Filed: Mar. 04, 2019
Latest Update: Mar. 04, 2019
Summary: STIPULATION AND ORDER REGARDING CLASS CERTIFICATION BRIEFING SCHEDULE AND CLOSE OF MERITS DISCOVERY MORRISON C. ENGLAND, JR. , District Judge . Plaintiff Shawn Alger ("Plaintiff") and Defendant FCA US LLC f/k/a Chrysler Group LLC ("Defendant") (together, the "Parties"), by and through their respective counsel, hereby stipulate as follows: STIPULATION WHEREAS, this case is a class action lawsuit wherein plaintiff alleges that certain models of vehicles manufactured by defendant are defect
Summary: STIPULATION AND ORDER REGARDING CLASS CERTIFICATION BRIEFING SCHEDULE AND CLOSE OF MERITS DISCOVERY MORRISON C. ENGLAND, JR. , District Judge . Plaintiff Shawn Alger ("Plaintiff") and Defendant FCA US LLC f/k/a Chrysler Group LLC ("Defendant") (together, the "Parties"), by and through their respective counsel, hereby stipulate as follows: STIPULATION WHEREAS, this case is a class action lawsuit wherein plaintiff alleges that certain models of vehicles manufactured by defendant are defecti..
More
STIPULATION AND ORDER REGARDING CLASS CERTIFICATION BRIEFING SCHEDULE AND CLOSE OF MERITS DISCOVERY
MORRISON C. ENGLAND, JR., District Judge.
Plaintiff Shawn Alger ("Plaintiff") and Defendant FCA US LLC f/k/a Chrysler Group LLC ("Defendant") (together, the "Parties"), by and through their respective counsel, hereby stipulate as follows:
STIPULATION
WHEREAS, this case is a class action lawsuit wherein plaintiff alleges that certain models of vehicles manufactured by defendant are defective;
WHEREAS, the parties have been engaged in discovery since the commencement of this action in an effort to ensure that plaintiff has sufficient evidence to file a Motion for Class Certification;
WHEREAS, the parties desire to put in place a class certification briefing schedule that will ensure that each party is provided sufficient time to respond to the various arguments presented by the opposing party;
WHEREAS, in the interest of judicial economy and to prevent the unnecessary expenditure of resources, the parties also desire to extend the discovery cut-off date in this case so that additional, merits-based discovery can be finalized following the court's ruling on plaintiff's Motion for Class Certification.
NOW, THEREFORE, the undersigned counsel for the Parties, having met and conferred, stipulate and agree as follows:
1. On or before April 30, 2019 Plaintiff will file his Motion for Class Certification.
2. To the extent Plaintiff submits any declarations or reports from experts to support his Motion for Class Certification, he shall also provide defense counsel with dates that such experts will be available for deposition within 30 days of the submission of such reports or declarations.
3. Defendant's opposition to Plaintiff's Motion for Class Certification will be filed on or before June 30, 2019.
4. To the extent Defendant submits any declarations or reports from experts to support its Response in Opposition to Plaintiff's Motion for Class Certification, it shall also provide Plaintiff's counsel with dates that such experts will be available for deposition within 30 days of the submission of such reports or declarations.
5. Plaintiffs' reply in support of his Motion for Class Certification will be filed on or before July 30, 2019.
6. The page limits on the Motion for Class Certification shall be as follows: Plaintiff's Motion for Class Certification 30 pages, Defendant's Opposition to Motion for Class Certification 30 pages; Plaintiff's Reply Brief in Support of Motion for Class Certification 15 pages.
7. The deadline to complete merits-based discovery is November 30, 2019.
IT IS SO ORDERED.
