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

Filing 482

STIPULATION and ORDER GRANTING Leave to File Amended Complaint, signed by Magistrate Judge Michael J. Seng on 2/14/2017. (Lafata, M)

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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,

NO.

1:09-cv-01247-MJS

STIPULATION AND ORDER
GRANTING LEAVE TO FILE
AMENDED COMPLAINT

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v.
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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,
Defendants.

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The Parties, by and through their respective counsel of record and pursuant to Fed. R.
Civ. P. 15(a)(2), hereby stipulate as follows:
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That Plaintiffs shall file the Amended Arredondo Complaint, attached to this

stipulation as Exhibit A, concurrently with the filing of this stipulation.
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This stipulation is being provided solely for the purpose of effectuating the

Parties’ Settlement Agreement.
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In the event the Settlement is terminated or fails to become effective for any

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reason, the Parties to the Settlement will be deemed to have reverted to their respective

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litigation positions as of August 24, 2016. In that event, this stipulation will have no effect, the
STIPULATION AND ORDER GRANTING LEAVE
TO FILE AMENDED COMPLAINT - 1
No. 1:09-cv-01247-MJS

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Amended Arredondo Complaint shall be withdrawn and stricken, and the Arredondo Complaint

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filed on July 17, 2009 (ECF No. 2) will remain the operative complaint.

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4.

No pleadings or motions shall be filed in response to the Amended Arredondo

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Complaint, as it is being filed solely for the purposes of effectuating the Parties’ Settlement

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Agreement.

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SO STIPULATED:

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SAVITT BRUCE & WILLEY LLP

MCCORMICK BARSTOW LLP

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By /s/ David N. Bruce (as authorized on
11/18/2016)
David N. Bruce, Pro Hac Vice
Miles A. Yanick, Pro Hac Vice

By /s/ D. Greg Durbin (as authorized on
11/18/2016)
D. Greg Durbin, State Bar No. 81749
Laura A. Wolfe, State Bar No. 266751

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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

MARTINEZ AGUILASOCHO & LYNCH

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By /s/ William C. Hahesy (as authorized on
11/18/2016)
William C. Hahesy, State Bar No. 105743

By /s/ Mario Martinez (as authorized on
11/18/2016)
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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ORDER

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Good cause appearing, the above Stipulation is accepted and adopted as the
Order of this Court.

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IT IS SO ORDERED.
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Dated:

February 14, 2017

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND ORDER GRANTING LEAVE
TO FILE AMENDED COMPLAINT - 2
No. 1:09-cv-01247-MJS

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STIPULATION AND ORDER GRANTING LEAVE
TO FILE AMENDED COMPLAINT - 3
No. 1:09-cv-01247-MJS

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STIPULATION AND ORDER GRANTING LEAVE
TO FILE AMENDED COMPLAINT - 4
No. 1:09-cv-01247-MJS