving Defendants shall be permitted to file Replies to Plaintiffs’ Responses by 

June 18, 2021, as follows: 

a. A Reply in support of the Consolidated Motion to Dismiss, not to exceed fifteen 

(15) pages; and 

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b. Replies in support of any Individual Briefs, not to exceed ten (10) pages. 

DONE AND ORDERED in Chambers at Miami, Miami-Dade County, Florida, this 

____ day of ___________, 2021. 

____________________________________ 

HONORABLE DARRIN P. GAYLES

United States District Judge 

Copies furnished via CM/ECF to Counsel of Record 

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