Case: Martinez v. Mobis Alabama, LLC

Martinez v. Mobis Alabama, LLC et al.

COMPLAINT with Jury Demand filed by Jorge Oswaldo Aquino Martinez. (Filing fee $402, receipt number AGANDC-11990201) (Attachments: # 1 Civil Cover Sheet)(jkb) Please visit our website at http://www.gand.uscourts.gov/commonly-used-forms to obtain Pretrial Instructions and Pretrial Associated Forms which includes the Consent To Proceed Before U.S. Magistrate form. (Entered: 08/11/2022)

1 Civil Cover Sheet

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Electronic Summons Issued as to GB2G, Inc., Mobis Alabama, LLC, SPJ Connect. (Attachments: # 1 Summons Mobis Alabama, # 2 Summons SPJ Connect, Inc.)(jkb) (Entered: 08/11/2022)

Return of Service Executed by Jorge Oswaldo Aquino Martinez. Mobis Alabama, LLC served on 8/11/2022, answer due 9/1/2022. (Lampros, Peter) (Entered: 08/12/2022)

NOTICE of Appearance by Peter Andrew Lampros on behalf of Jorge Oswaldo Aquino Martinez (Lampros, Peter) (Entered: 08/15/2022)

Return of Service Executed by Jorge Oswaldo Aquino Martinez. SPJ Connect served on 8/18/2022, answer due 9/8/2022. (Lampros, Peter) (Entered: 08/22/2022)

Return of Service Executed by Jorge Oswaldo Aquino Martinez. GB2G, Inc. served on 8/18/2022, answer due 9/8/2022. (Lampros, Peter) (Entered: 08/22/2022)

Joint MOTION for Extension of Time for Defendants to Respond to the Complaint and for Plaintiff to File His Motion for Class Certification by GB2G, Inc., SPJ Connect. (Gibbs, John) (Entered: 08/31/2022)

NOTICE of Appearance by Jon Michael Gumbel on behalf of Mobis Alabama, LLC (Gumbel, Jon) (Entered: 09/08/2022)

APPLICATION for Admission of Michael Lee Lucas Pro Hac Vice (Application fee $ 150, receipt number AGANDC-12053025).by Mobis Alabama, LLC. (Gumbel, Jon) Documents for this entry are not available for viewing outside the courthouse. (Entered: 09/08/2022)

NOTICE of Appearance by Ingu Hwang on behalf of Mobis Alabama, LLC (Hwang, Ingu) (Entered: 09/08/2022)

ORDER granting 7 Joint MOTION for Extension of Time to File First Amended Complaint, Answers or Other Responses to the Complaint, and Class Certification Motion. Plaintiff Jorge Oswaldo Aquino Martinez shall have until September 14, 2022, to file an amended complaint. Defendants Mobis Alabama, LLC, doing business as Hyundai Mobis, GB2G, Inc., doing business as Allswell, and SPJ Connect, shall have thirty (30) days from the filing of the amended complaint in which to answer, move, or otherwise respond to plaintiff's complaint. The time within which plaintiff may file his Motion for Class Certification is extended to six months after the opening of discovery in this case. Signed by Magistrate Judge Russell G. Vineyard on 9/12/2022. (rsg) (Entered: 09/12/2022)

APPROVAL by Clerks Office re: 9 APPLICATION for Admission of Michael Lee Lucas Pro Hac Vice (Application fee $ 150, receipt number AGANDC-12053025). Attorney Michael L. Lucas added appearing on behalf of Mobis Alabama, LLC (cdg)

MINUTE ORDER granting Michael Lee Lucas's 9 Application for Admission Pro Hac Vice. Entered by CRD at the direction of Chief U.S. District Judge Timothy C. Batten, Sr. If the applicant does not have CM/ECF access in the Northern District of Georgia already, they must request access at http://pacer.gov. If they have electronically filed in this district in a previous case, please omit this step.(usw)

NOTICE of Appearance by Charles E. Peeler on behalf of GB2G, Inc., SPJ Connect (Peeler, Charles) (Entered: 09/20/2022)

NOTICE by Jorge Oswaldo Aquino Martinez CIVIL LOCAL RULE 23.1(C) JOINT STATEMENT (Benjamin, Rachel) (Entered: 09/22/2022)

