Crawford et al v. FCA US LLC
Derek Griesel, Leroy Mault, Hank Vanderhulst, Bradley Crawford, Greg Gouker, Nathan Felker, Jacob Lane, Brandon Bailey, Wesley Distad, Glenn Brainard, Patrick Phelan, Dennis Sullivan, Dennis Diaz, Shaun Graham, Kevin Hunting, Russell Raley, Christian Christensen, Michael O'Brien, Gary Grendahl and Paul Maier |
FCA US LLC and Chrysler Group LLC |
Dennis Anderson, Kwaterski Construction, Inc., Gregory Briggs, James Deale, Justin Ewing, Kara Gulbranson, Matthew Ogren and Reyes Vargas |
2:2020cv12341 |
August 27, 2020 |
US District Court for the Eastern District of Michigan |
David R. Grand |
Stephen J Murphy |
Contract: Other |
28 U.S.C. § 1332 Diversity-(Citizenship) |
Both |
Docket Report
This docket was last retrieved on March 4, 2024. A more recent docket listing may be available from PACER.
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Filing 59 ORDER Granting #53 Motion for Protective Order. Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 58 REPLY to Response re #53 MOTION for Protective Order from Requiring Plaintiffs to Travel to the Eastern District of Michigan for In-Person Depositions filed by Dennis Anderson, Brandon Bailey, Glenn Brainard, Gregory Briggs, Christian Christensen, Bradley Crawford, James Deale, Dennis Diaz, Wesley Distad, Justin Ewing, Nathan Felker, Greg Gouker, Shaun Graham, Gary Grendahl, Derek Griesel, Kara Gulbranson, Kevin Hunting, Kwaterski Construction, Inc., Jacob Lane, Paul Maier, Leroy Mault, Michael O'Brien, Matthew Ogren, Patrick Phelan, Russell Raley, Dennis Sullivan, Hank Vanderhulst, Reyes Vargas. (Attachments: #1 Index of Exhibits, #2 Exhibit 1 - Cases Rising: Get Boosted, Centers for Disease Control and Prevention, July 22, 2022, #3 Exhibit 2 - Omicron and BA.5: A Guide to What We Know, Yale Medicine News, Kathy Katella, July 6, 2022, #4 Exhibit 3 - Is the BA.5 COVID-19 subvariant super contagious?, Katie Kerwin McCrimmon, UCHealth Today, July 19, 2022, #5 Exhibit 4 - Omicron BA.5: What we know about this COVID-19 strain, July 12, 2022) (Miller, E.) |
Filing 57 NOTICE of Appearance by Shelby Smith on behalf of Dennis Anderson, Brandon Bailey, Glenn Brainard, Gregory Briggs, Christian Christensen, Bradley Crawford, James Deale, Dennis Diaz, Wesley Distad, Justin Ewing, Nathan Felker, Greg Gouker, Shaun Graham, Gary Grendahl, Derek Griesel, Kara Gulbranson, Kevin Hunting, Kwaterski Construction, Inc., Jacob Lane, Paul Maier, Leroy Mault, Michael O'Brien, Matthew Ogren, Patrick Phelan, Russell Raley, Dennis Sullivan, Hank Vanderhulst, Reyes Vargas. (Smith, Shelby) |
Filing 56 RESPONSE to #53 MOTION for Protective Order from Requiring Plaintiffs to Travel to the Eastern District of Michigan for In-Person Depositions filed by FCA US LLC. (Attachments: #1 Exhibit A - Azar Declaration) (Azar, Thomas) |
Filing 55 STIPULATED ORDER Amending Scheduling Order re #43 Scheduling Order, (Final Pretrial Conference Reset for 3/18/2024 02:00 PM before District Judge Stephen J. Murphy III, Jury Trial Reset for 4/1/2024 09:00 AM before District Judge Stephen J. Murphy III). Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 54 ORDER Granting Withdrawal of Counsel of Record Stephen W. King. Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 53 MOTION for Protective Order from Requiring Plaintiffs to Travel to the Eastern District of Michigan for In-Person Depositions by Dennis Anderson, Brandon Bailey, Glenn Brainard, Gregory Briggs, Christian Christensen, Bradley Crawford, James Deale, Dennis Diaz, Wesley Distad, Justin Ewing, Nathan Felker, Greg Gouker, Shaun Graham, Gary Grendahl, Derek Griesel, Kara Gulbranson, Kevin Hunting, Kwaterski Construction, Inc., Jacob Lane, Paul Maier, Leroy Mault, Michael O'Brien, Matthew Ogren, Patrick Phelan, Russell Raley, Dennis Sullivan, Hank Vanderhulst, Reyes Vargas. (Attachments: #1 Index of Exhibits, #2 Exhibit 1 Plaintiffs Notices of Depositions, #3 Exhibit 2 Why youre going to hate traveling this summer, CNN BUSINESS, June 1, 2022, #4 Exhibit 3 Plaintiffs Unpublished Authority, #5 Exhibit 4 Reynolds, et al., v. FCA US, LLC, No. 2:19-cv-11745 (E.D. Mich. May 26, 2022), #6 Exhibit 5 Michigan coronavirus dashboard: vaccines, cases, deaths and map, BRIDGE MICHIGAN, #7 Exhibit 6 A New Covid Mystery, THE NEW YORK TIMES, Apr. 6, 2022, #8 Exhibit 7 Who Is at High Risk for Severe Coronavirus Disease?, JOHNS HOPKINS MEDICINE, Dec. 8, 2021, #9 Exhibit 8 US likely to see a surge of Covid-19 in the fall, Fauci says, CNN, Apr. 7, 2022, #10 Exhibit 9 A New Wave of Covid-19 Is Coming. Heres How to Prepare, The New York Times, Mar. 30, 2022, #11 Exhibit 10 Analysis: Flight delays, cancellations mar U.S. summer travel, REUTERS, June 29, 2022, #12 Exhibit 11 Airline ticket prices are up 25%, outpacing inflation here are the ways you can still save, CNBC, June 2, 2022) (Miller, E.) |
Filing 52 NOTICE of Appearance by Alison Rodney on behalf of FCA US LLC. (Rodney, Alison) |
Filing 51 NOTICE of Appearance by Alison Rodney on behalf of FCA US LLC. (Rodney, Alison) |
Filing 50 ATTORNEY APPEARANCE: Dana Fraser appearing on behalf of Dennis Anderson, Brandon Bailey, Glenn Brainard, Gregory Briggs, Christian Christensen, Bradley Crawford, James Deale, Dennis Diaz, Wesley Distad, Justin Ewing, Nathan Felker, Greg Gouker, Shaun Graham, Gary Grendahl, Derek Griesel, Kara Gulbranson, Kevin Hunting, Kwaterski Construction, Inc., Jacob Lane, Paul Maier, Leroy Mault, Michael O'Brien, Matthew Ogren, Patrick Phelan, Russell Raley, Dennis Sullivan, Hank Vanderhulst, Reyes Vargas (Fraser, Dana) |
Filing 49 STATEMENT of DISCLOSURE of CORPORATE AFFILIATIONS and FINANCIAL INTEREST by FCA US LLC identifying Corporate Parent FCA North America Holdings LLC, Other Affiliate Stellantis N.V., Other Affiliate FCA Foreign Sales Holdco Ltd. (UK), Other Affiliate SFS UK1 Limited (UK) for FCA US LLC. (D'Aunoy, Stephen) |
Filing 48 NOTICE of Appearance by Stacey Slaughter on behalf of Dennis Anderson, Gregory Briggs, James Deale, Justin Ewing, Kara Gulbranson, Kwaterski Construction, Inc., Matthew Ogren, Reyes Vargas. (Slaughter, Stacey) |
Filing 47 NOTICE of Appearance by Austin Hurt on behalf of Dennis Anderson, Gregory Briggs, James Deale, Justin Ewing, Kara Gulbranson, Kwaterski Construction, Inc., Matthew Ogren, Reyes Vargas. (Hurt, Austin) |
Filing 46 STIPULATED ORDER Regarding Additional Case Deadlines re #43 Scheduling Order, (Motion for Class Certification due by 1/26/2023; Response due by 3/13/2023; Reply due by 4/17/2023). Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 45 STIPULATED PROTECTIVE ORDER. Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 44 STIPULATED ORDER for the Production of Documents and Electronically Stored Information Protocol. Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 43 SCHEDULING ORDER: Discovery due by 6/23/2023, Dispositive Motion Cut-off set for 7/3/2023, Final Pretrial Conference set for 10/18/2023 02:00 PM before District Judge Stephen J. Murphy III, Jury Trial set for 10/31/2023 09:00 AM before District Judge Stephen J. Murphy III. Signed by District Judge Stephen J. Murphy, III. (Refer to image for additional dates) (DPar) |
