Robles v. AgReserves, Inc. et al

Filing 31

STIPULATION AND ORDER for DISMISSAL with prejudice of Defendant South Valley Almond Company, LLC and The Church of Jesus Christ of Latter Day Saints, signed by District Judge Anthony W. Ishii on 10/13/2015. (Martin-Gill, S)

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Richard D. Marca, Bar #127365
[e-mail]
Jamie Wrage, Bar #188982
[e-mail]
Jeff T. Olsen, Bar #283249
[e-mail]
GRESHAM SAVAGE NOLAN & TILDEN,
A Professional Corporation
3750 University Avenue, Suite 250
Riverside, CA 92501-3335
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Defendants,
AGRESERVES, INC. dba SOUTH VALLEY FARMS,
improperly named as SOUTH VALLEY FARMS dba
SOUTH VALLEY ALMOND COMPANY, LLC.;
GEORGE CAMPO, an individual; and
JAY PAYNE, an individual; and specially
appearing for unserved parties THE CHURCH
OF JESUS CHRIST OF LATTER DAY SAINTS and
SOUTH VALLEY FARMS dba SOUTH VALLEY
ALMOND COMPANY

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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GRESHAM|SAVAGE

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ATTORNEYS AT LAW 3750
UNIVERSITY AVE. STE. 250
RIVERSIDE, CA 92501-3335
[phone]

JUAN CARLOS ROBLES, an individual;

)
)
Plaintiff,
)
)
vs.
)
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AGRESERVES, INC.,; THE CHURCH OF
)
JESUS CHRIST OF LATTER DAY SAINTS; )
SOUTH VALLEY FARMS dba SOUTH
)
VALLEY ALMOND COMPANY, LLC;
)
JORGE CAMPOS, an individual; JAY
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PAYNE, an individual; and DOES 1 through )
100, inclusive
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Defendants.
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AGRESERVES, INC.,
)
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COUNTERCLAIMANT,
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vs.
)
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JUAN CARLOS ROBLES, an individual; and )
ROES 1 through 10, inclusive,
)
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CASE NO. 1:14-CV-00540-AWI-JLT

STIPULATION AND ORDER FOR
DISMISSAL OF DEFENDANT
THE CHURCH OF JESUS CHRIST
OF LATTER DAY SAINTS AND
DEFENDANT SOUTH VALLEY
ALMOND COMPANY, LLC WITH
PREJUDICE

STIPULATION AND ORDER FOR DISMISSAL OF DEFENDANT THE CHURCH OF JESUS CHRIST
OF LATTER DAY SAINTS AND DEFENDANT SOUTH VALLEY ALMOND COMPANY, LLC WITH
PREJUDICE

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COUNTER-Defendants.

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TO THE DISTRICT COURT AND ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
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Plaintiff Juan Carlos Robles (“Plaintiff”) and Defendant AGRESERVES, INC. dba South

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Valley Farms (improperly named as South Valley Farms dba South Valley Almond Company,
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LLC), Defendant JORGE CAMPOS and Defendant JAY PAYNE (hereinafter collectively
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referred to as “Defendants”), stipulate as follows through their undersigned counsel of record:
WHEREAS, THE CHURCH OF JESUS CHRIST OF LATTER DAY SAINTS is an

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unserved party, has not appeared in this action and does not intend to appear for purposes of this
stipulation;
WHEREAS, SOUTH VALLEY FARMS dba SOUTH VALLEY ALMOND

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COMPANY, LLC is an unserved party, has not appeared in this action and does not intend to
appear for purposes of this stipulation, and does not exist as an entity;
WHEREAS, the Pleading Amendment Deadline has passed, per the Scheduling Order
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issued on August 1, 2014 in this case, the deadline was October 1, 2014;
THEREFORE, in light of the foregoing, Plaintiff and Defendants stipulate as follows:
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1.

Plaintiff and Defendants consent to the Dismissal of THE CHURCH OF JESUS

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CHRIST OF LATTER DAY SAINTS, from the above captioned matter, with prejudice.
2.
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Plaintiff and Defendants consent to the Dismissal of SOUTH VALLEY FARMS

dba SOUTH VALLEY ALMOND COMPANY, LLC from the above captioned matter, with
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prejudice.
3.

Plaintiff and THE CHURCH OF JESUS CHRIST OF LATTER DAY SAINTS,

hereby agree that each party shall bear its own attorneys’ fees and costs in this matter.

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4.

Plaintiff and SOUTH VALLEY FARMS dba SOUTH VALLEY ALMOND

COMPANY, LLC hereby agree that each party shall bear its own attorneys’ fees and costs in this
matter.

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GRESHAM|SAVAGE

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ATTORNEYS AT LAW 3750
UNIVERSITY AVE. STE. 250
RIVERSIDE, CA 92501-3335
[phone]

///
IT IS SO STIPULATED.
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STIPULATION AND ORDER FOR DISMISSAL OF DEFENDANT THE CHURCH OF JESUS CHRIST
OF LATTER DAY SAINTS AND DEFENDANT SOUTH VALLEY ALMOND COMPANY, LLC WITH
PREJUDICE

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Dated: October 12, 2015

EMPLOYMENT LAWYERS GROUP

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By:
/s/ Ann Guleser
Karl Gerber
Ann Guleser
Attorneys for Plaintiff
JUAN CARLOS ROBLES

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Dated: October 12, 2015

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GRESHAM SAVAGE NOLAN & TILDEN,
A Professional Corporation
By: :
/s/ Jeff T. Olsen
Richard D. Marca
Jamie Wrage
Jeff T. Olsen
Attorneys for Defendants,
AGRESERVES, INC. dba SOUTH
VALLEY FARMS, GEORGE CAMPO,
and JAY PAYNE, and specially
appearing for unserved parties THE
CHURCH OF JESUS CHRIST OF
LATTER DAY SAINTS and SOUTH
VALLEY FARMS dba SOUTH VALLEY
ALMOND COMPANY

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ORDER

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IT IS SO ORDERED.
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Dated:

October 13, 2015
SENIOR DISTRICT JUDGE

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GRESHAM|SAVAGE

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ATTORNEYS AT LAW 3750
UNIVERSITY AVE. STE. 250
RIVERSIDE, CA 92501-3335
[phone]

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STIPULATION AND ORDER FOR DISMISSAL OF DEFENDANT THE CHURCH OF JESUS CHRIST
OF LATTER DAY SAINTS AND DEFENDANT SOUTH VALLEY ALMOND COMPANY, LLC WITH
PREJUDICE