Joint MOTION for Extension of Time to File Answer to the Complaint by GB2G, Inc., SPJ Connect. (Gibbs, John) (Entered: 09/23/2022)

Corporate Disclosure Statement by GB2G, Inc., SPJ Connect.(Gibbs, John) (Entered: 09/23/2022)

ORDER granting 14 Joint MOTION for Extension of Time to File Answer to the Complaint, GB2G, Inc., Mobis Alabama, LLC, and SPJ Connect Answers due 10/14/2022. Signed by Magistrate Judge Russell G. Vineyard on 09/26/2022. (rsg) (Entered: 09/26/2022)

NOTICE of Appearance by Emily Evans Schifter on behalf of GB2G, Inc., SPJ Connect (Schifter, Emily) (Entered: 09/30/2022)

NOTICE of Appearance by Daniel Werner on behalf of Jorge Oswaldo Aquino Martinez (Werner, Daniel) (Entered: 10/04/2022)

MOTION to Dismiss Plaintiff's Class Action Complaint For Failure to State a Claim with Brief In Support by GB2G, Inc., SPJ Connect. (Attachments: # 1 Brief in Support of Their Motion to Dismiss Plaintiff's Class Action Complaint)(Gibbs, John) Modified on 10/17/2022 to edit text (gas). (Entered: 10/14/2022)

Certificate of Interested Persons and Corporate Disclosure Statement by Mobis Alabama, LLC identifying Corporate Parent Hyundai MOBIS Co. Ltd. for Mobis Alabama, LLC. (Lucas, Michael) (Entered: 10/14/2022)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM with Brief In Support by Mobis Alabama, LLC. (Attachments: # 1 Brief in Support of Motion)(Lucas, Michael) (Entered: 10/14/2022)

Consent MOTION for Extension of Time re: 19 Motion to Dismiss for Failure to State a Claim, 21 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Jorge Oswaldo Aquino Martinez. (Benjamin, Rachel) (Entered: 10/19/2022)

ORDER granting 22 Consent MOTION for Extension of Time. The time for plaintiff to respond to defendants' motions to dismiss, is extended to November 4, 2022. Signed by Magistrate Judge Russell G. Vineyard on 10/19/2022. (rsg) (Entered: 10/19/2022)

Clerks Notation re 20 Certificate of Interested Persons. Reviewed and approved by Chief U.S. District Judge Timothy C. Batten, Sr. (usw)

Consent MOTION Motion to Extend Initial Discovery Deadlines by GB2G, Inc., SPJ Connect. (Schifter, Emily) Modified motion type on 12/16/2022 (dmb). (Entered: 10/26/2022)

First AMENDED COMPLAINT (CLASS ACTION COMPLAINT) against GB2G, Inc., Mobis Alabama, LLC, SPJ Connectwith Jury Demand filed by Jorge Oswaldo Aquino Martinez. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24)(Benjamin, Rachel) Please visit our website at http://www.gand.uscourts.gov/commonly-used-forms to obtain Pretrial Instructions and Pretrial Associated Forms which includes the Consent To Proceed Before U.S. Magistrate form. (Entered: 11/04/2022)

Submission of 21 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM and 19 Motion to Dismiss for Failure to State a Claim, to Magistrate Judge Russell G. Vineyard. (usw)

APPLICATION for Admission of Benjamin Richard Botts Pro Hac Vice (Application fee $ 150, receipt number AGANDC-12188999).by Jorge Oswaldo Aquino Martinez. (Benjamin, Rachel) Documents for this entry are not available for viewing outside the courthouse. (Entered: 11/09/2022)

APPROVAL by Clerks Office re: 26 APPLICATION for Admission of Benjamin Richard Botts Pro Hac Vice (Application fee $ 150, receipt number AGANDC-12188999). Attorney Benjamin Richard Botts added appearing on behalf of Jorge Oswaldo Aquino Martinez (pdt)

MINUTE ORDER granting 26 Application for Admission Pro Hac Vice. Entered by CRD at the direction of Chief U.S. District Judge Timothy C. Batten, Sr. If the applicant does not have CM/ECF access in the Northern District of Georgia already, they must request access at http://pacer.gov. If they have electronically filed in this district in a previous case, please omit this step.(usw)

Joint MOTION for Extension of Time for Plaintiffs to File a Second Amended Complaint and to Extend Defendants' Deadline to Respond to Plaintiffs' Second Amended Complaint and Extend Page Limits by GB2G, Inc., SPJ Connect. (Gibbs, John) (Entered: 11/17/2022)

