Case: Zavala Martinez v. Manzana, LLC

Francisco Javier Zavala Martinez v. Manzana, LLC

COMPLAINT against All Defendants ( Filing fee $405 receipt number ACTDC-7987190.), filed by Carlos Giovanni Perez Castro, Rene Meza Quirino, Francisco Javier Zavala Martinez, Luis Adrian Perez Garcia, Victor Hugo Maximo Diaz.(Ahmad, Muneer) (Entered: 12/02/2024)

Notice: Pursuant to Federal Rule of Civil Procedure 7.1, a disclosure statement must be filed with a party's first appearance, pleading, petition, motion, response, or other request addressed to the Court and must be supplemented if any required information changes during the case. Signed by Clerk on 12/2/24.(Hushin, Z.) (Entered: 12/03/2024)

Order on Pretrial Deadlines: Amended Pleadings due by 1/31/2025 Discovery due by 6/3/2025 Dispositive Motions due by 7/8/2025 Signed by Clerk on 12/2/2024.(Freberg, B) (Entered: 12/03/2024)

ELECTRONIC FILING ORDER FOR COUNSEL - PLEASE ENSURE COMPLIANCE WITH COURTESY COPY REQUIREMENTS IN THIS ORDER Signed by Judge Victor A. Bolden on 12/2/2024.(Freberg, B) (Entered: 12/03/2024)

Standing Protective Order Signed by Judge Victor A. Bolden on 12/2/2024.(Freberg, B) (Entered: 12/03/2024)

Notice of Option to Consent to Magistrate Judge Jurisdiction.(Freberg, B) (Entered: 12/03/2024)

Standing Order for Fair Labor Standards Act cases not pleaded as a class or collective action. Signed by Judge Victor A. Bolden on 12/2/2024.(Freberg, B) (Entered: 12/03/2024)

Judge Victor A. Bolden and Judge S. Dave Vatti added. (Oliver, T.)

NOTICE TO COUNSEL/SELF-REPRESENTED PARTIES : Counsel or self-represented parties initiating or removing this action are responsible for serving all parties with attached documents and copies of 6 Notice of Option to Consent to Magistrate Judge Jurisdiction, 3 Order on Pretrial Deadlines, 4 Electronic Filing Order, 5 Standing Protective Order, 7 Standing Order for FLSA cases, 1 Complaint, filed by Luis Adrian Perez Garcia, Rene Meza Quirino, Carlos Giovanni Perez Castro, Victor Hugo Maximo Diaz, Francisco Javier Zavala Martinez, 2 Notice re: Disclosure Statement, Signed by Clerk on 12/3/2024.(Freberg, B) (Entered: 12/03/2024)

NOTICE of Appearance by Muneer I. Ahmad on behalf of Francisco Javier Zavala Martinez, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Victor Hugo Maximo Diaz (Ahmad, Muneer) (Entered: 12/03/2024)

Notice re: Disclosure Statement

Add and Terminate Judges

Request to Issue Summons

Request for Clerk to issue summons as to John Casertano. (Ahmad, Muneer)

Request for Clerk to issue summons as to Manzana, LLC. (Ahmad, Muneer)

Request for Clerk to issue summons as to N. Casertano Greenhouses & Farms, Inc.. (Ahmad, Muneer)

Request for Clerk to issue summons as to Lawrence Williams. (Ahmad, Muneer)

ELECTRONIC SUMMONS ISSUED in accordance with Fed. R. Civ. P. 4 and LR 4 as to *John Casertano, Manzana, LLC, N. Casertano Greenhouses & Farms, Inc., Lawrence Williams* with answer to complaint due within *21* days. Attorney *Muneer I. Ahmad* *Jerome N. Frank Legal Services* *Yale Law School, 127 Wall Street* *New Haven, CT 06511*. (Freberg, B) (Entered: 12/06/2024)

WAIVER OF SERVICE Returned Executed as to John Casertano waiver sent on 12/17/2024, answer due 2/17/2025; Manzana, LLC waiver sent on 12/17/2024, answer due 2/17/2025; N. Casertano Greenhouses & Farms, Inc. waiver sent on 12/17/2024, answer due 2/17/2025; Lawrence Williams waiver sent on 12/17/2024, answer due 2/17/2025 filed by Francisco Javier Zavala Martinez; Rene Meza Quirino; Carlos Giovanni Perez Castro; Luis Adrian Perez Garcia; Victor Hugo Maximo Diaz. (Ahmad, Muneer) (Entered: 01/16/2025)

