Alger v. FCA US LLC

Filing 65

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 6/11/19 ORDERING Defendant's opposition to Plaintiff's Motion for Class Certification will be due on or before 7/15/19, along with any declarations or reports from experts in support of same; Plaintiff's reply in support of his Motion for Class Certification will be due on or before 8/30/19. (Becknal, R)

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DYKEMA GOSSETT LLP
James P. Feeney (219045)
[e-mail]
Fred J. Fresard (pro hac vice)
Dommond E. Lonnie (142662)
Krista Lenart (pro hac vice)
[e-mail]
Brittany J. Mouzourakis (pro hac vice)
[e-mail]
[e-mail]
Abirami Gnanadesigan (263375)
[e-mail]
333 South Grand Avenue
Suite 2100
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant FCA US 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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STIPULATION TO EXTEND CLASS
CERTIFICATION BRIEFING
SCHEDULE; ORDER

Plaintiff,

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

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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Pursuant to Eastern District of California Local Rules 143 and 144, Plaintiff Shawn Alger

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

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(collectively, the “Parties”), by and through their attorneys of record, hereby stipulate as follows:

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STIPULATION
WHEREAS, this case is a putative class action lawsuit wherein Plaintiff alleges that certain
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STIPULATION TO EXTEND BRIEFING SCHEDULE

2:18-cv-00360-MCE-EFB

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models of vehicles manufactured by Defendant are defective;

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WHEREAS, the Parties previously negotiated a schedule for briefing class certification and

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completing merits discovery, where Plaintiff’s deadline to file his motion for class certification was

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April 30, 2019, Defendant’s deadline to file its opposition was June 30, 2019, and the deadline for

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Plaintiff’s reply in support of his motion for class certification was July 30, 2019. The proposed

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deadline to complete merits-based discovery was November 30, 2019. These deadlines were set

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forth in the Parties’ Stipulation and [Proposed] Order Regarding Class Certification Briefing

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Schedule and Close of Merits Discovery, filed on February 27, 2019. (Dkt. No. 46.);

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WHEREAS, on March 4, 2019, the Court entered an Order granting the Parties’ proposed

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schedule on class certification and merits discovery. (Stip. and Order Regarding Class Cert.

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Briefing Schedule and Close of Merits Disc.) (Dkt. No. 47.)

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WHEREAS, pursuant to the Court’s Order, Plaintiff filed his motion for class certification
and accompanying documents on April 30, 2019.

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WHEREAS, on or around April 29, 2019, Defendant contacted Plaintiff to request a two-

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week extension for filing its opposition to Plaintiff’s class certification motion due to a vacation that

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defense counsel had scheduled for June;

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WHEREAS, after meeting and conferring, the Parties agreed that Defendant’s deadline to

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oppose Plaintiff’s class certification motion would be extended by two weeks and that Plaintiff’s

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deadline to file his reply in support of class certification would also be extended by two weeks.

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WHEREAS, no previous extensions of time have been sought by the Parties as to the briefing
schedule for class certification.
NOW, THEREFORE, the undersigned counsel for the Parties, having met and conferred and
good cause appearing, stipulate and agree as follows:
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Defendant’s opposition to Plaintiff’s Motion for Class Certification will be due on or

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before July 15, 2019, along with any declarations or reports from experts in support

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of same.

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2.

Plaintiff’s reply in support of his Motion for Class Certification will be due on or
before August 30, 2019.
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STIPULATION TO EXTEND BRIEFING SCHEDULE

2:18-cv-00360-MCE-EFB

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Dated: June 7, 2019

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

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Attorneys for Plaintiff and the putative Class

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Dated: June 7, 2019

DYKEMA GOSSETT LLP

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By: /s/ Fred J. Fresard
DOMMOND E. LONNIE
JAMES P. FEENEY
FRED J. FRESARD (pro hac vice)
BRITTANY J. MOUZOURAKIS (pro hac
vice)
ABIRAMI GNANADESIGAN

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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.
Dated: June 11, 2019

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STIPULATION TO EXTEND BRIEFING SCHEDULE

2:18-cv-00360-MCE-EFB