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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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`THIS DOCUMENT RELATES TO:
`ALL END-PAYOR ACTIONS
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`Master File No. 12-md-02311
`Honorable Sean F. Cox
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`STIPULATION AND ORDER REGARDING BRIEFING SCHEDULE FOR
`FURTHER BRIEFING ON PENDING MOTION TO ENFORCE
`SETTLEMENT AGREEMENTS
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`WHEREAS, on September 15, 2021, the attorneys representing Element Fleet
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`Corporation; Wheels, Inc.; Donlen LLC, and Automotive Rentals, Inc. filed a
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`Motion to Enforce Settlement Agreements (Dkt. No. 2149);
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`WHEREAS, on September 27, 2021, End-Payor Plaintiffs (“EPPs”), by and
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`through their Court-appointed counsel (“class counsel”), filed an unopposed motion
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`to extend the deadline to file their objection to the Motion to Enforce Settlement
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`Agreements until October 13, 2021 (Dkt. No. 2150);
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`WHEREAS, the Court granted EPPs an extension of time to file a response to
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`the Motion to Enforce Settlement Agreements on September 29, 2021 (Dkt. 2152);
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`Case 2:12-md-02311-SFC-RSW ECF No. 2154, PageID.39594 Filed 10/13/21 Page 2 of 4
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`WHEREAS, pursuant to that Order, EPPs’ response to the Motion to Enforce
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`Settlement Agreements is currently due on October 13, 2021;
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`WHEREAS, counsel for EPPs and for Element Fleet Corporation; Wheels,
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`Inc.; Donlen LLC, and Automotive Rentals, Inc have continued to confer about
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`potential resolution of the dispute;
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`WHEREAS, more time is needed to complete those discussions.
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`IT IS THEREFORE STIPULATED AND AGREED by counsel for Element
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`Fleet Corporation; Wheels, Inc.; Donlen LLC, and Automotive Rentals, Inc. and by
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`class counsel that:
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`1. EPPs’ Response to the Motion to Enforce Settlement Agreements shall be
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`extended three weeks until November 3, 2021.
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`2. Any Reply to the Motion to Enforce Settlement Agreements shall be due
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`on November 17, 2021.
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`IT IS SO ORDERED.
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`Dated: October 13, 2021
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`s/Sean F. Cox
`Sean F. Cox
`U. S. District Judge
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`Case 2:12-md-02311-SFC-RSW ECF No. 2154, PageID.39595 Filed 10/13/21 Page 3 of 4
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`STIPULATED AND AGREED.
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`BALCH & BINGHAM LLP
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`/s/ L. Conrad Anderson IV
`Gregory C. Cook
`L. Conrad Anderson IV
`1901 6th Avenue North
`Suite 1500
`Birmingham, AL 35203
`Telephone: (205) 251-8100
`gcook@balch.com
`canderson@balch.com
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`Tyler P. Bishop
`BALCH & BINGHAM LLP
`30 Ivan Allen, Jr. Blvd., NW
`Suite 700
`Atlanta, Georgia 30308
`Telephone: (404) 962-3521
`tbishop@balch.com
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`Attorneys for Element Fleet
`Corporation, Wheels, Inc.,
`Donlen LLC, and Automotive
`Rentals, Inc.
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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
`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
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`Case 2:12-md-02311-SFC-RSW ECF No. 2154, PageID.39596 Filed 10/13/21 Page 4 of 4
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`Burlingame, California 94010
`Telephone: (650) 697-6000
`azapala@cpmlegal.com
`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
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