With no explanation, chose the best option from "A", "B", "C" or "D". questions, Pennsylvania counsel also raised objections about the identity of documents Bayer’s counsel reviewed with the witnesses in deposition preparation. Defendants of course have no objection to the Court coordinating with Judge New on this matter and involving him in its resolution as appropriate. Nonetheless, it is appropriate for this Court to resolve the issue to preserve efficiency and consistency in Xarelto actions, particularly in light of PTO 23 (¶ H.M.38), which contemplates that this Court will resolve any "disputes during or relating to depositions” taken in tire MDL, See, e.g,, 28 U.S.C, § 1407 (MDL procedure exists to “promote the just and efficient conduct of [related] actions” and serve “the convenience of parties”); Manual for Complex Litigation (4th) § 20.313 (<HOLDING>). * V 4 Defendants respectfully request that

A: recognizing need for coordinating rulings on discovery disputes
B: holding that a discovery exception to a statute of limitation applies only to the discovery of facts not discovery of the law
C: recognizing trial courts decision on discovery issues implies a finding that requested discovery was not reasonably available
D: recognizing the need for limited jurisdictional discovery to establish exception to the fsia
A.