Lohr v. Nissan North America, Inc et al

Filing 75

ORDER re parties' 74 Stipulation to Further Extend Class Certification Deadlines. Deadline to file Motion for ClassCertification and serve Plaintiffs' expert disclosures and reports is 6/19/2020; Deadline for Plaintiffs to produce experts for deposition is 7/30/2020; Deadline to file opposition to Motion for Class Certification and serve NNA's expert disclosures and reports is 10/9/2020; Deadline for NNA to produce experts for deposition is 11/13/2020; Deadline to file reply regarding Motion for Class Certification is 11/25/2020. Signed by Judge Ricardo S. Martinez. (PM)

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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TAMARA LOHR and RAVIKIRAN
SINDOGI, on behalf of themselves and
all others similarly situated,

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Plaintiffs,

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STIPULATION AND ORDER TO
FURTHER EXTEND CLASS
CERTIFICATION DEADLINES

vs.
NISSAN NORTH AMERICA, INC.
Defendant.

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NO. 2:16-cv-01023-RSM

Plaintiffs Tamara Lohr and Ravikiran Sindogi (“Plaintiffs”) and Defendant Nissan
North America, Inc. (“NNA”) (collectively, the “Parties”) enter into this stipulation
with reference to the following facts and recitals:
1. Between March and June, 2019, Parties attempted mediation before Hon.
James L. Warren (Ret.) at JAMS in San Francisco. No resolution was
reached.
2. The Parties are coordinating discovery and class certification deadlines in
this action with a companion case filed in the Northern District of
California, Johnson, et al. v. Nissan N. Am., Inc., Case No. 3:17-cv-00517WHO.
3. Due to the unsuccessful mediation efforts, the Parties need additional time
to complete discovery in anticipation of class certification briefing and in
anticipation of the preparation of expert reports.
4. As the result of significant consultation and coordination of their
scheduling needs, the Parties have agreed to extend the deadlines in this

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case and in Johnson to accommodate the delays from trying to mediate,

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both parties’ need for additional discovery, and the necessity of addressing

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complex issues in both cases with the assistance of experts.

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5. The Parties have coordinated with counsel in Johnson and are seeking

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entry of a similar scheduling order. If this Court and the Johnson court

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approve these requests, then the two cases will remain on parallel tracks if

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a resolution is not reached prior to class certification. An extension of the

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deadlines in this matter, as reflected below, may facilitate on-going

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informal settlement discussions, and will not be unduly prejudicial to

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either party.
6. Four other extensions of the class certification briefing schedule have been
entered in this matter. ECF Nos. 62, 68, 70, and 73.
7. For the above reasons, the Parties stipulate to extend the deadlines in this

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matter as set forth below and respectfully request that the Court enter an

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order accordingly:

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Event

Deadline

Proposed Deadline

Deadline to file Motion for Class
Certification and serve Plaintiffs’ expert
disclosures and reports

November 19, 2019

June 19, 2020

Deadline for Plaintiffs to produce experts for
deposition

December 31, 2019

July 30, 2020

Deadline to file opposition to Motion for
Class Certification and serve NNA’s expert
disclosures and reports

February 10, 2020

October 9, 2020

Deadline for NNA to produce experts for
deposition

February 28, 2020

November 13, 2020

Deadline to file reply regarding Motion for
Class Certification

March 19, 2020

November 25, 2020

Class Certification Hearing

April 15, 2020

As set by Court

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IT IS SO STIPULATED.
Respectfully submitted,

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Dated: September 26, 2019

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By: /s/ Lisa A. White
Presented by and on Behalf of Plaintiffs

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Greg F. Coleman (pro hac vice)
Adam A. Edwards (pro hac vice)
Lisa A. White (pro hac vice)
GREG COLEMAN LAW PC
First Tennessee Plaza
800 S. Gay Street, Suite 1100
Knoxville, Tennessee 37929
Tel: [phone]
[e-mail]
[e-mail]
[e-mail]
Beth E. Terrell (WSBA #26759)
Amanda M. Steiner (WSBA #29147)
Benjamin M. Drachler (WSBA #51021)
TERRELL MARSHALL LAW
GROUP PLLC
936 North 34th Street, Suite 300
Seattle, Washington 98103-8869
Telephone: [phone]
[e-mail]
[e-mail]
[e-mail]

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Charles Crueger (pro hac vice)
Erin Dickinson (pro hac vice)
CRUEGER DICKINSON LLC
4532 N. Oakland Avenue
Whitefish Bay, WI 53211
Telephone: [phone]
[e-mail]
[e-mail]

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Edward A. Wallace
WEXLER WALLACE LLP
55 West Monroe Street, Suite 3300
Chicago, Illinois 60603
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Attorneys for Plaintiff

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Dated: September 26, 2019
By: /s/ Holly Pauling Smith
Presented by and on Behalf of Defendant
William R. Sampson (pro hac vice)
Holly Pauling Smith (pro hac vice)
SHOOK, HARDY & BACON L.L.P.
2555 Grand Boulevard
Kansas City, Missouri 64108
Tel: [phone]
Fax: [phone]
Heather A. Hedeen, WSBA #50687
SHOOK HARDY & BACON L.L.P.
701 Fifth Avenue, Suite 6800
Seattle, WA 98104
Phone: [phone]
[e-mail]

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Amir M. Nassihi (SBN 235936)
SHOOK, HARDY & BACON L.L.P.
One Montgomery, Suite 2600
San Francisco, CA 94104
Tel: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Defendant

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I. ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated this 30 day of September, 2019.

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A

RICARDO S. MARTINEZ
CHIEF UNITED STATES DISTRICT JUDGE

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