Submission of 24 Consent MOTION Motion to Extend Initial Discovery Deadlines to Magistrate Judge Russell G. Vineyard. (dmb)

Submission of 27 Joint MOTION for Extension of Time for Plaintiffs to File a Second Amended Complaint and to Extend Defendants' Deadline to Respond to Plaintiffs' Second Amended Complaint and Extend Page Limits to Magistrate Judge Russell G. Vineyard. (dmb)

ORDER granting 24 Motion for Extension of Time to Complete Discovery and 27 Motion for Extension of Time and denying as moot 19 Motion to Dismiss for Failure to State a Claim and 21 Motion to Dismiss for Failure to State a Claim. The Amended Class Action complaint supersedes the original complaint. The parties shall have until 30 calendar days after the District Judge rules on the motions to dismiss the second amended complaint in which to conduct the Rule 26(f) conference if this action remains pending and shall file initial disclosures and the Joint Preliminary Report and Discovery Plan within 15 days after the Rule 26(f) conference. Signed by Magistrate Judge Russell G. Vineyard on 12/16/2022. (dmb) (Entered: 12/16/2022)

Second AMENDED COMPLAINT (CLASS ACTION COMPLAINT) against All Defendants with Jury Demand filed by Jorge Oswaldo Aquino Martinez. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26, # 27 Exhibit 27, # 28 Exhibit 28)(Benjamin, Rachel) Please visit our website at http://www.gand.uscourts.gov/commonly-used-forms to obtain Pretrial Instructions and Pretrial Associated Forms which includes the Consent To Proceed Before U.S. Magistrate form. (Entered: 12/16/2022)

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APPLICATION for Admission of Allison Hawkins Pro Hac Vice (Application fee $ 150, receipt number AGANDC-12270139).by Mobis Alabama, LLC. (Gumbel, Jon) Documents for this entry are not available for viewing outside the courthouse. (Entered: 12/19/2022)

PROPOSED SUMMONS filed by Jorge Oswaldo Aquino Martinez for Defendant Kia Georgia, Inc. (Benjamin, Rachel) (Entered: 12/20/2022)

PROPOSED SUMMONS filed by Jorge Oswaldo Aquino Martinez for Defendant Job Knowledge LLC (Benjamin, Rachel) (Entered: 12/20/2022)

PROPOSED SUMMONS filed by Jorge Oswaldo Aquino Martinez for Defendant Total Employee Solution Support (TESS) (Benjamin, Rachel) (Entered: 12/20/2022)

PROPOSED SUMMONS filed by Jorge Oswaldo Aquino Martinez for Defendant Youngjin Lee (Benjamin, Rachel) (Entered: 12/20/2022)

APPROVAL by Clerks Office re: 30 APPLICATION for Admission of Allison Hawkins Pro Hac Vice (Application fee $ 150, receipt number AGANDC-12270139). Attorney Allison Hawkins added appearing on behalf of Mobis Alabama, LLC (cdg)

Electronic Summons Issued as to Kia Georgia, Inc.. (dmb) (Entered: 12/22/2022)

Electronic Summons Issued as to Job Knowledge, LLC. (dmb) (Entered: 12/22/2022)

Electronic Summons Issued as to Total Employee Solution Support, LLC. (dmb) (Entered: 12/22/2022)

Electronic Summons Issued as to Youngjin Lee. (dmb) (Entered: 12/22/2022)

MINUTE ORDER granting 30 Application for Admission Pro Hac Vice. Entered by CRD at the direction of Chief U.S. District Judge Timothy C. Batten, Sr. If the applicant does not have CM/ECF access in the Northern District of Georgia already, they must request access at http://pacer.gov. If they have electronically filed in this district in a previous case, please omit this step.(usw)

WAIVER OF SERVICE Returned Executed by Jorge Oswaldo Aquino Martinez. Kia Georgia, Inc. waiver mailed on 12/28/2022, answer due 2/27/2023. (Sutherland, Brian) (Entered: 01/05/2023)

Return of Service Executed by Jorge Oswaldo Aquino Martinez. Job Knowledge, LLC served on 1/5/2023, answer due 1/26/2023. (Benjamin, Rachel) (Entered: 01/06/2023)

