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`November 5, 2025
`VIA ECF
`Honorable Brian R. Martinotti, U.S.D.J.
`United States District Court
`District of New Jersey
`U.S. Post Office & Courthouse
`2 Federal Square
`Newark, NJ 07102
`Re: In re: Insulin Pricing Litigation, No. 2:23-md-03080-BRM-RLS
`MDL No. 3080 | CMO 23
`Dear Judge Martinotti:
`We represent the CVS Caremark and Zinc Defendants and write on behalf of all parties in
`accordance with CMO No. 22, which directed the parties to “meet and confer with Judge Dickson
`regarding the issues raised in the parties’ recent statute of limitations submissions and to establish
`a process to address those issues.” ECF No. 776. Having met and conferred as directed, the parties
`agree on the terms set forth in the attached proposed CMO. If the proposed CMO is acceptable to
`Your Honor, the parties respectfully request that the Court enter it as CMO No. 23.
`Thank you for your continuing attention to this matter.
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`cc: Honorable Lena D. Wettre, U.S.M.J.
`All counsel of record
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`Respectfully submitted,
` /s John D. Tortorella
`John D. Tortorella
`Counsel for Defendants Caremark Rx, LLC,
`Caremark LLC, and Caremark PCS Health,
`LLC
`/s Nicholas C. Suellentrop
`Nicholas C. Suellentrop
`Williams & Connolly LLP
`Counsel for Defendants Caremark Rx, LLC,
`Caremark LLC, and Caremark PCS Health,
`LLC
`e-mail: jtortorella@khmarino.com
`Case 2:23-md-03080-BRM-LDW Document 794 Filed 11/05/25 Page 1 of 1 PageID:
`21051
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