This Order expressly preserves all defenses, including jurisdictional, venue, and any other challenges under Federal Rule of Civil Procedure 12(b)(1), which will be briefed and decided at a later point in time as determined by the Court.

For every individual Direct Action Plaintiff in this MDL proceeding, the Consolidated Master DAP Complaint (and any subsequent amendments, if applicable) combined with the Short Form Complaint filed by that Plaintiff pursuant to the terms below (and any subsequent amendments, if applicable), shall be deemed that Plaintiff’s legally operative pleading.

Other than as expressly set forth above, absent further direction or leave of Court, each Short Form Complaint filed by a party represented by a member of the DAP EC may not, during the motion to dismiss process, assert additional factual allegations, claims and/or causes of action or name Defendants not named in the Consolidated Master DAP Complaint.

Any DAP that has filed a Short Form Complaint and wishes to amend the same may do so under the parameters of the Federal Rules of Civil Procedure and this Court’s relevant Orders.

By agreeing to the procedures for filing the Consolidated Master DAP Complaint and the Short Form Complaints, no Defendant has agreed to or admitted the allegations that will be set forth in those documents, nor has any Defendant conceded or waived its rights to dispute the legal validity of the claims alleged therein.

This matter having been before the Court for an initial case management conference on August 29, 2024, with attorneys for various class plaintiffs having requested appointment as interim class counsel and proposing various leadership structures, having reviewed all applicants’ written submissions, having considered the oral presentations made by counsel during the hearing on leadership appointments held on September 23, 2024, and having entered a Minute Order on the Docket on September 23, 2024 [ECF No. 146], the Court hereby ORDERS as follows:

c) Coordinating with the DAP Executive Committee and Defendants regarding procedural matters, case management, discovery, and, to the extent applicable, trial, to promote the orderly and efficient conduct of this litigation.

e) Meeting and conferring with Defendants and the DAP Executive Committee to submit to the Court a schedule governing discovery and other pretrial matters.

Moreover, if circumstances require direct correspondence with the Court by any individual plaintiff’s attorney, copies of any said communications shall simultaneously be served upon all Interim Co-Lead Class Counsel by email.

Nothing contained in this provision shall be construed to limit the rights of any party or counsel to assert the attorney-client privilege or attorney work product doctrine.

CASE MANAGEMENT ORDER NO. 14 – Production of Field Names WHEREAS, in accordance with the Court’s direction at the March 14, 2025 status conference, the parties have met and conferred with respect to their respective Requests for Production and responses and objections concerning specified structured data field names and are continuing to meet and confer on certain issues concerning the requests; and WHEREAS, the parties have agreed to mutual rolling productions of such structured data field names to be substantially completed on or before May 1, 2025; NOW, THEREFORE, IT IS SO ORDERED that: The parties shall produce their respective structured data field names on a rolling

basis to be substantially completed on or before May 1, 2025.

The Defendants and the American Medical Association and Illinois State Medical

Society (the “Association DAPs”) shall continue to meet and confer regarding structured data requests for the Association DAPs and an appropriate deadline for any such production; Dated: March 25, 2025

Matthew F. Kennelly United States District Judge

(time and expense reporting by class counsel) The Court hereby ORDERS that Interim Co-Lead Class Counsel (“Class Counsel”), to efficiently manage and direct the prosecution of this case, adhere to the following protocol with respect to time and expense reporting:

Class Counsel shall develop a standardized form for collection and submission of time and expense reports.

Within two weeks of the end of every quarter, Class Counsel shall collect the time and expense reports from any law firms authorized to perform work on behalf of the proposed Class in this litigation from the previous quarter, to be evaluated for adherence to the guidelines described herein.

At the Court’s request, Class Counsel shall make summaries of such time and expense records by timekeeper and law firm available for in camera review.

c) Time shall not be submitted, nor compensated if included in any fee petition, for the following: i. work not performed at the request or under the direction of Class