Alger v. FCA US LLC

Filing 173

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr on 5/10/2021 EXTENDING the deadline to disclose experts and exchange reports to 6/30/2021; and the deadline to disclose supplemental experts and exchange reports to 8/13/2021.(Becknal, R)

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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]
Attorneys for Plaintiff and the Class
Additional counsel listed on signature page

DYKEMA GOSSETT LLP
James P. Feeney (State Bar No. 219045)
Fred J. Fresard (Pro Hac Vice)
Krista L. Lenart (Pro Hac Vice)
333 South Grand Ave., Suite 2100
Los Angeles, California 90071
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
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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SHAWN ALGER as an individual and on
behalf of all others similarly situated,

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Case No.: 2:18-cv-00360-MCE-EFB
JOINT STIPULATION AND ORDER TO
MODIFY EXPERT DISCOVERY
SCHEDULE

Plaintiff,

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v.
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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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JOINT STIP AND [PROPOSED] 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);
WHEREAS, on January 20, 2020 the Court entered an order pursuant to the parties’

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stipulation extending the discovery cut-off date to March 30, 2020 (Dkt. No. 136);

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WHEREAS, on February 18, 2020 the Court entered an order Granting Class Certification
(Dkt. No. 141);

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WHEREAS, on March 23, 2020, the Court entered an order pursuant to the parties’ stipulation

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extending the discovery cut-off date to June 15, 2020 to allow sufficient time to conduct mediation

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(Dkt. No. 145);

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WHEREAS, on May 7, 2020 the parties engaged in a mediation that did not resolve in
settlement.

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WHEREAS, on June 17, 2020 the court entered an order extending the time for the

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completion of certain depositions to September 10, 2020 so that the parties could continue their

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mediation efforts (Dkt. No. 156);

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WHEREAS, on August 21, 2020 the court entered an order extending the time for the
completion of certain depositions to December 18, 2020 (Dkt. No. 160);

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WHEREAS, on January 4, 2021 the court entered an order extending the time for the
completion of certain depositions to March 15, 2021 (Dkt. No. 169);

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WHEREAS, following the entry of this order the parties have met and conferred concerning
the nature and extent of the defendant’s duty to supplement its discovery responses.

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WHEREAS, the defendant needs additional time to supplement its discovery responses and

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those supplemental responses will likely impact the expert reports that are due to be exchanged on

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May 14, 2021; and

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///
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JOINT STIP AND ORDER

2:18-cv-00360-MCE-EFB

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WHEREAS, the parties believe that efficiencies will be achieved if the deadline to exchange

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expert and rebuttal expert reports is extended for a period of 45 days while keeping all other

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deadlines in place.

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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 disclose experts and exchange reports shall be June 30, 2021; and

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2.

The deadline to disclose supplemental experts and exchange reports shall be August

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13, 2021.
Dated: May 4, 2021

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
401 Watt Avenue
Sacramento, California 95864
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]

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MARK P. CHALOS (Pro Hac Vice)
KENNETH S. BYRD (Pro Hac Vice)
MADELINE M. GOMEZ (Pro Hac Vice)
LIEFF CABRASER HEIMANN &
BERNSTEIN, LLP
222 Second Avenue South, Suite 1640
Nashville, Tennessee 37201
Telephone: [phone]
Facsimile:
[phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]

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Attorneys for Plaintiff and the Class
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JOINT STIP AND ORDER

2:18-cv-00360-MCE-EFB

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Dated: May 4, 2021

DYKEMA GOSSETT LLP

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By: /s/ Fred J. Fresard
James P. Feeney (State Bar No. 219045)
Fred J. Fresard (Pro Hac Vice)
Krista L. Lenart (Pro Hac Vice)
333 South Grand Ave., Suite 2100
Los Angeles, California 90071
Telephone: [phone]
Facsimile: [phone]
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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ORDER
IT IS SO ORDERED.

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Dated: May 10, 2021

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JOINT STIP AND ORDER

2:18-cv-00360-MCE-EFB