NOTICE of Appearance by Madelyn Finucane on behalf of Francisco Javier Zavala Martinez, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Victor Hugo Maximo Diaz (Finucane, Madelyn) (Entered: 02/05/2025)

MOTION for Leave to Appear Law Student Interns Mauricio Gonzalez Sanchez, Diana Miranda Jimenez, Natalia Poblete, Clara Shanabrook, Gabriela Torres-Lorenzotti, and Theodore Watler Attorney Muneer Ahmad. by Francisco Javier Zavala Martinez, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Victor Hugo Maximo Diaz. (Attachments: # 1 Exhibit Exhibit A: Consent of Supervising Attorney, # 2 Exhibit Exhibit B: Law Student Certification, # 3 Exhibit Exhibit C: Plaintiffs' Authorization of Law Students' Appearances)(Ahmad, Muneer) (Entered: 02/10/2025)

NOTICE of Appearance by Kevin R. Brady on behalf of John Casertano, Manzana, LLC, N. Casertano Greenhouses & Farms, Inc., Lawrence Williams (Brady, Kevin) (Entered: 02/14/2025)

MOTION for Attorney(s) Christopher J. Schulte to be Admitted Pro Hac Vice (paid $200 PHV fee; receipt number ACTDC-8066836) by John Casertano, Manzana, LLC, N. Casertano Greenhouses & Farms, Inc., Lawrence Williams. (Attachments: # 1 Affidavit)(Brady, Kevin) (Entered: 02/14/2025)

Disclosure Statement by Manzana, LLC, N. Casertano Greenhouses & Farms, Inc.. (Brady, Kevin) (Entered: 02/18/2025)

MOTION to Dismiss by John Casertano, Manzana, LLC, N. Casertano Greenhouses & Farms, Inc., Lawrence Williams.Responses due by 3/11/2025 (Brady, Kevin) (Entered: 02/18/2025)

Memorandum in Support re 17 MOTION to Dismiss filed by John Casertano, Manzana, LLC, N. Casertano Greenhouses & Farms, Inc., Lawrence Williams. (Brady, Kevin) (Entered: 02/18/2025)

ORDER granting 15 Motion to Appear Pro Hac Vice for Attorney Christopher J. Schulte. Signed by Clerk on 2/21/2025. (Freberg, B) (Entered: 02/21/2025)

Order on Motion for Admission Pro Hac Vice

NOTICE of Appearance by Christopher James Schulte on behalf of John Casertano, Manzana, LLC, N. Casertano Greenhouses & Farms, Inc., Lawrence Williams (Schulte, Christopher) (Entered: 02/28/2025)

MOTION for Attorney(s) Jeremy M. Creelan to be Admitted Pro Hac Vice (paid $200 PHV fee; receipt number ACTDC-8081578) by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez. (Attachments: # 1 Affidavit Exhibit A - Creelan Affidavit)(Ahmad, Muneer) (Entered: 02/28/2025)

MOTION for Attorney(s) Daniel R. Echeverri to be Admitted Pro Hac Vice (paid $200 PHV fee; receipt number ACTDC-8081615) by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez. (Attachments: # 1 Affidavit Exhibit A - Echeverri Affidavit)(Ahmad, Muneer) (Entered: 02/28/2025)

ORDER granting 21 Motion to Appear Pro Hac Vice for Attorney Jeremy M. Creelan. Signed by Clerk on 3/3/2025. (Freberg, B) (Entered: 03/03/2025)

ORDER granting 22 Motion to Appear Pro Hac Vice for Attorney Daniel R. Echeverri. Signed by Clerk on 3/3/2025. (Freberg, B) (Entered: 03/03/2025)

Order on Motion for Admission Pro Hac Vice

First MOTION for Extension of Time to File Response/Reply Opposition as to 17 MOTION to Dismiss until 04/25/2025 by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez. (Ahmad, Muneer) (Entered: 03/04/2025)