Minute Entry for virtual proceedings before District Judge Stephen J. Murphy, III: Scheduling Conference held on 9/22/2021. (Court Reporter: None Present, Not on the Record) (DPar) |
Filing 42 DISCOVERY plan jointly filed pursuant to Federal Rules of Civil Procedure 26(f) (Miller, E.) |
Filing 41 ORDER for Withdrawal of Counsel. Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 40 ORDER Requiring Joint Discovery Plan and Setting Rule 16 Scheduling Conference via ZOOM, (Scheduling Conference set for 9/22/2021 09:30 AM before District Judge Stephen J. Murphy III). Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 39 NOTICE of Appearance by Stephen W. King on behalf of FCA US LLC. (King, Stephen) |
Filing 38 ANSWER to Amended Complaint with Affirmative Defenses with Jury Demand by FCA US LLC. (Azar, Thomas) |
Filing 37 ORDER Granting #34 Motion to Withdraw as Attorney.. Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 36 ATTORNEY APPEARANCE: Carl Lansing Rowley appearing on behalf of FCA US LLC (Rowley, Carl) |
Filing 35 OPINION and ORDER Granting in Part and Denying in Part #25 Motion to Dismiss; Granting #30 Motion for Leave to File Supplemental Authority, (Answer due by 9/3/2021). Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 34 MOTION for Withdrawal of Attorney Robert J. Giuffra, Jr., William B. Monahan, and Thomas C. White by FCA US LLC. (Monahan, William) |
Filing 33 ATTORNEY APPEARANCE: Thomas L. Azar, Jr appearing on behalf of FCA US LLC (Azar, Thomas) |
Filing 32 ATTORNEY APPEARANCE: Stephen A. D'Aunoy appearing on behalf of FCA US LLC (D'Aunoy, Stephen) |
Filing 31 RESPONSE to #30 MOTION for Leave to File Notice of Supplemental Authority filed by All Defendants. (Attachments: #1 Exhibit A - Response to Plaintiffs' Notice of Supplemental Authority) (Murray, Thomas) |
Filing 30 MOTION for Leave to File Notice of Supplemental Authority by All Plaintiffs. (Attachments: #1 Exhibit 1 - Notice of Supplemental Authority) (Miller, E.) |
Filing 29 REPLY to Response re #25 MOTION to Dismiss Consolidated Class Action Complaint filed by All Defendants. (Attachments: #1 Index of Exhibits, #2 Exhibit A - NHTSA Recall Quarterly Report (Apr. 21, 2021), #3 Exhibit B - Recall Repair Confirmation (Gulbranson)) (Murray, Thomas) |
Filing 28 ORDER Finding as Moot #16 Motion to Dismiss; Finding as Moot #17 Motion to Amend. Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 27 STIPULATED ORDER Granting Withdraw of Attorney Allison W. Reimann for Defendant FCA US LLC. Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 26 RESPONSE to #25 MOTION to Dismiss Consolidated Class Action Complaint filed by All Plaintiffs. (Attachments: #1 Index of Exhibits, #2 Exhibit 1 - Unpublished Cases, #3 Exhibit 2 - Notice Letter Confirmation) (Miller, E.) |
Filing 25 MOTION to Dismiss Consolidated Class Action Complaint by All Defendants. (Attachments: #1 Index of Exhibits, #2 Exhibit A - NHTSA Recall Quarterly Report (Jan. 19, 2021), #3 Exhibit B - Recall Repair Confirmation (Anderson), #4 Exhibit C - Notice Letter from Plaintiffs' Counsel (Aug. 20, 2020), #5 Exhibit D - Notice letter from Plaintiffs' Counsel (Dec. 1, 2020), #6 Exhibit E - Notice letter from Plaintiffs' Counsel Jan. 7, 2021)) (Murray, Thomas) |
