STIPULATION AND ORDER TO STAY ACTION JUDICIAL PANEL ON MUL TIDISTRICT LITIGATION

EDWARD M. CHEN, District Judge.

WHEREAS, on January 20, 2017, plaintiff Auburn Carpenter ("Plaintiff') filed a complaint (the "Complaint") against FCA US LLC ("FCA"), Robert Bosch LLC, and Robert Bosch GmbH (together, "Defendants");1

WHEREAS, Plaintiff alleges in the Complaint that Defendants made false representations concerning vehicle emissions and fuel efficiency concerning model year 2014-2016 Dodge Ram 1500 and model year 2014-2016 Jeep Grand Cherokee vehicles equipped with "EcoDiesel" engines (see Dkt. 1 at 4);

WHEREAS, Plaintiff alleges that the vehicles were equipped with a so-called "defeat device" designed to limit emissions and increase fuel efficiency in testing conditions (see id. at 31);

WHEREAS, Plaintiff purports to bring suit on behalf of a national, putative class of purchasers and lessees of the Dodge Ram 1500 and the Jeep Grand Cherokee vehicles with EcoDiesel engines (see id. at 56-57);

WHEREAS, at least eight other putative class action lawsuits (with the instant action, the "Actions") have been filed against FCA and/or Defendants making similar allegations concerning false representations of fuel efficiency and vehicle emissions in FCA vehicles with diesel engines that were allegedly equipped with "defeat devices,"2 and additional such suits may be filed in the future;

WHEREAS, plaintiffs in one of the Actions, Warren v. FCA US LLC, No. 17-cv-00059, have filed a motion with the Judicial Panel on Multidistrict Litigation ("JPML") requesting Transfer and Centralization of all Related Cases (and any future-filed "tag-along" actions), including the instant action, for coordinated or consolidated pretrial proceedings in a multidistrict litigation ("MDL"; the "MDL Motion"), see In re Chrysler-Dodge-Jeep EcoDiesel Mktg., Sales Practices, and Prods. Liab. Litig., MDL No. 2777 (J.P.M.L. filed February 9, 2017) (Dkt. No. 1);

WHEREAS, FCA intends to file a brief with the JPML supporting centralization of the Actions, including the instant action, and any "tag-along" cases in one district for consolidated pre-trial proceedings;

WHEREAS, the MDL Motion has been set for the next JPML Hearing Session on March 30, 2017;

WHEREAS, the parties have met and conferred and agree that the requested stay during the pendency of the MDL Motion would save judicial and party resources;

WHEREAS, if the MDL Motion is withdrawn and no Defendant thereafter (within two weeks of withdrawal) files its own motion with the JPML requesting transfer and centralization of all Actions (and any future-filed "tag-along" actions), including the instant action, for coordinated or consolidated pretrial proceedings in an MDL, the parties agree that the stay of this action should be immediately lifted; and

WHEREAS, should a stay order not be entered in any other related case, either party may move to lift the stay of this action.

NOW, THEREFORE, the parties, by and through their undersigned attorneys, hereby stipulate and request that the Court enter an Order staying all proceedings and cancelling any deadlines in this action until further order of the Court after the JPML has decided whether to centralize the Actions, including the instant action, in an MDL proceeding.

ATTESTATION (CIVIL LOCAL RULE 5-l(i)(3))

In accordance with Civil Local Rule 5-1 (i)(3), I attest that concurrence in the filing of this document has been obtained from the signatories. SULLIVAN & CROMWELL LLP

ORDER

PURSUANT TO STIPULATION, IS SO ORDERED.