STIPULATION AND [PROPOSED] ORDER REGARDING DEPOSITION OF DEFENDANT FCA US LLC

EDMUND F. BRENNAN, Chief Magistrate Judge.

Pursuant to Magistrate Judge Edmund F. Brennan's August 8, 2018 Minute Order (Dkt. No. 22) and Local Rule 143, 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, Defendant filed a Motion for Protective Order ("Motion") on July 18, 2018 to prohibit Plaintiff's Federal Rule of Civil Procedure ("Rule") 30(b)(6) deposition of Defendant, for which Plaintiff noticed twenty-three deposition topics and attached fourteen document requests (Dkt. No. 18);

WHEREAS, the Parties filed their Joint Statement Re Discovery Disagreement on Topics Listed and Documents Requested in Plaintiff's Fed. R. Civ. P. 30(b)(6) Deposition Notice to Defendant FCA US LLC on August 1, 2018 (Dkt. No. 21);

WHEREAS, Defendant's Motion was heard on August 8, 2018;

WHEREAS, the Court entered a Minute Order on August 8, 2018 denying Defendant's Motion and directing the Parties to submit a Stipulation and Proposed Order designating the number of proposed witnesses and estimated time required for the deposition, as discussed at the hearing (Dkt. No. 22);

WHEREAS, Plaintiff's counsel sent an email to defense counsel on August 13, 2018 that grouped and narrowed the scope of topics for the Rule 30(b)(6) deposition to include the following categories and corresponding topics: NHTSA Complaints, Complaints Generally, and Internal Investigations (Topics 2, 3, 4, and 17); Design and Testing Documents (Topics 6, 7, 8, 9); Warranty Documents (Topics 13, 14, 15, and 19); Replacement Headrests (Topic 16); and E-mail retention policies (Topic 23);

WHEREAS, the Parties met and conferred telephonically on August 14, 2018 to discuss the proposed deposition categories, topics, related document requests, location, designated witnesses, and timing;

WHEREAS, the Parties agreed that Defendant would produce two witnesses to be deposed at the Law Firm of Miller, Canfield, Paddock and Stone, P.L.C. in Troy, Michigan;

WHEREAS, Defendant will produce documents for the document request categories (attached as Exhibit A to the deposition notice) that correspond with the deposition categories and topics discussed by the Parties, including document request numbers 3-8 and 10-14; and

WHEREAS, the Parties estimate that the total time for the deposition will be approximately seven hours but will meet and confer if additional time is needed. The Parties are in the process of finalizing the date(s) for the deposition.

NOW, THEREFORE, undersigned counsel for the Parties, having met and conferred, stipulate and agree as follows:

[PROPOSED] ORDER

IT IS SO ORDERED.