Filing 24 STIPULATED ORDER to Enlarge Page Limits for FCA US LLC's Motion to Dismiss. Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 23 STATEMENT of DISCLOSURE of CORPORATE AFFILIATIONS and FINANCIAL INTEREST by All Defendants identifying Corporate Parent FCA North America Holdings LLC, Other Affiliate FCA Holdco B.V., Other Affiliate Stellantis N.V. (f/k/a Fiat Chrysler Automobiles N.V.) for FCA US LLC. (Murray, Thomas) |
Filing 22 [DOCUMENT IS TITLED: CONSOLIDATED CLASS ACTION COMPLAINT] AMENDED COMPLAINT with Jury Demand (Consolidated Class Action Complaint) filed by Dennis Anderson, Shaun Graham, Derek Griesel, Brandon Bailey, Gregory Briggs, Bradley Crawford, Reyes Vargas, Dennis Diaz, Greg Gouker, Kwaterski Construction, Inc., Gary Grendahl, Christian Christensen, Glenn Brainard, Justin Ewing, Patrick Phelan, Nathan Felker, Hank Vanderhulst, Russell Raley, Matthew Ogren, James Deale, Kara Gulbranson, Kevin Hunting, Michael O'Brien, Leroy Mault, Dennis Sullivan, Jacob Lane, Paul Maier against FCA US LLC. NEW PARTIES ADDED. (Attachments: #1 Index of Exhibits, #2 Exhibit 1 - Part 573 Safety Recall Report for Recall 19V-757 (Nov. 14, 2019), #3 Exhibit 2 - Part 573 Safety Recall Report for Recall 19V-757 (Oct. 31, 2019), #4 Exhibit 3 - Important Safety Recall Notice Letter, #5 Exhibit 4 - Important Safety Recall Notice Letter, #6 Exhibit 5 - Dealer Service Instructions for Safety Recall 19V-757 (Apr. 2020), #7 Exhibit 6 - Dealer Service Instructions for Safety Recall 19V-757 (Rev. May 2020), #8 Exhibit 7 - Part 573 Safety Recall Report for Recall 19V-757 (Apr. 2, 2020), #9 Exhibit 8 - Customer Handling for SAFETY RECALL VB1 20142019 DS 3.0L EGR Cooler (Dec. 2019), #10 Exhibit 9 - Part 573 Safety Recall Report for Recall 19V-757 (Apr. 21, 2020),, #11 Exhibit 10 - Dealer Service Instructions for Safety Recall 19V-757 (Rev. May 1, 2020), #12 Exhibit 11 - Important Safety Recall notice sent to Plaintiff Hank Vanderhulst, #13 Exhibit 12 - Important Safety Recall notice sent to Plaintiff Leroy Mault, #14 Exhibit 13 - Important Safety Recall notice sent to Plaintiff Leroy Mault, #15 Exhibit 14 - NHTSA Press Release, U.S. DOT Fines Fiat Chrysler $70 million for Failure to Provide Early Warning Report Data to NHTSA (Dec. 10, 2015), #16 Exhibit 15 - FCA US LLC Consent Order Response (July 26, 2015), #17 Exhibit 16 - Consent Decree filed in In re Chrysler-Dodge-Jeep EcoDiesel (N.D. Cal. Jan. 10, 2019), #18 Exhibit 17 - Email from FCA to Plaintiff Crawford (Aug. 5, 2020), #19 Exhibit 18 - Invoice from Lithia Chrysler Dodge Jeep Ram Fiat of Tri-Cities to Plaintiff Hunting (Oct. 8, 2020), #20 Exhibit 19 - Billy G. Holland, et al., Modeling Approach to Estimate EGR Cooler Thermal Fatigue Life (2015), #21 Exhibit 20 - Exhaust gas recirculation, Wikipedia, #22 Exhibit 21 - X-Engineer.org article containing photograph of an EGR cooler, #23 Exhibit 22 - Mathis Riiber, EGR Cooler - What is it and Why it Fails?, BulletProofDiesel.com (Aug. 27, 2020), #24 Exhibit 23 - Jonathan S. Reiskin, E&MU - EGR Cooling Issues Vex Fleets - Often-Overlooked Component in Exhaust Gas Recirculation Systems Can Cause Big Problem, Transport Topics (July 16, 2012), #25 Exhibit 24 - Jim Park, Stay Ahead of Trouble on EGR Engines, Truckinginfo.com (Feb. 11, 2014), #26 Exhibit 25 - Vashani, et al., Thermal and Strain Characteristics of EGR Cooler, Advanced Science and Technology Letters, Vol. 47 (Healthcare and