Alger v. FCA US LLC

Filing 156

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr., on 6/16/2020 CONTINUING the deadline to complete previously noticed depositions, as well as the depositions of Dr. Bruce Davis and Dr. Mariusz Ziejewski, to 9/10/2020. (Kastilahn, A)

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1 7 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: (916) 779-7000 Facsimile: (916) 721-2501 Email: bill@kctlegal.com Email: stalley@kctlegal.com Email: ian@kctlegal.com 8 Attorneys for Plaintiff and the putative Class 9 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: (213) 457-1800 Facsimile: (213) 457-1850 Email: jfeeney@dykema.com Email: ffresard@dykema.com Email: dlonnie@dykema.com Email: agnanadesigan@dykema.com 2 3 4 5 6 10 11 12 13 14 15 16 17 18 Attorneys for Defendant FCA US LLC f/k/a Chrysler Group LLC 19 UNITED STATES DISTRICT COURT 20 EASTERN DISTRICT OF CALIFORNIA 21 22 SHAWN ALGER as an individual and on behalf of all others similarly situated, 23 Case No.: 2:18-cv-00360-MCE-EFB STIPULATION AND ORDER EXTENDING DISCOVERY DEADLINES Plaintiff, 24 v. Assigned to Hon. Morrison C. England, Jr. Courtroom 7, 14th Floor Complaint Filed: February 16, 2018 25 26 27 FCA US LLC f/k/a CHRYSLER GROUP LLC, a Delaware Corporation, and DOES 1 through 100, inclusive, Defendants. 28 1 STIP AND ORDER 2:18-cv-00360-MCE-EFB 1 Plaintiff Shawn Alger (“Plaintiff”) and Defendant FCA US LLC f/k/a Chrysler Group LLC 2 (“Defendant”) (together, the “Parties”), by and through their respective counsel, hereby stipulate as 3 follows: 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 STIPULATION 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]; 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]; WHEREAS, Plaintiff served his initial disclosures on September 19, 2018 and Defendant served its initial disclosures and supplemental initial disclosures on September 28, 2018; WHEREAS, the Court entered an order on January 4, 2019 extending the discovery cut-off to March 18, 2019 [Dkt. No. 43]; 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]; 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; WHEREAS, on January 6, 2020 the Court entered an order pursuant to the parties’ stipulation extending the discovery cut-off date to March 30, 2020 (Dkt 136); 19 WHEREAS, on February 18, 2020 the Court entered an order Granting Class Certification; 20 WHEREAS, on March 23, 2020 the Court entered an order pursuant to the parties’ stipulation 21 extending the discovery cut-off date to June 15, 2020 (Dkt 145); 22 WHEREAS, on May 7, 2019 the parties engaged in a mediation before the Honorable Layne 23 Phillips and continue to engage in settlement discussions in the hope of obtaining resolution of this 24 case; and 25 26 27 28 WHEREAS, the parties desire to further continue the discovery cut-off date for 90 days in order to continue settlement discussions. NOW, THEREFORE, the undersigned counsel for the Parties, having met and conferred, stipulate and agree as follows: 2 STIP AND ORDER 2:18-cv-00360-MCE-EFB 1 The deadline to complete previously noticed depositions, as well as the depositions of Dr. 2 Bruce Davis and Dr. Mariusz Ziejewski, is continued to September 10, 2020. All other case 3 deadlines shall be adjusted accordingly, consistent with the Court’s Initial Pretrial Scheduling 4 Order [Dkt. No. 3]. 5 Dated: June 15, 2020. Respectfully submitted, 6 KERSHAW, COOK & TALLEY PC 7 8 10 By: /s/ Stuart C. Talley STUART C. TALLEY WILLIAM A. KERSHAW IAN J. BARLOW 11 Attorneys for Plaintiff and the putative Class 9 12 Dated: June 15, 2020 DYKEMA GOSSETT LLP 13 By: /s/ Fred J. Fresard FRED J. FRESARD DOMMOND E. LONNIE JAMES P. FEENEY ABIRAMI GNANADESIGAN 14 15 16 17 Attorneys for Defendant FCA US LLC f/k/a/ Chrysler Group LLC 18 19 20 21 ORDER IT IS SO ORDERED. 22 Dated: June 16, 2020 23 24 25 26 27 28 3 STIP AND ORDER 2:18-cv-00360-MCE-EFB

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