ORDER granting 25 Motion for Extension of Time to File Response/Reply.The Court GRANTS the parties' joint motion for an extension of time to file Plaintiffs' opposition to Defendants' motion to dismiss until April 25, 2025, and the Defendants' reply to 21 days after Plaintiffs file their opposition.Signed by Judge Victor A. Bolden on 3/5/2025. (McCowan, D) (Entered: 03/05/2025)

Order on Motion for Extension of Time to File Response/Reply to Motion

ORDER granting 13 Motion to Appear.The Court GRANTS the Plaintiffs' motion to permit the appearance of a law student interns Mauricio Gonzalez Sanchez, Natalia Poblete, Gabriela Torres-Lorenzotti, Theodore Watler, Clara Shanabrook, and Diana Miranda Jimenez.The Court finds that the motion satisfies all of the requirements of Local Rule 83.9 for such admission except for the two-semester requirement in regard to Clara Shanabrook and Diana Miranda Jimenez. The Court waives the two-semester requirement for Clara Shanabrook and Diana Miranda Jimenez. See Perea et al. v. Industrial Pallet, LLC et al., No. 3:21-cv- 00533-MPS, ECF No. 58 (D. Conn. Mar. 2, 2022) (granting leave to appear for law student in second semester of studies).Signed by Judge Victor A. Bolden on 3/7/2025. (McCowan, D) (Entered: 03/07/2025)

Order on Motion to Appear

NOTICE of Appearance by Jeremy M. Creelan on behalf of Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez (Creelan, Jeremy) (Entered: 03/11/2025)

NOTICE of Appearance by Daniel Echeverri on behalf of Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez (Echeverri, Daniel) (Entered: 03/11/2025)

AMENDED COMPLAINT against All Defendants, filed by Carlos Giovanni Perez Castro, Rene Meza Quirino, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez, Victor Hugo Maximo Diaz.(Ahmad, Muneer) (Entered: 03/11/2025)

MOTION for Attorney(s) Angela L. Zhang to be Admitted Pro Hac Vice (paid $200 PHV fee; receipt number ACTDC-8094551) by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez. (Attachments: # 1 Affidavit Exhibit A - Zhang Affidavit)(Ahmad, Muneer) (Entered: 03/12/2025)

ORDER granting 31 Motion to Appear Pro Hac Vice for Attorney Angela L. Zhang. Signed by Clerk on 3/13/2025. (Freberg, B) (Entered: 03/13/2025)

Order on Motion for Admission Pro Hac Vice

Joint REPORT of Rule 26(f) Planning Meeting. (Ahmad, Muneer) (Entered: 03/24/2025)

INITIAL SCHEDULING ORDER.The Court adopts the following schedule for pre-trial deadlines based on the parties' Rule 26(f) Report, the Court's preferences with respect to scheduling, and the Court's current calendar:-Initial disclosures due by March 27, 2025.-Damages analysis due by March 27, 2025.-Joinder of parties due by May 9, 2025.-Amended pleadings due by May 9, 2025.-Responses to amended pleadings due by May 30, 2025.-Designation and reports of expert witnesses on any issues on which they bear the burden of proof due by October 3, 2025.-Depositions of expert witnesses on any issues on which they bear the burden of proof shall be completed by November 7, 2025.-Designation and reports of expert witnesses on any issues on which they do not bear the burden of proof due by November 14, 2025.-Depositions of expert witnesses on any issues on which they do not bear the burden of proof shall be completed by December 19, 2025.-All discovery shall close by December 19, 2025.-If, after the close of discovery, the parties wish to meet with a Magistrate Judge to discuss settlement, the parties may jointly file such a request by January 9, 2026.-Dispositive motions due by January 23, 2026.-Responses to dispositive motions due by February 13, 2026.-Any replies to responses to dispositive motions due by February 27, 2026.-Joint trial memorandum, which shall include, inter alia, any and all motions in limine, is due by March 20, 2026, or thirty (30) days after the Court rules on any dispositive motions.-Trial ready date is April 20, 2026, or thirty (30) days after the Joint Trial Memorandum is filed.Signed by Judge Victor A. Bolden on 3/25/2025.(McCowan, D) (Entered: 03/25/2025)

