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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
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`IN RE AUTOMOTIVE PARTS
`ANTITRUST LITIGATION
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`Master File No. 12-md-02311
`Honorable Sean F. Cox
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`THIS DOCUMENT RELATES TO:
`ALL END-PAYOR ACTIONS
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`END-PAYOR PLAINTIFFS’ UNOPPOSED MOTION FOR EXTENSION
`OF TIME TO RESPOND TO CLASS ACTION CAPITAL’S MOTION TO
`ENFORCE SETTLEMENT AGREEMENTS
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`End-Payor Plaintiffs (“EPPs”), by and through their Court-appointed counsel
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`(“class counsel”), respectfully submit this unopposed motion for an extension of
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`time to respond to Element Fleet Corporation, Wells, Inc., Donlen LLC, and
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`Automotive Rentals, Inc.’s Motion to Enforce Settlement Agreements. ECF No.
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`2149. Pursuant to the Federal Rules of Civil Procedure and the Local Rules of the
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`Eastern District of Michigan, the deadline to respond to this motion is September 29,
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`2021. EPPs respectfully request this extension to properly address the issues raised
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`by Class Action Capital and its clients. Movants do not oppose EPP’s request for an
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`extension.
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`Case 2:12-md-02311-SFC-RSW ECF No. 2150, PageID.39579 Filed 09/27/21 Page 2 of 5
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`EPPs respectfully request that the Court enter an Order—attached hereto as
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`Exhibit 1 and submitted separately via ECF utility—permitting EPPs to file an
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`opposition brief on or before October 13, 2021. EPPs seek this extension due to work
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`and personal obligations. Extending the Response deadline will allow EPPs to
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`adequately address movant’s arguments.
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`Granting the relief sought by EPPs is well within the discretion of this Court.
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`See e.g. Slaven v. Spirit Airlines, Inc., 2009 U.S. Dist. LEXIS 99712, *7-8 (E.D.
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`Mich. Oct. 27, 2009) (finding a schedule may be modified for good cause, a standard
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`met when the moving party has diligently attempted to meet the current deadline and
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`no prejudice to the opposing party will result) (citing Leary v. Daeschner, 349 F.3d
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`888, 906 (6th Cir. 2003)); see also JAT, Inc. v. Nat’l City Bank, 2007 U.S. Dist.
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`LEXIS 82907, *7-8 (E.D. Mich. Nov. 8, 2007).
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`CONCLUSION
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`For the reasons stated above, EPPs respectfully request that this Court enter
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`an Order permitting them to file a Response to Element Fleet Corporation, Wells,
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`Inc., Donlen LLC, and Automotive Rentals, Inc.’s Motion to Enforce Settlement
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`Agreements on or before October 13, 2021.
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`Case 2:12-md-02311-SFC-RSW ECF No. 2150, PageID.39580 Filed 09/27/21 Page 3 of 5
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`Dated: September 27, 2021
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`Respectfully submitted,
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`SUSMAN GODFREY L.L.P.
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`/s/ Jenna G. Farleigh
`Marc M. Seltzer
`Steven G. Sklaver
`1900 Avenue of the Stars, Suite 1400
`Los Angeles, California 90067-6029
`Telephone: (310) 789-3100
`mseltzer@susmangodfrey.com
`ssklaver@susmangodfrey.com
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`Terrell W. Oxford
`Chanler A. Langham
`SUSMAN GODFREY LLP
`1000 Louisiana Street, 5100
`Houston, Texas 77002
`Telephone: (713) 651-9366
`toxford@susmangodfrey.com
`clangham@susmangodfrey.com
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`Floyd G. Short
`Jenna G. Farleigh
`SUSMAN GODFREY LLP
`1201 Third Avenue, Suite 3800
`Seattle, Washington 98101
`Telephone: (206) 516-3880
`fshort@susmangodfrey.com
`jfarleigh@susmangodfrey.com
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`Adam J. Zapala
`Elizabeth Castillo
`COTCHETT, PITRE &
`McCARTHY, LLP
`San Francisco Airport Office Center
`840 Malcolm Road, Suite 200
`Burlingame, California 94010
`Telephone: (650) 697-6000
`azapala@cpmlegal.com
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`Case 2:12-md-02311-SFC-RSW ECF No. 2150, PageID.39581 Filed 09/27/21 Page 4 of 5
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`ecastillo@cpmlegal.com
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`William V. Reiss
`ROBINS KAPLAN LLP
`399 Park Avenue, Suite 3600
`New York, New York 10022
`Telephone: (212) 980-7400
`wreiss@ robinskaplan.com
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`Attorneys for End-Payor Plaintiffs-
`Appellees
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`Case 2:12-md-02311-SFC-RSW ECF No. 2150, PageID.39582 Filed 09/27/21 Page 5 of 5
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`CERTIFICATE OF SERVICE
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`I hereby certify that on September 27, 2021, I electronically filed the
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`foregoing paper with the Clerk of the court using the ECF system which will send
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`notification of such filing to all counsel of record registered for electronic filing.
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`Dated: September 27, 2021
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`/s/ Jenna G. Farleigh
`Jenna G. Farleigh
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`Attorney for End-Payor Plaintiffs
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