Arredondo, et al. vs. Delano Farms Company, et al.

Filing 285

STIPULATION and ORDER GRANTING the parties' request for an extension of time to file opposition to the Motions to Decertify the Class and the Motion for an Order Requiring Plaintiffs to Submit a Trial Plan. Plaintiffs' opposition is due by 4/29/2013 with any replies thereto to be filed by 5/13/2013. Order signed by Magistrate Judge Michael J. Seng on 4/22/2013. (Rooney, M)

1
GREGORY J. RAMIREZ (SBN 150515)
2 JAMES E. PERERO (SBN 258124)
MYERS, WIDDERS, GIBSON & JONES, LLP
3 5425 Everglades Street
Ventura, California 93003
4 Telephone: [phone]
Facsimile: [phone]
5
MARCOS CAMACHO (SBN 123501)
6 MARIO MARTINEZ (SBN 200721)
THOMAS PATRICK LYNCH (SBN 159277)
7 LAW OFFICES OF MARCOS CAMACHO
1227 California Avenue
8 Bakersfield, CA 93304
Telephone [phone]
9 Facsimile [phone]
10 Attorneys for Plaintiffs, SABAS ARREDONDO,
et al.
11
12

UNITED STATES DISTRICT COURT

13

EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION

14
15 SABAS ARREDONDO, JOSE CUEVAS,
HILARIO GOMEZ, IRMA LANDEROS, and
16 ROSALBA LANDEROS individually
and on behalf of all others similarly situated,
17
Plaintiffs,
18
vs.
19
DELANO FARMS COMPANY, a
20 Washington State Corporation; CAL-PACIFIC
FARM MANAGEMENT, L.P.; T&R
21 BANGI'S AGRICULTURAL SERVICES,
INC. and DOES 1 through 10, inclusive,
22
Defendants.
23

CASE NO. 1:09-CV-01247-MJS
STIPULATION TO EXTEND TIME TO
FILE PLAINTIFFS' OPPOSITIONS TO
MOTIONS TO DECERTIFY THE CLASS
FILED BY DELANO FARMS COMPANY
AND T & R BANGI AG SERVICES/CALPACIFIC FARM MANAGEMENT AND
TO EXTEND TIME TO FILE
PLAINTIFFS' OPPOSITION TO
DEFENDANT DELANO FARMS
COMPANY’S MOTION FOR ORDER
REQUIRING PLAINTIFFS TO SUBMIT
TRIAL PLAN; STIPULATION TO
EXTEND TIME FOR DEFENDANTS'
REPLIES TO OPPOSITIONS

24
25

This Stipulation is entered into between SABAS ARREDONDO, JOSE CUEVAS,

26 HILARIO GOMEZ, IRMA LANDEROS and ROSALBA LANDEROS individually and on behalf
27 of the certified class ("Plaintiffs"), and Defendants DELANO FARMS COMPANY, CAL28 PACIFIC FARM MANAGEMENT, L.P., and T&R BANGI'S AGRICULTURAL SERVICES,
1

1:09-CV-01247-LJO-DLB

1 INC. (collectively the "Parties"), by and through their respective counsel of record herein.
WHEREAS, Plaintiffs’ oppositions to Motions To Decertify The Class filed by Delano

2

3 Farms Company and T & R Bangi AG Services/Cal-Pacific Farm Management currently has a
4 deadline for filing of April 22, 2013;
WHEREAS, Plaintiffs’ opposition to Defendant Delano Farms Company’s Motion For

5

6 Order Requiring Plaintiffs to Submit Trial Plan currently has a deadline for filing of April 22,
7 2013;
8

WHEREAS, the Parties hereby stipulate to extend the time to file oppositions to

9 Defendants’ three motions by one week;
10

WHEREAS, the Reason for stipulation is to permit Plaintiffs counsel additional time based

11 on the voluminous nature of the three separate motions filed by two defendants, and covering
12
13

thousands of pages of documents;
WHEREAS, the Parties further agree that in their Opposition to Delano Farms Company’s

14
15
16

Motion For Order Requiring Plaintiffs to Submit Trial Plan, Plaintiffs will not take the position
that the Motion is not properly before the Court, but Plaintiffs will retain their full rights to

17 otherwise oppose the motion;
18

WHEREAS, the Parties further stipulate that any replies to Plaintiffs' Oppositions by

19 Defendants' Delano Farms Company and T & R Bangi AG Services/Cal-Pacific Farm
20

Management will also be extended by one week;

