Alger v. FCA US LLC

Filing 33

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 10/4/2018 CONTINUING hearing re 27 and 29 Motions for Discovery to 10/31/2018 at 10:00 AM. If the discovery disputes cannot be resolved in the interim, then the Parties shall file a Joint Statement Regarding Discovery Disagreement on or before 10/24/2018. (Zignago, K.)

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DYKEMA GOSSETT LLP
James P. Feeney (219045)
[e-mail]
Fred J. Fresard (pro hac vice)
[e-mail]
Dommond E. Lonnie (142662)
[e-mail]
Brittany J. Mouzourakis (pro hac vice)
[e-mail]
Abirami Gnanadesigan (263375)
[e-mail]
333 South Grand Avenue
Suite 2100
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant
FCA US LLC f/k/a CHRYSLER GROUP LLC

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333 SOUTH GRAND AVENUE
SUITE 2100
LOS ANGELES, CA 90071

DYKEMA GOSSETT LLP

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION
SHAWN ALGER as an individual and on behalf

16 of all others similarly situated,
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Plaintiff,

Case No. 2:18-cv-00360-MCE-EFB
Assigned to:
Hon. Morrison C. England, Jr.

vs.

19 FCA US LLC f/k/a CHRYSLER GROUP LLC, a

JOINT STIPULATION TO CONTINUE
HEARING DATE TO OCTOBER 31, 2018

Delaware Corporation, and DOES 1 through 100,

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Defendants.

DATE:
TIME:
JUDGE:
CTRM:

October 31, 2018
10 a.m.
Hon. Edmund F. Brennan
8, 13th Floor

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JOINT STIPULATION TO
CONTINUE HEARING DATE TO OCTOBER 31, 2018
Plaintiff SHAWN ALGER, AS AN INDIVIDUAL AND ON BEHALF OF ALL OTHERS

26 SIMILARLY SITUATED (“Plaintiff”) and Defendant FCA US LLC, formerly known as
27 CHRYSLER GROUP, LLC (“Defendant”), by and through their attorneys of record in this case,
28 stipulate and agree as follows:
JOINT STIPULATION TO CONTINUE HEARING DATE TO OCTOBER 31, 2018 CASE NO. 2:18-CV-00360-MCE-EFB

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WHEREAS, on September 14, 2018, Plaintiff filed a Notice of Motion and Motion Regarding

2 Discovery Disagreement, setting October 10, 2018, as the hearing date (Doc. #27);
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WHEREAS, on September 19, 2018, Defendant filed a Notice of Motion and Motion to

4 Compel, also setting October 10, 2018, as the hearing date (Doc. #29).
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WHEREAS, pursuant to Local Rule 251, the Parties are to file a Joint Statement Regarding

6 Discovery Disagreement on or before October 3, 2018;
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WHEREAS, the Parties are continuing to meet and confer, in earnest, in order to further

8 resolve and narrow the discovery disputes. Both Parties believe additional time is needed to resolve
9 and narrow the discovery disputes;
IT IS HEREBY STIPULATED by and between Plaintiff and Defendant that the hearing date

11 on Plaintiff’s Motion (Doc. #27) and Defendant’s Motion (Doc. #29) be continued to October 31,
333 SOUTH GRAND AVENUE
SUITE 2100
LOS ANGELES, CA 90071

DYKEMA GOSSETT LLP

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12 2018, at 10 a.m., or as soon thereafter as this matter may be heard. If the discovery disputes cannot
13 be resolved in the interim, then the Parties will file a Joint Statement Regarding Discovery
14 Disagreement on or before October 24, 2018, as required by Local Rule 251.
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Dated: October 3, 2018

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Dykema Gossett LLP
James P. Feeney
Fred J. Fresard
Dommond E. Lonnie
Abirami Gnanadesigan
Brittany J. Mouzourakis

By:
/s/ Fred J. Fresard
James P. Feeney
Fred J. Fresard
Dommond E. Lonnie
Abirami Gnanadesigan
Brittany J. Mouzourakis
Attorneys for Defendant
FCA US LLC f/k/a CHRYSLER GROUP LLC

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Dated: October 3, 2018

KERSHAW, COOK &TALLEY PC
William A. Kershaw
Stuart C. Talley
Ian J. Barlow

JOINT STIPULATION TO CONTINUE HEARING DATE TO OCTOBER 31, 2018 CASE NO. 2:18-CV-00360-MCE-EFB

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By: /s/Ian J. Barlow
(As authorized on October 3, 2018)
William A. Kershaw
Stuart C. Talley
Ian J. Barlow
Attorneys for PLAINTIFF AND THE
PUTATIVE CLASS

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The Court, having considered the Stipulation to Continue Hearing Date to October 31, 2018,

10 submitted herewith, and good cause appearing, hereby enters the following order:
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1.
The October 10, 2018, hearing date on Plaintiff’s Motion (Doc. #27) and
333 SOUTH GRAND AVENUE
SUITE 2100
LOS ANGELES, CA 90071

DYKEMA GOSSETT LLP

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[PROPOSED] ORDER

12 Defendant’s Motion (Doc. #29) is continued to October 31, 2018, at 10 a.m.
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2.
If the discovery disputes cannot be resolved in the interim, then the Parties shall file
14 a Joint Statement Regarding Discovery Disagreement on or before October 24, 2018, as required by
15 Local Rule 251.
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IT IS SO ORDERED.
Dated: October 4, 2018.

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JOINT STIPULATION TO CONTINUE HEARING DATE TO OCTOBER 31, 2018 CASE NO. 2:18-CV-00360-MCE-EFB