Alger v. FCA US LLC

Filing 145

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr., on 3/23/2020 EXTENDING the deadline to complete discovery to 6/15/2020. If resolution of this case is not achieved on or before 5/15/2020, plaintiff shall file a motion seeking approval of a plan to provide notice to the class. (Kastilahn, A)

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KERSHAW, COOK & TALLEY PC
William A. Kershaw (State Bar No. 057486)
Stuart C. Talley (State Bar No. 180374)
Ian J. Barlow (State Bar No. 262213)
401 Watt Avenue
Sacramento, California 95864
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]

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Attorneys for Plaintiff and the putative Class

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DYKEMA GOSSETT LLP
James P. Feeney (State Bar No. 219045)
Fred J. Fresard (pro hac vice)
Dommond E. Lonnie (State Bar No. 142662)
Abirami Gnanadesigan (State Bar No. 263375)
333 South Grand Ave., Suite 2100
Los Angeles, California 90071
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]

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Attorneys for Defendant
FCA US LLC f/k/a Chrysler Group LLC

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Case No.: 2:18-cv-00360-MCE-EFB

SHAWN ALGER as an individual and on
behalf of all others similarly situated,

STIPULATION AND ORDER
EXTENDING DISCOVERY DEADLINES

Plaintiff,
v.

Assigned to Hon. Morrison C. England, Jr.
Courtroom 7, 14th Floor
Complaint Filed: February 16, 2018

FCA US LLC f/k/a CHRYSLER GROUP
LLC, a Delaware Corporation, and DOES 1
through 100, inclusive,
Defendants.

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STIP AND ORDER

2:18-cv-00360-MCE-EFB

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Plaintiff Shawn Alger (“Plaintiff”) and Defendant FCA US LLC f/k/a Chrysler Group LLC

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(“Defendant”) (together, the “Parties”), by and through their respective counsel, hereby stipulate as

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follows:

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STIPULATION

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WHEREAS, Plaintiff filed his initial complaint on February 15, 2018 [Dkt. No. 1] and his
class action complaint on February 16, 2018 [Dkt. No. 4];

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WHEREAS, Plaintiff filed his Second Amended Complaint (“SAC”) on April 23, 2018 [Dkt.
No. 13] and Defendant filed its Answer to the SAC on May 14, 2018 [Dkt. No. 14];

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WHEREAS, Plaintiff served his initial disclosures on September 19, 2018 and Defendant
served its initial disclosures and supplemental initial disclosures on September 28, 2018;

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WHEREAS, the Court entered an order on January 4, 2019 extending the discovery cut-off
to March 18, 2019 [Dkt. No. 43];

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WHEREAS, on March 4, 2019, the Court entered an order on stipulated class certification
deadlines and to extend the discovery cut-off to November 30, 2019 [Dkt. No. 47];

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WHEREAS, pursuant to the Parties’ stipulation and the Court’s March 4, 2019 Order,
Plaintiff filed his motion for class certification on April 30, 2019;

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WHEREAS, on January 20, 2020 the Court entered an order pursuant to the parties’
stipulation extending the discovery cut-off date to March 30, 2020 (Dkt 136);

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WHEREAS, on February 18, 2020 the Court entered an order Granting Class Certification;

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WHEREAS, the parties now desire to engage in mediation to determine if resolution of this

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case is possible and seek to extend the discovery cut-off deadline to allow sufficient time to conduct

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mediation;

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NOW, THEREFORE, the undersigned counsel for the Parties, having met and conferred,
stipulate and agree as follows:

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1.

The deadline to complete merits-based discovery is extended to June 15, 2020. All

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other case deadlines shall be adjusted accordingly, consistent with the Court’s Initial

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Pretrial Scheduling Order [Dkt. No. 3].

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STIP AND ORDER

2:18-cv-00360-MCE-EFB

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2.

If resolution of this case is not achieved on or before May 15, 2020, plaintiff shall
file a motion seeking approval of a plan to provide notice to the class.

Dated: March 18, 2020.

Respectfully submitted,

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KERSHAW, COOK & TALLEY PC

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By: /s/ Stuart C. Talley
STUART C. TALLEY
WILLIAM A. KERSHAW
IAN J. BARLOW

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Attorneys for Plaintiff and the putative Class

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Dated: March 18, 2020.

DYKEMA GOSSETT LLP

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By: /s/ Fred J. Fresard
FRED J. FRESARD
DOMMOND E. LONNIE
JAMES P. FEENEY
ABIRAMI GNANADESIGAN

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Attorneys for Defendant
FCA US LLC f/k/a/ Chrysler Group LLC

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ORDER
IT IS SO ORDERED.

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DATED: March 23, 2020
_______________________________________
MORRISON C. ENGLAND, JR.
UNITED STATES DISTRICT JUDGE

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STIP AND ORDER

2:18-cv-00360-MCE-EFB