ORDER.The Court orders the parties to submit simultaneous filings of no more than ten (10) pages providing legal support for their respective positions on discovery, see Rule 26(f) Report, ECF No. 33 at 7-9, by April 4, 2025, and any responses to these simultaneous filings of no more than five (5) pages, by April 11, 2025. A hearing on the discovery conference will be held by video on April 17, 2025, at 11:00 a.m., although the parties should be advised that the matter may be addressed on the written submissions without such a hearing.Signed by Judge Victor A. Bolden on 3/25/2025.(McCowan, D) (Entered: 03/25/2025)

MOTION to Dismiss Amended Complaint by John Casertano, Manzana, LLC, N. Casertano Greenhouses & Farms, Inc., Lawrence Williams.Responses due by 4/15/2025 (Brady, Kevin) (Entered: 03/25/2025)

Set Deadlines/Hearings

Order

NOTICE regarding conference via Zoom re: 33 Joint REPORT of Rule 26(f) Planning Meeting.Discovery Conference set for 4/17/2025 at 11:00 AM via Zoom before Judge Victor A. Bolden.Call-in and Public Access Number: 646 828 7666Meeting ID: 160 693 3767Meeting Password: 277617Please note: Members of the public are permitted to join this hearing by audio only using the public access number above. Video participation is permitted by the parties and counsel only. This is in accordance with the remote access policies of the Judicial Conference of the United States, which governs the practices of the federal courts. All persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, screenshots, streaming, and rebroadcasting in any form, of court proceedings. Violation of these prohibitions may result in sanctions, including restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the court.(McCowan, D)

Joint STATUS REPORT Regarding Discovery Motions by John Casertano, Manzana, LLC, N. Casertano Greenhouses & Farms, Inc., Lawrence Williams. (Brady, Kevin) (Entered: 04/04/2025)

ORDER.In light of the status report filed by the parties, ECF No. 37, the parties are relieved of the obligations of the Court's previous Order, ECF No. 35, which had required briefing and a hearing. As a result, that Order is no longer in effect. Consistent with that same status report, the parties may file a revised Rule 26(f) report by April 11, 2025.Signed by Judge Victor A. Bolden on 4/7/2025.(McCowan, D) (Entered: 04/07/2025)

Order

ORDER denying as moot 17 Motion to Dismiss.Because an Amended Complaint, ECF No. 30, has been filed, as well as a motion to dismiss that Amended Complaint, ECF No. 36, the Court DENIES AS MOOT the motion to dismiss the original Complaint, ECF No. 17 . See In re Crysen/Montenay Energy Co., 226 F.3d 160, 162 (2d Cir. 2000) ("It is well settled that an amended pleading ordinarily supersedes the original and renders it of no legal effect.").Signed by Judge Victor A. Bolden on 4/8/2025. (McCowan, D) (Entered: 04/08/2025)

Order on Motion to Dismiss

Amended REPORT of Rule 26(f) Planning Meeting. (Ahmad, Muneer) (Entered: 04/11/2025)

Memorandum in Opposition re 36 MOTION to Dismiss Amended Complaint filed by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez. (Ahmad, Muneer) (Entered: 04/25/2025)

SCHEDULING ORDER.The Court adopts the following schedule for pre-trial deadlines based on the parties' revised Rule 26(f) Report, the Court's preferences with respect to scheduling, and the Court's current calendar:-Initial disclosures due by May 9, 2025, if not previously provided consistent with the deadline agreed to by the parties.-Damages analysis due by May 9, 2025, if not previously provided consistent with the deadline agreed to by the parties.-Joinder of parties due by May 9, 2025.-Amended pleadings due by May 9, 2025.-Responses to amended pleadings due by May 30, 2025.-Designation and reports of expert witnesses on any issues on which they bear the burden of proof due by October 3, 2025.-Depositions of expert witnesses on any issues on which they bear the burden of proof shall be completed by November 14, 2025.-Designation and reports of expert witnesses on any issues on which they do not bear the burden of proof due by November 14, 2025.-Depositions of expert witnesses on any issues on which they do not bear the burden of proof shall be completed by December 19, 2025.-Depositions of fact witnesses shall be completed by December 19, 2025.-All discovery shall close by December 19, 2025.-Class certification motion due by January 16, 2026.-If, after the close of discovery, the parties wish to meet with a Magistrate Judge to discuss settlement, the parties may jointly file such a request by January 23, 2026.-Dispositive motions due by February 13, 2026.-Responses to dispositive motions due by March 6, 2026.-Any replies to responses to dispositive motions due by March 20, 2026.-Joint trial memorandum, which shall include, inter alia, any and all motions in limine, is due by April 17, 2026, or thirty (30) days after the Court rules on any dispositive motions.-Trial ready date is May 18, 2026, or thirty (30) days after the Joint Trial Memorandum is filed.Signed by Judge Victor A. Bolden on 4/28/2025.(McCowan, D) (Entered: 04/28/2025)

