Gathron v. Chrysler Group LLC

Filing 38

STIPULATION AND ORDER TO RESCHEDULE CASE MANAGEMENT CONFERENCE re 37 STIPULATION. Case Management Statement due by 6/17/2014. Case Management Conference set for 6/24/2014 02:00 PM in Courtroom 2, 17th Floor, San Francisco. Signed by Judge William H. Orrick on 05/16/2014. (jmdS, COURT STAFF) (Filed on 5/16/2014)

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

Elizabeth C. Pritzker (State Bar No. 146267)
[e-mail]
Bethany L. Caracuzzo (State Bar No. 190687)
[e-mail]
PRITZKER | LAW
633 Battery Street, Suite 110
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Eric H. Gibbs (State Bar No. 178658)
[e-mail]
Dylan Hughes (State Bar No. 209113)
[e-mail]
Rachel A. Naor (State Bar No. 284966)
[e-mail]
GIRARD GIBBS LLP
601 California Street, 14th Floor
San Francisco, California 94108
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff Kiwanna McClain Gathron
[ADDITIONAL COUNSEL LISTED NEXT PAGE]

16
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

17
18
19

KIWANNA MCCLAIN GATHRON,
Plaintiff,

20
21
22

vs.
CHRYSLER GROUP LLC,

23
24
25

Defendant.

Case No. 3:13-cv-05922-WHO
STIPULATION AND ORDER TO
RESCHEDULE CASE MANAGEMENT
CONFERENCE
N.D. Cal Local Rules 6-1(b) and 6-2
Date: May 27, 2014
Time: 2:00 P.M.
Judge: Hon. William H. Orrick
Courtroom: 2, 17th Floor

26
27
28

STIPULATION AND ORDER TO RESCHEDULE CASE MANAGEMENT
CONFERENCE CASE NO. 3:13-cv-05922-WHO

1
2
3
4
5

Wayne A. Wolff (State Bar No. 161351)
[e-mail]
SEDGWICK LLP
333 Bush Street, 30th Floor
San Francisco, California 94101-2834
Telephone: [phone]
Facsimile: [phone]

12

Kathy A. Wisniewski
[e-mail]
John W. Rogers
[e-mail]
Stephen A. D’Aunoy
[e-mail]
THOMPSON COBURN LLP
One US Bank Plaza
St. Louis, Missouri 63101
Telephone: [phone]
Facsimile: [phone]

13

Attorneys for Defendant Chrysler Group LLC

6
7
8
9
10
11

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

STIPULATION AND ORDER TO RESCHEDULE CASE MANAGEMENT
CONFERENCE CASE NO. 3:13-cv-05922-WHO

1

This stipulation is entered into by Plaintiff Kiwanna McClain Gathron and Defendant Chrysler

2

Group LLC, by and through their respective counsel, with reference to the following facts and recitals:

3

1.

4

Plaintiff filed her proposed class action complaint on December 20, 2013, alleging that
the headlight harnesses in 2011 and 2012 Dodge Chargers are defective;

5

2.

Chrysler filed a motion to dismiss Plaintiff’s complaint on February 19, 2014;

6

3.

As the parties reported in their joint case management conference statement, (Dkt. # 32),

7

because Chrysler issued a recall of the 2011 and 2012 Dodge Charger vehicles built

8

between May 20, 2010 and November 8, 2011, the parties decided to focus their

9

preliminary discovery efforts on the recall and its effect on this litigation;

10

4.

At the case management conference on March 25, 2014, the Court vacated the hearing on

11

defendant’s motion to dismiss in order to allow the parties to focus on this limited

12

discovery; (Dkt. # 36);

13

5.

Chrysler has begun its production of documents responsive to Plaintiff’s discovery

14

requests, and anticipates completing its production by May 22, 2014, three days before

15

the scheduled case management conference;

16

6.

Plaintiff has committed to promptly reviewing the production once it is completed and

17

evaluating whether all of her litigation goals have been achieved and this case can be

18

dismissed voluntarily;

19

7.

However, because Chrysler anticipates completing its production only a few days before

20

the case management conference, the parties jointly request that the conference be reset

21

to allow Plaintiff’s review and evaluation to be completed before the parties return to

22

Court;

23

8.

The parties therefore request that the Court reschedule the case management conference

24

scheduled for May 27, 2014, to June 24, 2014, with the parties to file their joint CMC

25

statement by June 17, 2014.

26

NOW, THEREFORE, the parties hereby stipulate and agree, subject to Court approval, that the

27

parties shall have until June 17, 2014, to file their joint case management conference statement, and that

28

the case management conference is reset to June 24, 2014.
1
STIPULATION AND ORDER TO RESCHEDULE CASE MANAGEMENT
CONFERENCE CASE NO. 3:13-cv-05922-WHO

1
2
3

DATED: May 16, 2014

4

PRITZKER | LAW
By: /s/ Elizabeth C. Pritzker

5
Elizabeth C. Pritzker
Attorneys for Plaintiff Kiwanna McClain Gathron

6
7
8

DATED: May 16, 2014

9

GIRARD GIBBS LLP
By: /s/ Dylan Hughes

10
Dylan Hughes
Attorneys for Plaintiff Kiwanna McClain Gathron

11
12

DATED: May 16, 2014

SEDGWICK LLP

13
By: /s/ Wayne A. Wolff

14

Wayne A. Wolff
Attorneys for Chrysler Group LLC

15
16

DATED: May 16, 2014

THOMPSON COBURN LLP

17
By: /s/ John W. Rogers

18

John W. Rogers
Attorneys for Chrysler Group LLC

19
20
21
22
23

ATTESTATION
I, Elizabeth C. Pritzker, am the ECF User whose ID and password are being used to file this

24

document. In compliance with Local Rule 5-1(i)(3), I hereby attest that all other signatories listed have

25

concurred in this filing.

26
27
28

/s/ Elizabeth C. Pritzker
Elizabeth C. Pritzker
2
STIPULATION AND ORDER TO RESCHEDULE CASE MANAGEMENT
CONFERENCE CASE NO. 3:13-cv-05922-WHO

1
2
3
4
5

PURSUANT TO STIPULATION, IT IS ORDERED that the parties shall have until June 17,
2014, to file their joint case management conference statement, and that the case management
conference is reset to June 24, 2014.

6
7
8
9

Dated: May 16, 2014
Hon. William H. Orrick
United States District Judge

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3
STIPULATION AND ORDER TO RESCHEDULE CASE MANAGEMENT
CONFERENCE CASE NO. 3:13-cv-05922-WHO