United States District Court, W.D. Washington, Seattle
TAMARA LOHR and RAVIKIRAN SINDOGI on behalf of themselves and all others similarly situated, Plaintiffs,
NISSAN NORTH AMERICA, INC., and NISSAN MOTOR CO., LTD., Defendants.
TERRELL MARSHALL LAW GROUP PLLC Attorneys for Plaintiffs,
Beth E. Terrell, Amanda M. Steiner, Benjamin M. Drachler,
Terrell Marshall Law Group PLLC, Gregory F. Coleman, Mark E.
Silvey, Lisa A. White, GREG COLEMAN LAW PC, Charles J.
Crueger, Erin Dickinson, CRUEGER DICKINSON LLC Edward A.
Wallace, WEXLER WALLACE LLP.
HARDY & BACON L.L.P. Attorneys for Defendant Nissan North
America, Inc. Heather A. Hedeen, SHOOK HARDY & BACON
L.L.P. Amir Nassihi, Andrew L. Chang, SHOOK HARDY & BACON
L.L.P., Holly Pauling Smith, William R. Sampson, SHOOK HARDY
& BACON L.L.P.
STIPULATION AND ORDER TO FURTHER EXTEND CLASS
CERTIFICATION DEADLINES TO FACILITATE SETTLEMENT
RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE.
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
March 28, 2019, the Parties had a productive all day private
mediation before Hon. James L. Warren (Ret.) at JAMS in San
Based on the Parties' progress, a second all day
mediation session has been scheduled for May 23, 2019.
Parties are coordinating discovery and class certification
deadlines in this action with a companion case filed in the
Northern District of California, Johnson v. Nissan N.
Am., Inc., 4. The Parties require additional time to
continue mediation efforts before undertaking further work to
complete discovery in anticipation of class certification
briefing and in anticipation of the preparation of expert
Parties have agreed to extend the deadlines in this case and
in Johnson, to accommodate resolution discussions.
Parties have coordinated with counsel in Johnson and
are seeking entry of a similar scheduling order. If this
Court and the Johnson court approve these requests,
then the two cases will remain on parallel tracks if a
resolution is not reached. An extension of the deadlines in
this matter, as reflected below, would facilitate settlement
discussions and will not be unduly prejudicial to either
these reasons, the Parties stipulate to extend the deadlines
in this matter as set forth below and respectfully request
that the Court enter an order accordingly:
Deadline to file Motion for Class Certification and
serve Plaintiffs' expert disclosures and
June 14, 2019
November 19, 2019
Deadline for Plaintiffs to produce experts for
July 26, 2019
December 31, 2019
Deadline to file opposition to Motion for Class
Certification and serve NNA's expert
disclosures and reports
September 4, 2019
February 10, 2020
Deadline for NNA to produce experts for deposition
September 23, 2019
February 28, 2020
Deadline to file reply regarding Motion for Class
October 14, 2019
March 19, 2020