MOTION for Attorney(s) Sara E. Cervantes to be Admitted Pro Hac Vice (paid $200 PHV fee; receipt number ACTDC-8149907) by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez. (Ahmad, Muneer) (Entered: 04/28/2025)

ORDER granting 43 Motion to Appear Pro Hac Vice for Attorney Sara E. Cervantes. Signed by Clerk on 4/29/2025. (Freberg, B) (Entered: 04/29/2025)

Order on Motion for Admission Pro Hac Vice

REPLY to Response to 36 MOTION to Dismiss Amended Complaint filed by John Casertano, Manzana, LLC, N. Casertano Greenhouses & Farms, Inc., Lawrence Williams. (Schulte, Christopher) (Entered: 05/16/2025)

Joint MOTION for Extension of Time by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez. (Ahmad, Muneer) (Entered: 09/26/2025)

ORDER The Court has considered the parties 46 Joint Motion for Extension of Time. The motion is hereby GRANTED. The case deadlines are reset as follows. Designation and Reports from Expert Witnesses: February 6, 2026 (all experts). Expert Depositions: April 3, 2026 (all experts). Depositions of Fact Witnesses: April 3, 2026. Close of Discovery: April 3, 2026. Deadline for Motion for Class Certification: May 1, 2026. Deadline for Parties to Jointly Request a Settlement Conference before a Magistrate Judge: May 8, 2026. Deadline for Dispositive Motions: May 29, 2026. Deadline for Responses to Dispositive Motions: June 19, 2026. Deadline for Replies to Responses to Dispositive Motions: July 2, 2026. Deadline for Joint Trial Memorandum (including any motions in limine): July 31, 2026, or 30 days after the Court rules on any dispositive motions. Trial Ready Date: August 31, 2026, or 30 days after the joint trial memorandum is filed. Signed by Judge Victor A. Bolden on 9/29/2025. (Fregia, P) (Entered: 09/29/2025)

Order on Motion for Extension of Time

Set Deadlines: Discovery due by 4/3/2026; Dispositive Motions due by 5/29/2026; Joint Trial Memorandum due by 7/31/2026; Trial Ready Date 8/31/2026. (Velez, F)

Set Deadlines/Hearings

Consent MOTION for Leave to Appear Law Student Interns Sharon Du, Jordan Cozby Attorney Muneer I. Ahmad. by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez. (Attachments: # 1 Exhibit Consent of Supervising Attorney, # 2 Exhibit Law Student Certification, # 3 Exhibit Plaintiffs' Authorization of Law Students' Appearances)(Ahmad, Muneer) (Entered: 10/10/2025)

ORDER granting 48 Motion to Appear law student appearance (Sharon Du and Jordan Cozby) under D. Conn. Local Rule 83.9, supervised by Attorney Muneer Ahmad, for Plaintiffs. The Court GRANTS the motion to appear. Signed by Judge Victor A. Bolden on 10/14/2025. (Fregia, P) (Entered: 10/14/2025)

Order on Motion to Appear

Joint MOTION for Discovery Conference by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez. (Attachments: # 1 Exhibit G - Notice of Site Inspection, # 2 Exhibit H - Correspondence)(Ahmad, Muneer) (Entered: 11/11/2025)