WAIVER OF SERVICE Returned Executed by Jorge Oswaldo Aquino Martinez. Youngjin Lee waiver mailed on 12/28/2022, answer due 2/27/2023. (Benjamin, Rachel) (Entered: 01/10/2023)

Return of Service Executed by Jorge Oswaldo Aquino Martinez. Total Employee Solution Support, LLC served on 1/10/2023, answer due 1/31/2023. (Benjamin, Rachel) (Entered: 01/16/2023)

NOTICE of Appearance by Charles K. McKnight, Jr on behalf of Job Knowledge, LLC (McKnight, Charles) (Entered: 01/20/2023)

Certificate of Interested Persons by Job Knowledge, LLC. (McKnight, Charles) (Entered: 01/20/2023)

Consent MOTION for Extension of Time To Respond to Second Amended Class Action Complaint by Job Knowledge, LLC. (Attachments: # 1 Text of Proposed Order Proposed Order Granting Consent Motion for Extension of Time for Defendant Job Knowledge, LLC to Respond to Second Amended Class Action Complaint)(McKnight, Charles) Modified event type on 1/24/2023 (dmb). (Entered: 01/20/2023)

Joint MOTION Expedited Motion for Extension of Page Limitations by GB2G, Inc., SPJ Connect, SPJ Connect, Inc.. (Schifter, Emily) (Entered: 01/20/2023)

RESPONSE in Opposition re 46 Joint MOTION Expedited Motion for Extension of Page Limitations filed by Jorge Oswaldo Aquino Martinez, Elvis Nahum Cruz Vasquez, Heber Alfonso Zapata Contreras, Isidro Arellano Chihuahua, Jose Maria Ramirez Morales, Luis Adrian Salazar Lozano, Veronica Olan Castillo, Aaron Hernan Perez Salazar. (Werner, Daniel) (Entered: 01/23/2023)

ORDER granting in part and denying in part 46 Motion for Extension of Page limits. Defendants are granted leave to file briefs in support of their motions to dismiss of up to 60 pages in length. Plaintiffs are likewise granted leave to file responses to the motions to dismiss of up to 60 pages in length. Reply briefs shall not exceed 30 pages in length. Signed by Magistrate Judge Russell G. Vineyard on 1/24/2023. (dmb) (Entered: 01/24/2023)

ORDER granting 45 Motion for Extension of Time to File Answer. Job Knowledge, LLC Answer due 2/27/2023. Signed by Magistrate Judge Russell G. Vineyard on 1/24/2023. (dmb) (Entered: 01/24/2023)

Clerks Notation re 44 Certificate of Interested Persons. Reviewed and approved by Chief U.S. District Judge Timothy C. Batten, Sr. (usw)

NOTICE of Appearance by Nicholas Francesco McDaniel on behalf of Job Knowledge, LLC (McDaniel, Nicholas) (Entered: 01/26/2023)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM with Brief In Support by Mobis Alabama, LLC. (Attachments: # 1 Brief Memorandum of Law in Support of Partial Motion to Dismiss Plaintiffs' Second Amended Complaint)(Lucas, Michael) (Entered: 01/27/2023)

MOTION to Dismiss Plaintiffs' Second Amended Complaint with Brief In Support by GB2G, Inc., SPJ Connect, Inc.. (Attachments: # 1 Brief Brief in Support of Motion to Dismiss)(Gibbs, John) (Entered: 01/27/2023)

Notice for Leave of Absence for the following date(s): 3/2-8/2023, 4/17-19/2023, 5/31-6/14/2023, by Daniel Werner. (Werner, Daniel) Modified docket text on 2/1/2023 (dmb). (Entered: 01/28/2023)

Joint MOTION for Extension of Time to File Answer and for an Extension of Time for Plaintiffs to Respond to Motion to Dismiss with Brief In Support by Total Employee Solution Support, LLC. (Attachments: # 1 Text of Proposed Order Proposed Order)(Kresser, David) (Entered: 01/30/2023)

ORDER granting 54 Joint MOTION for Extension of Time to File Answer and for an Extension of Time for Plaintiffs to Respond to Motion to Dismiss. Total Employee Solution Support, LLC Answer due 3/15/2023. To the extent TotalEmployee Solution Support, LLC files a motion to dismiss, Plaintiffs shall haveforty-five (45) days to file a response in opposition. Signed by Magistrate Judge Russell G. Vineyard on 1/30/2023. (dmb) (Entered: 01/30/2023)

