Filed: Oct. 30, 2017
Latest Update: Oct. 30, 2017
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE JOINT PROPOSED ELECTRONICALLY STORED INFORMATION PROTOCOL EDWARD M. CHEN , District Judge . WHEREAS, pursuant to the Court's Pretrial Order No. 12 (Docket No. 222) and Amended Pretrial Order No. 12 (Docket No. 227), the Plaintiffs' Steering Committee, on behalf of the consumer and reseller dealer class plaintiffs, the Department of Justice, on behalf of the United States Environmental Protection Agency, and counsel for Defen
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE JOINT PROPOSED ELECTRONICALLY STORED INFORMATION PROTOCOL EDWARD M. CHEN , District Judge . WHEREAS, pursuant to the Court's Pretrial Order No. 12 (Docket No. 222) and Amended Pretrial Order No. 12 (Docket No. 227), the Plaintiffs' Steering Committee, on behalf of the consumer and reseller dealer class plaintiffs, the Department of Justice, on behalf of the United States Environmental Protection Agency, and counsel for Defend..
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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE JOINT PROPOSED ELECTRONICALLY STORED INFORMATION PROTOCOL
EDWARD M. CHEN, District Judge.
WHEREAS, pursuant to the Court's Pretrial Order No. 12 (Docket No. 222) and Amended Pretrial Order No. 12 (Docket No. 227), the Plaintiffs' Steering Committee, on behalf of the consumer and reseller dealer class plaintiffs, the Department of Justice, on behalf of the United States Environmental Protection Agency, and counsel for Defendants FCA US LLC, Fiat Chrysler Automobiles N.V., V.M. Motori S.p.A., V.M. North America, Inc., Sergio Marchionne, Robert Bosch, LLC, and Robert Bosch GmbH (collectively, "Defendants") (jointly, "the Parties") are required to submit a joint proposed Electronically Stored Information ("ESI") Protocol within thirty (30) days of the entry of Pretrial Order No. 12;
WHEREAS, thirty (30) days from the entry of Pretrial Order No. 12 (Docket 222) is October 28, 2017 and thirty (30) days from the entry of Amended Pretrial Order No. 12 (Docket 227) is November 1, 2017;
WHEREAS, the Parties have met and conferred, and exchanged drafts of the joint proposed ESI Protocol;
WHEREAS, the Parties have reached agreement on a substantial portion of the issues addressed by the joint proposed ESI Protocol; and
WHEREAS, due to the complexities of the technical issues involved with developing a joint proposed ESI Protocol that completely and comprehensively addresses the issues involved, the Parties require additional time to continue negotiations and finalize agreed terms;
IT IS THEREFORE STIPULATED AND AGREED by the Parties, subject to the Court's approval, as follows:
1. The deadline for the Parties to file their joint proposed ESI Protocol is November 14, 2017.
[PROPOSED] ORDER GRANTING STIPULATION TO EXTEND TIME
Based on the foregoing Stipulation, the Court GRANTS the Parties' Stipulation to Extend Time to File Joint Proposed Electronically Stored Information Protocol. The deadline for the Parties to file their joint ESI Protocol is November 14, 2017.
IT IS SO ORDERED.