Nursing 2014) (Apr. 2014), #27 Exhibit 26 - Bulletin, HELLA KGaA, Hueck & Co. (2015), #28 Exhibit 27 - Kun Yang, et al., Characterizing Diesel Particulate Filter Failure During Commercial Fleet Use due to Pinholes, Melting, Cracking and Fouling, 2 Emission Control Sci. & Tech. (Apr. 8, 2016), #29 Exhibit 28 - Ccarmichael05, Cracked EGR Cooler, Ram1500Diesel.com (May 31, 2016), #30 Exhibit 29 - Hershey1, Losing Coolant, CarComplaints.com (June 20, 2016), #31 Exhibit 30 - KWC, EGR Cooler leaking, EcoDieselRam.com (May 22, 2017), #32 Exhibit 31 - TzarIgor, Are you slowly loosing coolant?, Ram1500Diesel.com (June 26, 2017), #33 Exhibit 32 - Andrepatry & Dawn, Engine compartment fires, CarGurus.com, #34 Exhibit 33 - BMW Important Safety Recall (May 2019), #35 Exhibit 34 - Park Jae-hyuk, BMW fined $10 million for delayed recall, KoreaTimes.co.kr (Dec. 24, 2018), #36 Exhibit 35 - FCA US LLC Chronology, 20142019 Ram 1500 EcoDiesel Engine Compartment (Oct. 24, 2019), #37 Exhibit 36 - FCA Press Release, Statement - EGR Cooler (Oct. 25, 2019), #38 Exhibit 37 - Part 573 Safety Recall Report for Recall 19V-757 (June 11, 2020), #39 Exhibit 38 - 2014 RAM 1500 OWNER COMMENTS, CarComplaints.com, Post #187 (June 17, 2020), #40 Exhibit 39 - 2014 Ram Commercial eBrochure, #41 Exhibit 40 - 2014 RAM 1500 OWNER COMMENTS, CarComplaints.com, Post #164 (Jan. 14, 2020), #42 Exhibit 41 - Bobcope399, Engine Fire, EcoDieselRam.com, Post #119 (Dec. 24, 2019), #43 Exhibit 42 - New Safety Recall Advanced Communication (Nov. 1, 2019), #44 Exhibit 43 - Brianw0048, Redesigned EGR Cooler, Ram1500Diesel.com, Post #5 (Mar. 2020), #45 Exhibit 44 - Themidnightwill, Updated EGR Part #?, Ram1500Diesel.com, Post #2 (May 2020), #46 Exhibit 45 - Deward, Ram1500Diesel.com (Nov. 19, 2018), #47 Exhibit 46 - Declaration of Bradley Crawford re Venue), #48 Exhibit 47 - Chrysler World service record (Nov. 25, 2019)) (Berman, Steve) Modified on 1/12/2021 (LGra). |
Filing 21 Notice to Parties Regarding Consolidated Case: Order of consolidation entered on *01/05/2021*. Designated lead case number is *20-12341*. (DPer) |
Filing 20 STIPULATED ORDER consolidating cases and setting schedule for consolidated amended complaint and motion to dismiss. Signed by District Judge Stephen J. Murphy, III. (DPer) |
Filing 19 AMENDED COMPLAINT with Jury Demand filed by Derek Griesel, Bradley Crawford, Hank Vanderhulst, Leroy Mault, Greg Gouker, Nathan Felker, Jacob Lane, Brandon Bailey, Wesley Distad, Glenn Brainard, Patrick Phelan, Dennis Sullivan, Dennis Diaz, Shaun Graham, Kevin Hunting, Russell Raley, Christian Christensen, Michael O'Brien, Gary Grendahl against FCA US LLC. NEW PARTIES ADDED. (Attachments: #1 Index of Exhibits, #2 Exhibit 1 - Part 573 Safety Recall Report for Recall 19V-757 (Nov. 14, 2019), #3 Exhibit 2 - Part 573 Safety Recall Report for Recall 19V-757 (Oct. 31, 2019), #4 Exhibit 3 - Important Safety Recall Notice Letter, #5 Exhibit 4 - Important Safety Recall Notice Letter, #6 Exhibit 5 - Dealer Service Instructions for Safety Recall 19V-757 (Apr. 2020), #7 Exhibit 6 - Dealer Service Instructions for Safety Recall 19V-757 (Rev. May 2020), #8 Exhibit 7 - Part 573 Safety Recall Report for Recall 19V-757 (Apr. 2, 2020), #9 Exhibit 8 - Customer Handling for SAFETY RECALL VB1 20142019 DS 3.0L EGR Cooler (Dec. 2019), #10 Exhibit 9 - Part 573 Safety Recall Report for Recall 19V-757 (Apr. 21, 2020), #11 Exhibit 10 - Dealer Service Instructions for Safety Recall 