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

Filing 297

STIPULATION and ORDER Regarding Mediation Scheduling and Oral Argument on Motion for Decertification. Deadline for mediation: June 21, 2013, Parties to Advise Court of outcome of mediation: June 24, 2013., Oral Argument on defendants' pending motions: July 19, 2013 at 9:30 a.m. before Magistrate Judge Michael J. Seng in Courtroom 6 (MJS), Fresno Courthouse, signed by Magistrate Judge Michael J. Seng on 05/30/2013. (Yu, L)

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The Honorable Michael J. Seng

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LAW OFFICES OF WILLIAM C. HAHESY
William C. Hahesy
State Bar No. 105743
225 West Shaw Avenue, Suite 105
Fresno, CA 93704
Telephone: [phone]
Facsimile: [phone]

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Attorneys for DELANO FARMS COMPANY

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SAVITT BRUCE & WILLEY LLP
David N. Bruce
Miles A. Yanick
1425 Fourth Avenue, Suite 800
Seattle, Washington 98101
Telephone: [phone]
Facsimile: [phone]

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Attorneys for DELANO FARMS COMPANY

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Pro Hac Vice
Pro Hac Vice

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA AT FRESNO

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SABAS ARREDONDO, JOSE CUEVAS,
HILARIO GOMEZ, IRMA LANDEROS, and
ROSALBA LANDEROS individually, and on
behalf of all others similarly situated,

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Plaintiffs,

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v.

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NO.

1:09-cv-01247-MJS

STIPULATION AND ORDER
REGARDING MEDIATION
SCHEDULING AND ORAL
ARGUMENT ON MOTION FOR
DECERTIFICATION

DELANO FARMS COMPANY, a Washington
State Corporation; CAL-PACIFIC FARM
MANAGEMENT, L.P.; T&R BANGI'S
AGRICULTURAL SERVICES, INC., and
DOES 1 through 10, inclusive,

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Defendants.

I.

STIPULATION AND JOINT MOTION

The parties have diligently pursued arrangements for mediation since appearing for a
STIPULATION AN ORDER REGARDING MEDIATION
SCHEDULING AND ORAL ARGUMENT ON MOTION FOR
DECERTIFICATION - 1
No. 1:09-cv-01247

SAVITT BRUCE & WILLEY LLP
1425 Fourth Avenue Suite 800
Seattle, Washington 98101-2272
[phone]

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Status Conference with Judge Boone, and now have identified a mediator acceptable to all

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parties and have scheduled mediation with that mediator for June 21, 2013, the first date on

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which all necessary counsel, parties, and the mediator are available.
The parties note that this mediation is several weeks after the deadline for mediation

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(May 31, 2013) established by Judge Boone, and only a few days prior to the date currently set

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for oral argument of defendants’ motions to decertify and for a trial plan.

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The parties therefore respectfully request and suggest that this Court (a) extend the

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deadline for mediation to June 21, 2013, and (b) re-schedule oral argument on defendants’

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pending motions, as jointly stipulated to and requested below. The requesting scheduling

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adjustments may facilitate the non-judicial resolution of this matter and, should mediation fail,

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will allow the Court adequate time for review of the submittals on the pending motion prior to

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oral argument.
The parties to the above-captioned matter, through their respective counsel of record,

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hereby stipulate to and jointly request the following dates for mediation and for oral argument

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on the pending motions:

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June 21, 2013

Deadline for mediation

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June 24, 2013

Parties to advise Court of outcome of mediation

July 19, 2013, 9:30 am

Oral argument on defendants’ pending motions

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SO STIPULATED:

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SAVITT BRUCE & WILLEY LLP
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GRISWOLD, LASALLE, COBB, DOWD & GIN,
LLP

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/s/ David N. Bruce
David N. Bruce, Pro Hac Vice
Miles A. Yanick, Pro Hac Vice

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/s/ Michael R. Johnson
Michael R. Johnson, State Bar No. 237767

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Attorneys for Delano Farms Company
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Attorneys for Cal-Pacific Farm Management,
L.P., and T&R Bangi’s Agicultural Services,
Inc.

STIPULATION AN ORDER REGARDING MEDIATION
SCHEDULING AND ORAL ARGUMENT ON MOTION FOR
DECERTIFICATION - 2
No. 1:09-cv-01247

SAVITT BRUCE & WILLEY LLP
1425 Fourth Avenue Suite 800
Seattle, Washington 98101-2272
[phone]

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LAW OFFICES OF WILLIAM C. HAHESY

LAW OFFICES OF MARCOS CAMACHO

By

By

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/s/ William C. Hahesy
William C. Hahesy, State Bar No. 105743

Attorneys for Delano Farms Company

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II.

/s/ Mario G. Martinez
Mario G. Martinez, State Bar No. 200721

Attorneys for Plaintiffs Sabas Arredondo, et al
[PROPOSED] ORDER

Presented by:

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SAVITT BRUCE & WILLEY LLP
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By
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/s/ David N. Bruce
David N. Bruce, Pro Hac Vice
Miles A. Yanick, Pro Hac Vice

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Attorneys for Delano Farms Company

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LAW OFFICES OF WILLIAM C. HAHESY
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By

/s/ William C. Hahesy
William C. Hahesy, State Bar No. 105743

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Attorneys for Delano Farms Company
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GRISWOLD, LASALLE, COBB, DOWD & GIN, LLP
By

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/s/ Michael R. Johnson
Michael R. Johnson, State Bar No. 237767

Attorneys for Cal-Pacific Farm Management, L.P.,
and T&R Bangi’s Agicultural Services, Inc.
LAW OFFICES OF MARCOS CAMACHO

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By

/s/ Mario G. Martinez
Mario G. Martinez, State Bar No. 200721

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Attorneys for Plaintiffs Sabas Arredondo, et al
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STIPULATION AN ORDER REGARDING MEDIATION
SCHEDULING AND ORAL ARGUMENT ON MOTION FOR
DECERTIFICATION - 3
No. 1:09-cv-01247

SAVITT BRUCE & WILLEY LLP
1425 Fourth Avenue Suite 800
Seattle, Washington 98101-2272
[phone]

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ORDER

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Based on the foregoing stipulation, the Court hereby orders that the parties in

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action NO.1:09- cv-01247-MJS shall observe the following dates for mediation and for oral
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argument on the pending motions:

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June 21, 2013

Deadline for mediation

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June 24, 2013

Parties to advise Court of outcome of mediation

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July 19, 2013, 9:30 am

Oral argument on defendants’ pending motions

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IT IS SO ORDERED.

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Dated:

May 30, 2013

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE
DEAC_Signature-END:

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STIPULATION AN ORDER REGARDING MEDIATION
SCHEDULING AND ORAL ARGUMENT ON MOTION FOR
DECERTIFICATION - 4
No. 1:09-cv-01247

SAVITT BRUCE & WILLEY LLP
1425 Fourth Avenue Suite 800
Seattle, Washington 98101-2272
[phone]