NOTICE for Leave of Absence from 5/3-5/20/2023 by Mobis Alabama, LLC (Lucas, Michael) Modified docket text on 2/1/2023 (dmb). (Entered: 01/31/2023)

NOTICE of Appearance by JonVieve Hill on behalf of Total Employee Solution Support, LLC (Hill, JonVieve) (Entered: 02/01/2023)

Notice for Leave of Absence for the following date(s): 3/3/2023, 3/6-10/2023, by Charles K. McKnight, Jr. (McKnight, Charles) Modified docket text on 2/2/2023 (dmb). (Entered: 02/01/2023)

NOTICE of Appearance by William Jonathan Martin, II on behalf of Kia Georgia, Inc. (Martin, William) (Entered: 02/01/2023)

NOTICE of Appearance by Sarah M. Phaff on behalf of Kia Georgia, Inc. (Phaff, Sarah) (Entered: 02/01/2023)

APPLICATION for Admission of Kristin Greer Love Pro Hac Vice (Application fee $ 150, receipt number AGANDC-12363231).by Isidro Arellano Chihuahua, Elvis Nahum Cruz Vasquez, Jorge Oswaldo Aquino Martinez, Veronica Olan Castillo, Aaron Hernan Perez Salazar, Jose Maria Ramirez Morales, Luis Adrian Salazar Lozano, Heber Alfonso Zapata Contreras. (Attachments: # 1 Text of Proposed Order)(Werner, Daniel) Documents for this entry are not available for viewing outside the courthouse. (Entered: 02/02/2023)

Joint MOTION for Extension of Time to File Answer and for an Extension of Time for Plaintiffs to Respond to Motion to Dismiss by Kia Georgia, Inc.. (Attachments: # 1 Proposed Order)(Martin, William) . Added MOTION for Extension of Time on 2/10/2023 (dmb). (Entered: 02/09/2023)

APPROVAL by Clerks Office re: 61 APPLICATION for Admission of Kristin Greer Love Pro Hac Vice (Application fee $ 150, receipt number AGANDC-12363231). Attorney Kristin Greer Love added appearing on behalf of Isidro Arellano Chihuahua, Elvis Nahum Cruz Vasquez, Jorge Oswaldo Aquino Martinez, Veronica Olan Castillo, Aaron Hernan Perez Salazar, Jose Maria Ramirez Morales, Luis Adrian Salazar Lozano, Heber Alfonso Zapata Contreras (cdg)

MINUTE ORDER granting 61 Application for Admission Pro Hac Vice. Entered by CRD at the direction of Chief U.S. District Judge Timothy C. Batten, Sr. If the applicant does not have CM/ECF access in the Northern District of Georgia already, they must request access at http://pacer.gov. If they have electronically filed in this district in a previous case, please omit this step.(usw)

ORDER granting 62 Joint MOTION for Extension of Time to File Answer and Extension of time for Plaintiffs to respond to Motion to Dismiss. Kia Georgia, Inc. Answer due 3/15/2023. To the extent Defendant Kia Georgia, Inc. moves to dismiss the second amended complaint, Plaintiffs shall have 45 days to submit any response in opposition. Signed by Magistrate Judge Russell G. Vineyard on 2/14/2023. (dmb) (Entered: 02/14/2023)

Defendant Youngjin Lee's ANSWER to 29 Amended Complaint by GB2G, Inc., SPJ Connect, Inc.. Discovery ends on 7/27/2023.(Gibbs, John) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 02/27/2023)

MOTION to Dismiss Defendant Job Knowledge LLC's Motion to Dismiss Plaintiffs' Second Amended Class Action Complaint with Brief In Support by Job Knowledge, LLC. (Attachments: # 1 Brief Defendant Job Knowledge, LLC's Memorandum of Law in Support of its Motion to Dismiss Plaintiffs' Second Amended Class Action Complaint)(McKnight, Charles) (Entered: 02/27/2023)

NOTICE Of Filing Correction of 65-1 by Job Knowledge, LLC re 65 MOTION to Dismiss Defendant Job Knowledge LLC's Motion to Dismiss Plaintiffs' Second Amended Class Action Complaint (Attachments: # 1 Brief)(McKnight, Charles) (Entered: 02/27/2023)

