Alger v. FCA US LLC

Filing 179

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr. on 9/13/2021 ORDERING the deadline for FCA US LLC to file its Motion for Summary Judgment shall be 9/27/2021. Plaintiffs shall have 21 days to respond to FCA US LLC's Motion for Summary Judgment. (Huang, H)

Case 2:18-cv-00360-MCE-JDP Document 179 Filed 09/13/21 Page 1 of 3

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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 Class

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Klein Thomas & Llee LLC
Fred J. Fresard (Pro Hac Vice)
[e-mail]
Ian K. Edwards (Pro Hac Vice)
[e-mail]
Anthony Thomas (State Bar No. 149284.)
[e-mail]
1100 Town and Country Rd
Orange, CA 92868
Telephone: [phone]
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,

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

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STIPULATION TO EXTEND
DISPOSITIVE MOTION DEADLINE;
ORDER

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

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

Defendants.

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STIPULATION TO EXTEND DISPOSITIVE MOTION DEADLINE

Case 2:18-cv-00360-MCE-JDP Document 179 Filed 09/13/21 Page 2 of 3

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

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(“Defendant” or “FCA”) (collectively, the “Parties”), by and through their attorneys of record,

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hereby stipulate as follows:

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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, on February 18, 2020 the Court entered an order Granting Class Certification
[Dkt. No. 141];
WHEREAS, on April 10, 2018, the Court entered an Order allowing Plaintiff to file his SAC
by April 23, 2018 and granting the Parties’ proposed briefing schedule [Dkt. No. 12];
WHEREAS, Plaintiff filed his SAC on April 23, 2018 [Dkt. No. 13] and Defendant filed its
Answer to the SAC on May 14, 2018 [Dkt. No. 14];
WHEREAS, on May 7, 2020 the parties engaged in a mediation that did not result in a
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. 165];

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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]
Whereas on May 10, 2021 the court entered an order extending the time for the parties to
exchange expert rebuttal reports to August 13, 2021 [Dkt. No. 173];

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WHEREAS, the parties are still completing expert discovery, including expert depositions;

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WHREAS, the parties are continuing settlement negotiations;

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WHEREAS, the Defendant needs to complete expert depositions before it can finalize its

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Motion for Summary Judgment; and

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

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Defendant’s Motion for Summary Judgment is extended for a period of 14 days while keeping all

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other deadlines in place.
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STIPULATION TO EXTEND DISPOSITIVE MOTION DEADLINE

2:18-cv-00360-MCE-EFB

Case 2:18-cv-00360-MCE-JDP Document 179 Filed 09/13/21 Page 3 of 3

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NOW, THEREFORE, undersigned counsel for the Parties, having met and conferred,
stipulate and agree as follows:
1.

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The deadline for FCA US LLC to file its Motion for Summary Judgment shall be
September 27, 2021.

2.

Plaintiffs shall have 21 days to respond to FCA US LLC’s Motion for Summary
Judgment.

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Dated: September 10, 2021

Respectfully submitted,
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: September 10, 2021

KLEIN THOMAS & LEE PLLC

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By: /s/ Fred J. Fresard
Fred J. Fresard
Ian K. Edwards
Anthony S. Thomas

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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: September 13, 2021

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STIPULATION TO EXTEND DISPOSITIVE MOTION DEADLINE

2:18-cv-00360-MCE-EFB