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

Filing 455

STIPULATION and ORDER regarding Modification of Scheduling Order: Status/Scheduling Conference set for 10/12/2016 at 04:00 PM in Courtroom 6 (MJS) before Magistrate Judge Michael J. Seng. signed by Magistrate Judge Michael J. Seng on 9/12/2016. (Kusamura, W)

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David N. Bruce, Pro Hac Vice
James P. Savitt, Pro Hac Vice
Miles A. Yanick, Pro Hac Vice
Sarah Gohmann Bigelow, Pro Hac Vice
SAVITT BRUCE & WILLEY LLP
1425 Fourth Avenue, Suite 800
Seattle, Washington 98101
Telephone: [phone]

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

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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 MODIFICATION OF
SCHEDULING ORDER

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.
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Having met and conferred, the Parties hereby submit that good cause exists to modify
the schedule contained in the Court’s Minute Order (Doc. 453), as required by Federal Rule of
Civil Procedure 16(b)(4). On August 24, 2016, the Parties mediated, have reached a tentative
settlement, and are now in the process of preparing a stipulation of settlement that the Parties
STIPULATION AND ORDER RE MODIFICATION OF
SCHEDULING ORDER - 1
No. 1:09-cv-01247-MJS

S AVITT BRUCE & W ILLEY LLP
1425 Fourth Avenue Suite 800
Seattle, Washington 98101-2272
[phone]

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anticipate will become the basis first for a motion for preliminary approval of the settlement
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and ultimately for its final approval.
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The Parties hereby stipulate as follows:
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1.

Plaintiffs’ deadline to file a modified trial plan and proposed schedule of further

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proceedings on September 12, 2016, should be vacated. All subsequent dates set forth in the
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schedule contained in the Court’s Minute Order (Doc. 453), should also be vacated.
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2.

Subject to the Court’s approval, the Parties will instead report to the Court on

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their progress in a telephonic status conference, to take place within 15 days of entry of this
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order.
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SO STIPULATED:
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SAVITT BRUCE & WILLEY LLP

M CCORMICK BARSTOW LLP

By /s/ David N. Bruce (as authorized on
9/9/2016)
David N. Bruce, Pro Hac Vice
Miles A. Yanick, Pro Hac Vice

By /s/ D. Greg Durbin (as authorized on
9/8/2016)
D. Greg Durbin, State Bar No. 81749
Laura A. Wolfe, State Bar No. 266751

Attorneys for Delano Farms Company

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

LAW OFFICES OF WILLIAM C. HAHESY

M ARTINEZ AGUILASOCHO & LYNCH

By /s/ William C. Hahesy (as authorized
On 9/9/2016)
William C. Hahesy, State Bar No. 105743

By /s/ Mario Martinez (as authorized on
9/9/2016)
Mario Martinez, State Bar No. 200721
Thomas Patrick Lynch, State Bar No.159277

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Attorney for Delano Farms Company
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Attorneys for Plaintiffs

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STIPULATION AND ORDER RE MODIFICATION OF
SCHEDULING ORDER - 2
No. 1:09-cv-01247-MJS

S AVITT BRUCE & W ILLEY LLP
1425 Fourth Avenue Suite 800
Seattle, Washington 98101-2272
[phone]

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ORDER
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Having considered the proposed Stipulation and Order Re: Modification of
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Scheduling Order in Case No. 1:09-cv-01247-MJS and good cause appearing, the
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Court Orders as follows:
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1. Plaintiffs’ September 12, 2016, deadline to file a modified trial plan and
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proposed schedule of further proceedings and all subsequent dates set forth in
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the Court’s Minute Order (Doc. 453) are vacated.
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2. A telephonic Status/Scheduling Conference shall be held at 4:00 P.M. October
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12, 2016. (The parties shall participate by dialing 888.204.5984 and entering
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access code 4446176.)
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3. Forty eight hours before the October 12, 2016, Status/Scheduling Conference,
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the parties shall submit a collective status report confirming that all terms of
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settlement of this case have been agreed to by all parties and reduced to a
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writing signed by all (or, if not so agreed and signed, an explanation as to why
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not and a proposed deadline for same) and an agreed schedule for all further
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proceedings in the case.
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4. The parties are commended for negotiating a resolution of this old and complex
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case.
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IT IS SO ORDERED.

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Dated:

September 12, 2016

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE
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STIPULATION AND ORDER RE MODIFICATION OF
SCHEDULING ORDER - 3
No. 1:09-cv-01247-MJS

S AVITT BRUCE & W ILLEY LLP
1425 Fourth Avenue Suite 800
Seattle, Washington 98101-2272
[phone]