Alger v. FCA US LLC

Filing 37

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 10/24/2018 ORDERING the 29 Motion for Discovery and 27 Motion for Discovery hearings are both CONTINUED to 11/7/2018 at 10:00 AM in Courtroom 8 (EFB) before Magistrate Judge Edmund F. Brennan. If the discovery disputes cannot be resolved in the interim, then the Parties shall file a Joint Statement Regarding Discovery Disagreement on or before 10/31/2018. (Washington, S)

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William A. Kershaw (State Bar No. 057486)
Stuart C. Talley (State Bar No. 180374)
Ian J. Barlow (State Bar No. 262213)
KERSHAW, COOK & TALLEY PC
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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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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Plaintiff,
v.
FCA US LLC f/k/a CHRYSLER GROUP
LLC, a Delaware Corporation, and DOES
1 through 100, inclusive,

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Case No.: 2:18-cv-00360-MCE-EFB
JOINT STIPULATION TO CONTINUE
HEARING DATE TO NOVEMBER 7, 2018;
[PROPOSED] ORDER
DATE:
TIME:
JUDGE:
DEPT.:

October 31, 2018
10:00 a.m.
Hon. Edmund F. Brennan
Courtroom 8, 13th Floor

Defendants.

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Plaintiff SHAWN ALGER, AS AN INDIVIDUAL AND ON BEHALF OF ALL OTHERS

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SIMILARLY SITUATED (“Plaintiff”) and Defendant FCA US LLC, formerly known as

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CHRYSLER GROUP, LLC (“Defendant”), by and through their attorneys of record in this case,

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stipulate and agree as follows:

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

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Regarding Discovery Disagreement, setting October 10, 2018, as the hearing date (Doc. #27);

JOINT STIPULATION TO CONTINUE DISCOVERY MOTION

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

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WHEREAS, on September 19, 2018, Defendant filed a Notice of Motion and Motion to Compel,

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also setting October 10, 2018, as the hearing date (Doc. #29);

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WHEREAS, on October 4, 2018, pursuant to a Joint Stipulation submitted by the parties

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(Doc. #32), the Court entered an Order continuing the hearing date on the parties’ discovery

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motions to October 31, 2018 (Doc. #33);

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WHEREAS, pursuant to Local Rule 251, the Parties are to file a Joint Statement Regarding
Discovery Disagreement on or before October 24, 2018;

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WHEREAS, the Parties are continuing to meet and confer, in earnest, in order to further

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resolve and narrow the discovery disputes. Both Parties believe additional time is needed to resolve

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and narrow the discovery disputes;

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IT IS HEREBY STIPULATED by and between Plaintiff and Defendant that the hearing

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date on Plaintiff’s Motion (Doc. #27) and Defendant’s Motion (Doc. #29) be continued to

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November 7, 2018, at 10 a.m., or as soon thereafter as this matter may be heard. If the discovery

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disputes cannot be resolved in the interim, then the Parties will file a Joint Statement Regarding

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Discovery Disagreement on or before October 31, 2018, as required by Local Rule 251.

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Dated: October 23, 2018.

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
Attorneys for Plaintiff and the putative Class

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Dated: October 23, 2018.

DYKEMA GOSSETT LLP

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By: /s/ Fred J. Fresard
DOMMOND E. LONNIE
JAMES P. FEENEY
FRED J. FRESARD
ABIRAMI GNANADESIGAN
BRITTANY MOUSOURAKIS
Attorneys for Defendant
FCA US LLC f/k/a/ Chrysler Group LLC

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-1JOINT STIPULATION TO CONTINUE DISCOVERY MOTION

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

[PROPOSED] ORDER

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The Court, having considered the Stipulation to Continue Hearing Date to November 7,
2018, submitted herewith, and good cause appearing, hereby enters the following order:
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The October 31, 2018, hearing date on Plaintiff’s Motion (Doc. #27) and

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Defendant’s Motion (Doc. #29) is continued to November 7, 2018, at 10:00 a.m., or as soon

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thereafter as this matter may be heard.

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2.

If the discovery disputes cannot be resolved in the interim, then the Parties shall file

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a Joint Statement Regarding Discovery Disagreement on or before October 31, 2018, as required

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by Local Rule 251.

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IT IS SO ORDERED.

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Dated: October 24, 2018

___________________________
Hon. Edmund F. Brennan
U.S. Magistrate Judge

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JOINT STIPULATION TO CONTINUE DISCOVERY MOTION

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