21
NOW THEREFORE, it is hereby stipulated and agreed by and between the Parties to this
22
action, through their respective undersigned counsel of record, that the time for Plaintiffs to file
23
Oppositions to Motions To Decertify The Class filed by Delano Farms Company and T & R Bangi
24
AG Services/Cal-Pacific Farm Management is extended to April 29, 2013, and the time to file an
25

opposition to Defendant Delano Farms Company’s Motion For Order Requiring Plaintiffs to

26
Submit Trial Plan is extended to April 29, 2013. The parties further stipulate and agree that the
27
time for Defendants to file their reply to Plaintiffs' Oppositions shall be extended by one week,
28
2

1:09-CV-01247-LJO-DLB

1 with a new reply date of May 13, 2013.
2
3 DATED: April 19, 2013

LAW OFFICE OF MARCOS CAMACHO

4
By: Mario Martinez
MARIO MARTINEZ, ESQ.
Attorneys for Plaintiffs, SABAS ARREDONDO, et al.

5
6
7
8 DATED: April 19, 2013

SAVITT BRUCE & WILLEY LLP

9
By: David N. Bruce
DAVID N. BRUCE, ESQ.
Attorneys for DELANO FARMS COMPANY

10
11
12
13

DATED: April 19, 2013

GRISWOLD, LASALLE, COBB, DOWD & GIN,
LLP

14
15
16
17

By: Michael R. Johnson
MICHAEL R. JOHNSON, ESQ.
Attorneys for CAL-PACIFIC FARM
MANAGEMENT, L.P.; and T&R BANGI'S
AGRICULTURAL SERVICES, INC.

18
19
20
21
22
23
24
25
26
27
28
3

1:09-CV-01247-LJO-DLB

1 GREGORY J. RAMIREZ (SBN 150515)
JAMES E. PERERO (SBN 258124)
2 MYERS, WIDDERS, GIBSON & JONES, LLP
5425 Everglades Street
3 Ventura, California 93003
Telephone: [phone]
4 Facsimile: [phone]
5 MARCOS CAMACHO (SBN 123501)
MARIO MARTINEZ (SBN 200721)
6 THOMAS PATRICK LYNCH (SBN 159277)
LAW OFFICES OF MARCOS CAMACHO
7 1227 California Avenue
Bakersfield, CA 93304
8 Telephone [phone]
Facsimile [phone]
9
Attorneys for Plaintiffs, SABAS ARREDONDO,
10 et al.
11

UNITED STATES DISTRICT COURT

12

EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION

13 SABAS ARREDONDO, JOSE CUEVAS,
HILARIO GOMEZ, IRMA LANDEROS, and
14 ROSALBA LANDEROS individually
and on behalf of all others similarly situated,
15
Plaintiffs,
16

CASE NO. 1:09-CV-01247-MJS
ORDER ON STIPULATION TO EXTEND
TIME TO FILE PLAINTIFFS'
OPPOSITIONS TO MOTIONS TO
DECERTIFY THE CLASS FILED BY
DELANO FARMS COMPANY AND T & R
BANGI AG SERVICES/CAL-PACIFIC
FARM MANAGEMENT AND
TO EXTEND TIME TO FILE
PLAINTIFFS' OPPOSITION TO
DEFENDANT DELANO FARMS
COMPANY’S MOTION FOR ORDER
REQUIRING PLAINTIFFS TO SUBMIT
TRIAL PLAN; STIPULATION TO
EXTEND TIME FOR DEFENDANTS'
REPLIES TO OPPOSITIONS

vs.

17 DELANO FARMS COMPANY, a
Washington State Corporation; CAL-PACIFIC
18 FARM MANAGEMENT, L.P.; T&R
BANGI'S AGRICULTURAL SERVICES,
19 INC. and DOES 1 through 10, inclusive,
Defendants.
20
21
22
23
24
25
26
27
28
1

1:09-CV-01247-LJO-DLB

IT IS SO ORDERED. Plaintiffs' deadline in which to file Oppositions to Motions to

1

2 Decertify the Class filed by Delano Farms Company and T & R Bangi AG Services/Cal-Pacific
3 Farm Management and Motion for Order Requiring Plaintiffs to Submit Trial Plan is now April
4 29, 2013. Defendants' deadline in which to file a reply to Plaintiffs' Oppositions is now May 13,
5 2013.
6
7
8 IT IS SO ORDERED.
9
Dated:

10

April 22, 2013

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE
DEAC_Signature-END:

11
12

92b0h

13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2

1:09-CV-01247-LJO-DLB