Consent MOTION for Extension of Time File Response to Motion To Dismiss re: 66 Notice of Filing, 65 MOTION to Dismiss Defendant Job Knowledge LLC's Motion to Dismiss Plaintiffs' Second Amended Class Action Complaint, Consent MOTION for Leave to File Excess Pages by Isidro Arellano Chihuahua, Sunghee Cho, Elvis Nahum Cruz Vasquez, Jorge Oswaldo Aquino Martinez, Veronica Olan Castillo, Aaron Hernan Perez Salazar, Jose Maria Ramirez Morales, Luis Adrian Salazar Lozano, Heber Alfonso Zapata Contreras. (Attachments: # 1 Text of Proposed Order)(Benjamin, Rachel) (Entered: 03/06/2023)

ORDER granting 67 Consent MOTION for Extension of Time File Response to Motion To Dismiss and Consent MOTION for Leave to File Excess Pages. Plaintiff's response to the Motion to Dismiss is due 4/3/2023. The page limit for the response is 60 pages and 30 pages for the reply. Signed by Magistrate Judge Russell G. Vineyard on 3/8/2023. (dmb) (Entered: 03/08/2023)

MOTION to Amend (Plaintiffs' Motion for Leave to File Third Amended Complaint) with Brief In Support by Isidro Arellano Chihuahua, Elvis Nahum Cruz Vasquez, Jorge Oswaldo Aquino Martinez, Veronica Olan Castillo, Aaron Hernan Perez Salazar, Jose Maria Ramirez Morales, Luis Adrian Salazar Lozano, Heber Alfonso Zapata Contreras. (Attachments: # 1 Exhibit (Motion Ex. A: Third Amended Complaint ("TAC")), # 2 TAC Table of Exhibits, # 3 Exhibit TAC 1: FLSA Consents to Sue, # 4 Exhibit TAC 2: Jorge Oswaldo Aquino Martinez Offer Letter, # 5 Exhibit TAC 3: Jorge Oswaldo Aquino Martinez Support Letter, # 6 Exhibit TAC 4: Elvis Nahum Cruz Vasquez Meeting Invitation, # 7 Exhibit TAC 5: Elvis Nahum Cruz Vasquez Offer Letter, # 8 Exhibit TAC 6: Elvis Nahum Cruz Vasquez Support Letter, # 9 Exhibit TAC 7: Elvis Nahum Cruz Vasquez Consular Interview Instructions, # 10 Exhibit TAC 8: Heber Alfonso Zapata Contreras Offer Letter, # 11 Exhibit TAC 9: Heber Alfonso Zapata Contreras Support Letter, # 12 Exhibit TAC 10: SPJ Email Attaching Jose Maria Ramirez Morales Offer Letter, # 13 Exhibit TAC 11: SPJ Email to Jose Maria Ramirez Morales Requesting Documents, # 14 Exhibit TAC 12: Jose Maria Ramirez Morales Email to SPJ Providing Documents, # 15 Exhibit TAC 13: Jose Maria Ramirez Morales Offer Letter, # 16 Exhibit TAC 14: Jose Maria Ramirez Morales Support Letter, # 17 Exhibit TAC 15: SPJ Email to Jose Maria Ramirez Morales with Travel Instructions, # 18 Exhibit TAC 16: SPJ Email to Jose Maria Ramirez Morales with Job Instructions, # 19 Exhibit TAC 17: SPJ Email to Jose Maria Ramirez Morales with Housing Instructions, # 20 Exhibit TAC 18: Luis Adrian Salazar Lozano Offer Letter, # 21 Exhibit TAC 19: Luis Adrian Salazar Lozano Support Letter, # 22 Exhibit TAC 20: Luis Adrian Salazar Lozano Consular Interview Instructions, # 23 Exhibit TAC 21: Isidro Arellano Chihuahua SPJ Meeting Announcement and Photographs, # 24 Exhibit TAC 22: Isidro Arellano Chihuahua Offer Letter, # 25 Exhibit TAC 23: Isidro Arellano Chihuahua Support Letter, # 26 Exhibit TAC 24: Isidro Arellano Chihuahua Consular Interview Instructions, # 27 Exhibit TAC 25: Aaron Hernan Perez Salazar Offer Letter, # 28 Exhibit TAC 26: Aaron Hernan Perez Salazar Visa Processing Instructions, # 29 Exhibit TAC 27: Aaron Hernan Perez Salazar Second Offer Letter & Support Letter, # 30 Exhibit TAC 28: Veronica Olan Castillo Offer Letter, # 31 Exhibit TAC 29: Veronica Olan Castillo Support Letter, # 32 Exhibit TAC 30: Plaintiff Chart, RICO Enterprise Chart, and Claims Chart, # 33 Exhibit (Motion Exhibit B: Second Amended Complaint-Third Amended Complaint Comparison))(Werner, Daniel) (Entered: 03/10/2023)

