Doe I, et al. v. Pure Forest, LLC, et al.

Filing 16

STIPULATION and ORDER signed by Judge Lawrence K. Karlton on 6/25/14 re 15 ORDERING a STAY of this action pending criminal investigation. (Meuleman, A)

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SEAN P. GATES (CA SBN 186247)
[e-mail]
MORRISON & FOERSTER LLP
707 Wilshire Boulevard
Los Angeles, California 90017-3543
Telephone: [phone]

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Attorney for Plaintiffs
John Doe I, John Doe II, John Doe III, John Doe IV, and John
Doe V

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ERICK C. TURNER (CA SBN 236186)
[e-mail]
TURNER LAW GROUP
7311 Greenhaven Drive, Suite 110
Sacramento, California 95831
Telephone: [phone]
Email: [e-mail]

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Attorney for Defendants
PURE FOREST, LLC, JEFF WADSWORTH, and
OWEN WADSWORTH

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JOHN DOE I, JOHN DOE II, JOHN DOE III,
JOHN DOE IV, AND JOHN DOE V,

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Plaintiffs,
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v.

Case No. 2:14-cv-00879-LKK-CMK
JOINT STIPULATION AND
ORDER RE STAY OF ACTION
PENDING CRIMINAL
INVESTIGATION

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PURE FOREST, LLC, JEFF WADSWORTH,
OWEN WADSWORTH,
Defendants.

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JT. STIP. AND [PROPOSED] ORDER RE STAY

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Plaintiffs John Doe I, John Doe II, John Doe III, John Doe IV, and John Doe V

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(collectively, “Plaintiffs”) filed the complaint in this action on April 8, 2014. The complaint

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alleges a number of causes of action based on alleged labor trafficking. On May 20, 2014, agents

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of the U.S. Department of Homeland Security, Homeland Security Investigations obtained a

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search warrant for a property and two vehicles owned by Defendants. The affidavit supporting

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the application for the search warrant states that the U.S. Department of Homeland Security and

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the U.S. Department of Labor are conducting a criminal investigation based on allegations similar

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to those alleged in Plaintiffs’ complaint. The search warrant has been executed and many of

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Defendants’ records have been seized. Although the criminal investigation is pending,

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Defendants have not been indicted.

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Given the pending criminal investigation, and pursuant to the Court’s order following the

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June 16, 2014 status conference, Plaintiffs and Defendants hereby stipulate to stay this action for

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120 days from the entry an order staying the case. Defendants, however, shall respond to the

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complaint and file any third-party complaint within 30 days of the entry of any such order.

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Dated: June 24, 2014
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SEAN P. GATES
MORRISON & FOERSTER LLP

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By: /s/ Sean P. Gates
SEAN P. GATES
Attorney for Plaintiffs
John Doe I, John Doe II, John Doe III, John Doe
IV, and John Doe V

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JT. STIP. AND [PROPOSED] ORDER RE STAY

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Dated: June 24, 2014

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ERICK C. TURNER
TURNER LAW GROUP

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By: /s/ Erick C. Turner (as authorized June 24, 2014)
ERICK C. TURNER

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Attorney for Defendants
PURE FOREST, LLC, JEFF WADSWORTH,
and OWEN WADSWORTH

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IT IS SO ORDERED:

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DATED: June 25, 2014.

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JT. STIP. AND [PROPOSED] ORDER RE STAY