19V-757 (Rev. May 1, 2020), #12 Exhibit 11 - Important Safety Recall notice sent to Plaintiff Hank Vanderhulst, #13 Exhibit 12 - Important Safety Recall notice sent to Plaintiff Leroy Mault, #14 Exhibit 13 - Important Safety Recall notice sent to Plaintiff Leroy Mault, #15 Exhibit 14 - NHTSA Press Release, U.S. DOT Fines Fiat Chrysler $70 million for Failure to Provide Early Warning Report Data to NHTSA (Dec. 10, 2015), #16 Exhibit 15 - FCA US LLC Consent Order Response (July 26, 2015), #17 Exhibit 16 - Consent Decree filed in In re Chrysler-Dodge-Jeep EcoDiesel Marketing, Sales Practices, and Products Liability Litigation, No. 17-md-02777 (N.D. Cal. Jan. 10, 2019), #18 Exhibit 17 - Email from FCA to Plaintiff Crawford (Aug. 5, 2020), #19 Exhibit 18 - Invoice from Lithia Chrysler Dodge Jeep Ram Fiat of Tri-Cities to Plaintiff Keith Hunting (Oct. 8, 2020), #20 Exhibit 19 - Billy G. Holland, et al., Modeling Approach to Estimate EGR Cooler Thermal Fatigue Life, 8 SAE Intl J. Engines 17241732 (2015), #21 Exhibit 20 - Exhaust gas recirculation, Wikipedia, #22 Exhibit 21 - X-Engineer.org article containing photograph of an EGR cooler, #23 Exhibit 22 - Mathis Riiber, EGR Cooler - What is it and Why it Fails?, BulletProofDiesel.com (Aug. 27, 2020), #24 Exhibit 23 - Jonathan S. Reiskin, E&MU - EGR Cooling Issues Vex Fleets - Often-Overlooked Component in Exhaust Gas Recirculation Systems Can Cause Big Problem, Transport Topics (July 16, 2012), #25 Exhibit 24 - Jim Park, Stay Ahead of Trouble on EGR Engines, Truckinginfo.com (Feb. 11, 2014), #26 Exhibit 25 - Vashani, et al., Thermal and Strain Characteristics of EGR Cooler, Advanced Science and Technology Letters, Vol. 47 (Healthcare and Nursing 2014) (Apr. 2014), #27 Exhibit 26 - Bulletin, HELLA KGaA, Hueck & Co. (2015), #28 Exhibit 27 - Kun Yang, et al., Characterizing Diesel Particulate Filter Failure During Commercial Fleet Use due to Pinholes, Melting, Cracking and Fouling, 2 Emission Control Sci. & Tech. (Apr. 8, 2016), #29 Exhibit 28 - Ccarmichael05, Cracked EGR Cooler, Ram1500Diesel.com (May 31, 2016), Post #1, #30 Exhibit 29 - Hershey1, Losing Coolant, CarComplaints.com (June 20, 2016), at Post #1, #31 Exhibit 30 - KWC, EGR Cooler leaking, EcoDieselRam.com (May 22, 2017), at Post #1, #32 Exhibit 31 - TzarIgor, Are you slowly loosing coolant?, Ram1500Diesel.com (June 26, 2017), at Post #112, #33 Exhibit 32 - Andrepatry & Dawn, Engine compartment fires, CarGurus.com, #34 Exhibit 33 - BMW Important Safety Recall (May 2019), #35 Exhibit 34 - Park Jae-hyuk, BMW fined $10 million for delayed recall, KoreaTimes.co.kr (Dec. 24, 2018), #36 Exhibit 35 - FCA US LLC Chronology, 20142019 Ram 1500 EcoDiesel Engine Compartment (Oct. 24, 2019), #37 Exhibit 36 - FCA Press Release, Statement - EGR Cooler (Oct. 25, 2019), #38 Exhibit 37 - Part 573 Safety Recall Report for Recall 19V-757 (June 11, 2020), #39 Exhibit 38 - 2014 RAM 1500 OWNER COMMENTS, CarComplaints.com, Post #187 (June 17, 2020), #40 Exhibit 39 - 2014 Ram Commercial eBrochure, #41 Exhibit 40 - 2014 RAM 1500 OWNER COMMENTS, CarComplaints.com, Post #164 (Jan. 14, 2020), #42 Exhibit 41 - Bobcope399, Engine Fire, EcoDieselRam.com, Post #119 (Dec. 24, 2019), #43 Exhibit 42 - New Safety Recall Advanced Communication (Nov. 1, 2019), #44 Exhibit 43 - Brianw0048, Redesigned EGR Cooler, Ram1500Diesel.com, Post #5 (Mar. 2020), #45 Exhibit 44 - Themidnightwill, Updated EGR Part #?, Ram1500Diesel.com, Post #2 (May 2020), #46 Exhibit 45 - Deward, Ram1500Diesel.com (Nov. 19, 2018), #47 Exhibit 46 - Declaration of Bradley Crawford re Venue) (Berman, Steve) |
