Cuevas, et al v. Dias & Fragoso, Inc.

Filing 32

STIPULATION and ORDER to File First Amended Complaint: that Plaintiffs shall file a First Amended Complaint, attached to the parties stipulation (Doc. 31), by July 31, 2018 and that Defendants DIAS & FRAGOSO, INC., D & F AGRICULTURAL ENTERPRISES, INC., GABRIEL M. DIAS, and JOHN L. FRAGOSO, shall have thirty days thereafter to answer or otherwise respond to the First Amended Complaint filed in this matter. signed by Magistrate Judge Barbara A. McAuliffe on 7/24/2018. (Herman, H)

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John E. Hill, State Bar #45338
[e-mail]
Enrique Martínez, State Bar #206884
[e-mail]
LAW OFFICES OF JOHN E. HILL
333 Hegenberger Road, Ste. 500
Oakland, CA 94621
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs & Putative Class

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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ROSALIE CUEVAS, ADOLFO GOMEZMORENO, REYNALDO TOLANO, and
AGUSTIN AMBRIZ, on behalf of themselves
and all others similarly situated,

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Plaintiffs,

Case No.: 1:17-cv-00357-LJO-BAM
CLASS AND COLLECTIVE ACTION
STIPULATION AND ORDER TO FILE
FIRST AMENDED COMPLAINT

vs.

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DIAS & FRAGOSO, INC., a California
Corporation; D & F AGRICULTURAL
ENTERPRISES, INC., a California
Corporation; GABRIEL M. DIAS; and JOHN
L. FRAGOSO,
Defendants.

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IT IS HEREBY STIPULATED by the parties who have appeared in this action, Plaintiffs
ROSALIE CUEVAS, ADOLFO GOMEZ-MORENO, REYNALDO TOLANO, and AGUSTIN
AMBRIZ, and Defendants DIAS & FRAGOSO, INC., D & F AGRICULTURAL ENTERPRISES,
INC., GABRIEL M. DIAS, and JOHN L. FRAGOSO by and through their respective attorneys of
record, that Plaintiffs may file a First Amended Complaint, a copy of which is attached hereto as
Exhibit “A.”
IT IS FURTHER STIPULATED that
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Plaintiffs will file the First Amended Complaint within seven (7) calendar days of

the Court’s Order permitting such filing;

STIPULATION AND ORDER TO FILE FIRST AMENDED COMPLAINT

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2.

Undersigned counsel for Defendants DIAS & FRAGOSO, INC., D & F

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AGRICULTURAL ENTERPRISES, INC., GABRIEL M. DIAS, and JOHN L. FRAGOSO is

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authorized to and will accept service of the FIRST AMENDED COMPLAINT on behalf of

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GABRIEL M. DIAS, in his individual capacity and as a partner in DIAS & FRAGOSO, INC., and

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D & F AGRICULTURAL ENTERPRISES, INC., and JOHN L. FRAGOSO, in his individual

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capacity and as a partner in DIAS & FRAGOSO, INC., and D & F AGRICULTURAL

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ENTERPRISES, INC.; and

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3.

Defendants’ response to the First Amended Complaint will be filed within thirty

(30) days after the First Amended Complaint is filed.
IT IS SO STIPULATED.

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ORDER

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IT IS HEREBY ORDERED, pursuant to the Stipulation of the parties, that Plaintiffs

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ROSALIE CUEVAS, ADOLFO GOMEZ-MORENO, REYNALDO TOLANO, and AGUSTIN

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AMBRIZ shall file a First Amended Complaint, attached to the parties stipulation (Doc. 31), by

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July 31, 2018 and that Defendants DIAS & FRAGOSO, INC., D & F AGRICULTURAL

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ENTERPRISES, INC., GABRIEL M. DIAS, and JOHN L. FRAGOSO, shall have thirty days

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thereafter to answer or otherwise respond to the First Amended Complaint filed in this matter.

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IT IS SO ORDERED.
Dated:

/s/ Barbara

July 24, 2018

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND ORDER TO FILE FIRST AMENDED COMPLAINT