ORDER. The Court grants ECF No. 50 and 52 motion for discovery conference. A telephone discovery conference will be held on November 24, 2025, at 2:00 p.m. to address all outstanding discovery issues. The parties may file additional briefing of no more than ten (10) pages each by November 14, 2025. Any responses to the additional briefing, limited to five (5) pages each, shall be filed by November 19, 2025. See Dietz v. Bouldin, 579 U.S. 40, 47 (2016) ("[D]istrict courts have the inherent authority to manage their dockets and courtrooms with a view toward the efficient and expedient resolution of cases.").Signed by Judge Victor A. Bolden on 11/12/2025. (Fregia, P) Modified on 11/12/2025 to note it's telephonic (Velez, F). (Entered: 11/12/2025)

Docket Entry Correction re 53 Order on Motion for Conference: The conference is telephonic. (Velez, F) (Entered: 11/12/2025)

NOTICE OF E-FILED CALENDAR: THIS IS THE ONLY NOTICE COUNSEL/THE PARTIES WILL RECEIVE. ALL PERSONS ENTERING THE COURTHOUSE MUST PRESENT PHOTO IDENTIFICATION. A Telephonic Discovery Conference is set for 11/24/2025 at 02:00 PM in Remote Setting before Judge Victor A. Bolden. To Join the Conference, dial: 1 203-684-6202 Enter Conference ID: 417 075 313# (Velez, F) (Entered: 11/12/2025)

Order on Motion for Conference AND Order on Motion for Conference

Calendar Entry

Docket Annotation

NOTICE by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez re 53 Order on Motion for Conference,,,,,,, Plaintiffs' Discovery Conference Brief (Attachments: # 1 Exhibit I, # 2 Exhibit J)(Creelan, Jeremy) (Entered: 11/14/2025)

RESPONSE re 52 Joint MOTION for Discovery Conference, 53 Order on Motion for Conference,,,,,,, 50 Joint MOTION for Discovery Conference filed by John Casertano, Manzana, LLC, N. Casertano Greenhouses & Farms, Inc., Lawrence Williams. (Attachments: # 1 Exhibit A- ESI Production, # 2 Exhibit B - Interrogatory Responses, # 3 Exhibit C - Interrogatory Response Summary)(Brady, Kevin) (Entered: 11/14/2025)

RESPONSE re 57 Response, Plaintiffs' Response to Defendants' Discovery Conference Brief filed by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez. (Attachments: # 1 Exhibit K)(Creelan, Jeremy) (Entered: 11/19/2025)

RESPONSE re 56 Notice (Other), Defendants' Response to Plaintiffs' Discovery Conference Brief filed by John Casertano, Manzana, LLC, N. Casertano Greenhouses & Farms, Inc., Lawrence Williams. (Brady, Kevin) (Entered: 11/19/2025)

Minute Entry for proceedings held on November 24, 2025 before Judge Victor A. Bolden: Telephone Discovery Conference. A separate order will be entered on the docket. Time: 28 minutes. (Court Reporter Terri Fidanza) (Fregia, P) (Entered: 11/24/2025)