RESPONSE in Opposition re 51 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM (HYUNDAI MOBIS' MTD) filed by Isidro Arellano Chihuahua, Elvis Nahum Cruz Vasquez, Jorge Oswaldo Aquino Martinez, Veronica Olan Castillo, Aaron Hernan Perez Salazar, Jose Maria Ramirez Morales, Luis Adrian Salazar Lozano, Heber Alfonso Zapata Contreras. (Benjamin, Rachel) (Entered: 03/10/2023)

RESPONSE in Opposition re 52 MOTION to Dismiss Plaintiffs' Second Amended Complaint (ALLSWELL/SPJ MOTION TO DISMISS) filed by Isidro Arellano Chihuahua, Elvis Nahum Cruz Vasquez, Jorge Oswaldo Aquino Martinez, Veronica Olan Castillo, Aaron Hernan Perez Salazar, Jose Maria Ramirez Morales, Luis Adrian Salazar Lozano, Heber Alfonso Zapata Contreras. (Benjamin, Rachel) (Entered: 03/10/2023)

Joint MOTION for Extension of Time for Defendants to Respond to Third Amended Complaint, for an Extension of Time for Plaintiffs' to Respond to Motions to Dismiss re: 69 MOTION to Amend (Plaintiffs' Motion for Leave to File Third Amended Complaint), Joint MOTION for Leave to File Excess Pages by Kia Georgia, Inc.. (Attachments: # 1 Proposed Order)(Martin, William) Added MOTION for Extension of Time and modified additional motion type on 3/15/2023 (dmb). (Entered: 03/14/2023)

ORDER granting 72 Motion for Extension of Time to Answer, MOTION for Leave to File Excess Pages and MOTION for Extension of Time. Plaintiffs shall file a third amended complaint by 3/20/2023. Kia Georgia, Inc. and Total Employee Solution Support, LLC Answer to the third amended complaint is due 4/19/2023. The deadline for each defendant to answer, file a motion to dismiss or otherwise respond is 4/19/2023. The page limit is expanded to 60 pages for each motion. The deadline for plaintiffs to respond to motions to dismiss or other filings by GB2G, Inc., Allswell, SPJ Connect, Inc., and Mobis Alabama, LLC is extended through and including 5/19/2023. The deadline for plaintiffs to respond is 6/5/2023. The page limit is expanded to 60 pages for each response. The deadline for the defendants to reply is 6/9/2023. The deadline for each defendant to reply to plaintiffs responses to defendants Kia, JKL, and TESSs motions to dismiss as to the Third Amended Complaint is extended through and including 6/26/2023. The page limit is expanded to 30 pages. The Clerk of Court is directed to terminate the motions to dismiss 51 52 and 65 as moot. Signed by Magistrate Judge Russell G. Vineyard on 3/15/2023. (dmb) (Entered: 03/15/2023)