Filing 18 STATEMENT of DISCLOSURE of CORPORATE AFFILIATIONS and FINANCIAL INTEREST by FCA US LLC identifying Corporate Parent FCA North America Holdings LLC, Other Affiliate Fiat Chrysler Automobiles NV, Other Affiliate FCA Holdco B.V. for FCA US LLC. (Murray, Thomas) |
Filing 17 Amended MOTION to Dismiss by All Defendants. (Attachments: #1 Index of Exhibits, #2 Exhibit A - NHTSA Recall Quarterly Report (Oct 22, 2020), #3 Exhibit B - Recall Repair Confirmation (Mault), #4 Exhibit C - Recall Repair Confirmation (Vanderhulst), #5 Exhibit D - CLRA Notice letter from Plaintiffs' Counsel, #6 Exhibit E - FCA's Response to Plaintiffs' Counsel's CLRA Notice Letter) (Murray, Thomas) |
Filing 16 MOTION to Dismiss by All Defendants. (Attachments: #1 Index of Exhibits, #2 Exhibit A - NHTSA Recall Quarterly Report (Oct 22, 2020), #3 Exhibit B - Recall Repair Confirmation (Mault), #4 Exhibit C - Recall Repair Confirmation (Vanderhulst), #5 Exhibit D - CLRA Notice letter from Plaintiffs' Counsel, #6 Exhibit E - FCA's Response to Plaintiffs' Counsel's CLRA Notice Letter) (Murray, Thomas) |
Filing 15 ATTORNEY APPEARANCE: Thomas C. White appearing on behalf of All Defendants (White, Thomas) |
Filing 14 STIPULATED ORDER to Enlarge Page Limits for FCA's Motion to Dismiss. Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 13 ORDER Denying #11 Motion to Extend Briefing Schedule. Signed by District Judge Stephen J. Murphy, III. (DPar) |
Filing 12 RESPONSE to #11 MOTION TO EXTEND Briefing Schedule Dates filed by All Plaintiffs. (Attachments: #1 Exhibit 1 - Unpublished Cases) (Miller, E.) |
Filing 11 MOTION TO EXTEND Briefing Schedule Dates by All Defendants. (Attachments: #1 Exhibit 1 - Wisconsin Complaint, #2 Exhibit 2 - Motion to Stay or Transfer in Wisconsin Case) (Murray, Thomas) |
Filing 10 NOTICE of Appearance by Dennis A. Lienhardt on behalf of All Plaintiffs. (Lienhardt, Dennis) |
Filing 9 STIPULATION AND ORDER Setting Motion to Dismiss Briefing Schedule. Set Motion Deadlines: (Motion due by 11/11/2020, Response due by 12/11/2020, Reply due by 1/7/2021.) Signed by District Judge Stephen J. Murphy, III. (AChu) |
Filing 8 ATTORNEY APPEARANCE: William B. Monahan appearing on behalf of All Defendants (Monahan, William) |
Filing 7 ATTORNEY APPEARANCE: Robert J. Giuffra, Jr appearing on behalf of All Defendants (Giuffra, Robert) |
Filing 6 ATTORNEY APPEARANCE: Thomas J. Murray appearing on behalf of All Defendants (Murray, Thomas) |
Filing 5 CERTIFICATE of Service/Summons Returned Executed. FCA US LLC served on 8/28/2020, answer due 9/18/2020. (Berman, Steve) |
Filing 4 SUMMONS Issued for *FCA US LLC* (LGra) |
Filing 3 NOTICE of Appearance by Sharon S. Almonrode on behalf of Bradley Crawford, Derek Griesel, Leroy Mault, Hank Vanderhulst. (Almonrode, Sharon) |
Filing 2 NOTICE of Appearance by E. Powell Miller on behalf of Bradley Crawford, Derek Griesel, Leroy Mault, Hank Vanderhulst. (Miller, E.) |