ORDER. The Court held a discovery conference on November 24, 2025. The issues presented concerned Plaintiffs' request to conduct a site inspection of Defendants' greenhouses and employee housing under Rule 34 of the Federal Rules of Civil Procedure, and several disputes regarding the sufficiency of Defendants' discovery responses. The Court deferred resolution of the remaining discovery disputes concerning Defendants' interrogatory responses and document production, and rather than address them imminently, will address them based on the parties filings.As to the site inspection, under Rule 34(a), a party may request, within the scope of Rule 26(b), "to produce and permit the requesting party or its representative to inspect, copy, test, or sample" designated documents, ESI, or tangible things in the responding partys possession, custody, or control. Fed. R. Civ. P. 34(a)(1). A party may also request "entry onto designated land or other property possessed or controlled by the responding party, so that the requesting party may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it. Fed. R. Civ. P. 34(a)(2). Any such request must describe with reasonable particularity each item or category of items to be inspected" and "must specify a reasonable time, place, and manner for the inspection." Fed. R. Civ. P. 34(b)(1)(A)(B). The responding party's written response "must either state that inspection and related activities will be permitted as requested or state with specificity the grounds for objecting to the request, including the reasons," and any objection must "state whether any responsive materials are being withheld on the basis of that objection." Fed. R. Civ. P. 34(b)(2)(B)(C).Plaintiffs seek an inspection this week, citing the imminent departure of the H-2A workers whose working and living conditions form part of the factual basis of their claims. Defendants oppose the timing of the inspection or ask that it be postponed until after the workers leave, citing safety concerns, disruption to greenhouse operations, and privacy interests for current residents in the housing units. In light of the text of Rule 34, the representations made by the parties at the conference, and the relevant caselaw, the Court will permit an inspection to proceed on either November 25, 2025 or November 26, 2025. Because Rule 34 requires that the inspection occur at a "reasonable time, place, and manner," see, e.g., N.Y. State Assn for Retarded Children v. Carey, 706 F.2d 956, 961 (2d Cir. 1983)(explaining that courts must weigh an inspections contribution to the "search for truth" against "the burdens and dangers created by the inspection."), the parties should agree on conditions identifying with particularity the areas to be inspected; limiting the duration and the number of individuals present; ensuring appropriate safety protocols; protecting the privacy of current housing occupants; and ensuring compliance with any existing protective order, and must do so by tonight at 11:59 p.m., or the Court will issue any order reasonably necessary in the absence of such an agreement. See United States v. Wynder, 2022 WL 3572881, at *2 (S.D.N.Y. Aug. 19, 2022)(courts may "order that party to permit the discovery or inspection; specify its time, place, and manner; and prescribe other just terms and conditions."); see also Dietz v. Bouldin, 579 U.S. 40, 47 (2016)("[D]istrict courts have the inherent authority to manage their dockets and courtrooms with a view toward the efficient and expedient resolution of cases."). Signed by Judge Victor A. Bolden on 11/24/2025. (Fregia, P) (Entered: 11/24/2025)

Joint NOTICE by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez (Finucane, Madelyn) (Entered: 11/24/2025)

Order

Status Conference

MOTION for Daniel R.Echeverri to Withdraw as Attorney by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez. (Echeverri, Daniel) (Entered: 12/02/2025)

ORDER. The Court GRANTS ECF. No. 63, motion to withdraw as attorney. The Clerk of Court is respectfully directed to terminate Attorney Daniel Echeverri's appearance on the docket. Signed by Judge Victor A. Bolden on 12/3/2025. (Fregia, P) Modified on 12/4/2025 to correct typo (Velez, F). (Entered: 12/03/2025)

Order on Motion to Withdraw as Attorney

Docket Entry Correction re 64 Order on Motion to Withdraw as Attorney: edited text. (Velez, F) (Entered: 12/04/2025)

Docket Annotation

MOTION for Attorney(s) Jacqueline M. Gordon to be Admitted Pro Hac Vice (paid $200 PHV fee; receipt number ACTDC-8424975) by Manzana, LLC, Lawrence Williams. (Attachments: # 1 Affidavit of Visiting Attorney, # 2 Exhibit Certificate of Good Standing)(Brady, Kevin) (Entered: 12/05/2025)

ORDER granting 66 Motion to Appear Pro Hac Vice for Attorney Jacqueline M. Gordon. Signed by Clerk on 12/8/2025. (Freberg, B) (Entered: 12/08/2025)

Order on Motion for Admission Pro Hac Vice

NOTICE of Appearance by Jacqueline M. Gordon on behalf of Manzana, LLC, Lawrence Williams (Gordon, Jacqueline) (Entered: 12/09/2025)

MOTION for Attorney(s) Andrew Rohrbach to be Admitted Pro Hac Vice (paid $200 PHV fee; receipt number ACTDC-8429021) by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez. (Ahmad, Muneer) (Entered: 12/10/2025)

MOTION for Attorney(s) Elizabeth M.D. Pullin to be Admitted Pro Hac Vice (paid $200 PHV fee; receipt number ACTDC-8429038) by Victor Hugo Maximo Diaz, Rene Meza Quirino, Carlos Giovanni Perez Castro, Luis Adrian Perez Garcia, Francisco Javier Zavala Martinez. (Ahmad, Muneer) (Entered: 12/10/2025)

ORDER granting 69 Motion to Appear Pro Hac Vice for Attorney Andrew Rohrbach. Signed by Clerk on 12/12/2025. (Barry, L.) (Entered: 12/12/2025)