Filing 1 COMPLAINT filed by Leroy Mault, Bradley Crawford, Hank Vanderhulst, Derek Griesel against FCA US LLC with Jury Demand. Plaintiff requests summons issued. Receipt No: AMIEDC-8012638 - Fee: $ 400. County of 1st Plaintiff: Out of State - County Where Action Arose: Oakland - County of 1st Defendant: Oakland. [Previously dismissed case: No] [Possible companion case(s): None] (Attachments: #1 Index of Exhibits, #2 Exhibit 1 - Nov. 14, 2019 FCA Part 573 Safety Recall Report 19V-757, #3 Exhibit 2 - Oct. 31, 2019 FCA Part 573 Safety Recall Report 19V-757, #4 Exhibit 3 - Issued Interim Safety Recall Notification Letter, #5 Exhibit 4 - Issued Interim Safety Recall Notification Letter Received by Owner of 2016 Ram 1500, #6 Exhibit 5 - Dealer Service Instructions for Safety Recall VB1/NHTSA 19V-757 Diesel EGR Cooler April 2020, #7 Exhibit 6 - Dealer Service Instructions for Safety Recall VB1/NHTSA 19V-757 Diesel EGR Cooler Revised May 2020, #8 Exhibit 7 - Apr. 2, 2020 FCA Part 573 Safety Recall Report 19V-757, #9 Exhibit 8 - Dec. 2019 Manufacturer Notice to Dealers, #10 Exhibit 9 - Dec. 10, 2015 NHTSA Press Release, #11 Exhibit 10 - FCA US LLC Consent Order Response July 26, 2015, #12 Exhibit 11 - Consent Decree, #13 Exhibit 12 - Aug. 5, 2020 email to Plaintiff Bradley Crawford, #14 Exhibit 13 - FCA Recall Notice Issued to Plaintiff Hank Vanderhulst, #15 Exhibit 14 - FCA Recall Notice Issued to Plaintiff Leroy Mault, #16 Exhibit 15 - FCA Recall Notice Issued to Plaintiff Leroy Mault, #17 Exhibit 16 - Press Kit, #18 Exhibit 17 - Modeling Approach to Estimate EGR Cooler Thermal Fatigue Life, #19 Exhibit 18 - Wikipedia Exhaust Gas Recirculation, #20 Exhibit 19 - Photograph of a vehicle EGR Cooler, #21 Exhibit 20 - Feb. 11, 2014 Truckinginfo.com article entitled Stay Ahead of Trouble on EGR Engines, #22 Exhibit 21 - CARCOMPLAINTS.COM, 2014 RAM 1500 OWNER COMMENTS - Fayetteville, NC, #23 Exhibit 22 - CARCOMPLAINTS.COM, 2014 RAM 1500 OWNER COMMENTS - Lindale, TX, #24 Exhibit 23 - TechTips Bulletin Loss of coolant at the EGR cooler Opel Insignia MY 2009, #25 Exhibit 24 - Emiss. Control Sci. Technol. article, #26 Exhibit 25 - Complaint on Dodge Ram Forum Cracked EGR Cooler, #27 Exhibit 26 - Complaint on Dodge EcoDiesel Forum EGR Cooler Leaking, #28 Exhibit 27 - Complaint on Ram1500 Forum EGR Cooler Leak, #29 Exhibit 28 - BMW Important Safety Recall May 2019, #30 Exhibit 29 - FCA US LLC Chronology 2014-2019 Ram 1500 EcoDiesel Engine Compartment, #31 Exhibit 30 - Oct. 25, 2019 FCA US Media Statement, #32 Exhibit 31 - 2014 Dodge Ram Commercial e-brochure, #33 Exhibit 32 - July 16, 2013 RAM ZONE Blogpost, #34 Exhibit 33 - Feb. 14, 2013 RAM ZONE Blogpost, #35 Exhibit 34 - Dealer Service Instructions for Safety Recall VB1/NHTSA 19V-757 Diesel EGR Cooler Revision 1 May 2020, #36 Exhibit 35 - Apr. 21 2020 FCA Part 573 Safety Recall Report 19V-757, #37 Exhibit 36 - Jun. 11, 2020 FCA Part 573 Safety Recall Report 19V-757, #38 Exhibit 37 - Jun. 11, 2020 DieselNet article, #39 Exhibit 38 - Thermal and Strain Characteristics of EGR Cooler, Advanced Science and Technology Letters, #40 Exhibit 39 - CARCOMPLAINTS.COM, 2014 RAM 1500 OWNER COMMENTS, #41 Exhibit 40 - Post by andrepatre & Dawn on Cargurus.com, #42 Exhibit 41 - Dec. 24, 2018 The Korean Times article, #43 Exhibit 42 - CARCOMPLAINTS.COM, 2014 RAM 1500 OWNER COMMENTS, #44 Exhibit 43 - Feb. 20, 2018 post by CR128 on ecodieselram.com, #45 Exhibit 44 - Oct. 12, 2017 post by EcoFire on ram1500diesel.com, #46 Exhibit 45 - Oct. 26, 2014 The Detroit News article, #47 Exhibit 46 - CARCOMPLAINTS.COM, 2014 RAM 1500 OWNER COMMENTS, #48 Exhibit 47 - Dec. 24, 2019 post by Bobcope399 and Dec. 18, 2019 post by AndyIRV on EcoDieselRam.com, #49 Exhibit 48 - Nov. 19, 2018 post by Deward on ram1500diesel.com) (Berman, Steve) |
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