Third AMENDED COMPLAINT against GB2G, Inc., Job Knowledge, LLC, Kia Georgia, Inc., Youngjin Lee, Mobis Alabama, LLC, SPJ Connect, Inc., Total Employee Solution Support, LLCwith Jury Demand filed by Veronica Olan Castillo, Jorge Oswaldo Aquino Martinez, Luis Adrian Salazar Lozano, Jose Maria Ramirez Morales, Aaron Hernan Perez Salazar, Elvis Nahum Cruz Vasquez, Heber Alfonso Zapata Contreras, Isidro Arellano Chihuahua. (Attachments: # 1 TABLE OF EXHIBITS, # 2 Exhibit 1: FLSA Consents to Sue, # 3 Exhibit 2: Jorge Oswaldo Aquino Martinez Offer Letter, # 4 Exhibit 3: Jorge Oswaldo Aquino Martinez Support Letter, # 5 Exhibit 4: Elvis Nahum Cruz Vasquez Meeting Invitation, # 6 Exhibit 5: Elvis Nahum Cruz Vasquez Offer Letter, # 7 Exhibit 6: Elvis Nahum Cruz Vasquez Support Letter, # 8 Exhibit 7: Elvis Nahum Cruz Vasquez Consular Interview Instructions, # 9 Exhibit 8: Heber Alfonso Zapata Contreras Offer Letter, # 10 Exhibit 9: Heber Alfonso Zapata Contreras Support Letter, # 11 Exhibit 10: SPJ Email Attaching Jose Maria Ramirez Morales Offer Letter, # 12 Exhibit 11: SPJ Email to Jose Maria Ramirez Morales Requesting Documents, # 13 Exhibit 12: Jose Maria Ramirez Morales Email to SPJ Providing Documents, # 14 Exhibit 13: Jose Maria Ramirez Morales Offer Letter, # 15 Exhibit 14: Jose Maria Ramirez Morales Support Letter, # 16 Exhibit 15: SPJ Email to Jose Maria Ramirez Morales with Travel Instructions, # 17 Exhibit 16: SPJ Email to Jose Maria Ramirez Morales with Job Instructions, # 18 Exhibit 17: SPJ Email to Jose Maria Ramirez Morales with Housing Instructions, # 19 Exhibit 18: Luis Adrian Salazar Lozano Offer Letter, # 20 Exhibit 19: Luis Adrian Salazar Lozano Support Letter, # 21 Exhibit 20: Luis Adrian Salazar Lozano Consular Interview Instructions, # 22 Exhibit 21: Isidro Arellano Chihuahua SPJ Meeting Announcement and Photographs, # 23 Exhibit 22: Isidro Arellano Chihuahua Offer Letter, # 24 Exhibit 23: Isidro Arellano Chihuahua Support Letter, # 25 Exhibit 24: Isidro Arellano Chihuahua Consular Interview Instructions, # 26 Exhibit 25: Aaron Hernan Perez Salazar Offer Letter, # 27 Exhibit 26: Aaron Hernan Perez Salazar Visa Processing Instructions, # 28 Exhibit 27: Aaron Hernan Perez Salazar Second Offer Letter & Support Letter, # 29 Exhibit 28: Veronica Olan Castillo Offer Letter, # 30 Exhibit 29: Veronica Olan Castillo Support Letter, # 31 Exhibit 30: Plaintiff Chart, RICO Enterprise Chart, and Claims Chart)(Werner, Daniel) Please visit our website at http://www.gand.uscourts.gov/commonly-used-forms to obtain Pretrial Instructions and Pretrial Associated Forms which includes the Consent To Proceed Before U.S. Magistrate form. (Entered: 03/20/2023)

1 TABLE OF EXHIBITS

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2 Exhibit 1: FLSA Consents to Sue

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3 Exhibit 2: Jorge Oswaldo Aquino Martinez Offer Letter

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4 Exhibit 3: Jorge Oswaldo Aquino Martinez Support Letter

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5 Exhibit 4: Elvis Nahum Cruz Vasquez Meeting Invitation

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6 Exhibit 5: Elvis Nahum Cruz Vasquez Offer Letter

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7 Exhibit 6: Elvis Nahum Cruz Vasquez Support Letter

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8 Exhibit 7: Elvis Nahum Cruz Vasquez Consular Interview Instructions

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9 Exhibit 8: Heber Alfonso Zapata Contreras Offer Letter

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10 Exhibit 9: Heber Alfonso Zapata Contreras Support Letter

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11 Exhibit 10: SPJ Email Attaching Jose Maria Ramirez Morales Offer Letter

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12 Exhibit 11: SPJ Email to Jose Maria Ramirez Morales Requesting Documents

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13 Exhibit 12: Jose Maria Ramirez Morales Email to SPJ Providing Documents

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14 Exhibit 13: Jose Maria Ramirez Morales Offer Letter

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15 Exhibit 14: Jose Maria Ramirez Morales Support Letter

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16 Exhibit 15: SPJ Email to Jose Maria Ramirez Morales with Travel Instructions

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17 Exhibit 16: SPJ Email to Jose Maria Ramirez Morales with Job Instructions

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18 Exhibit 17: SPJ Email to Jose Maria Ramirez Morales with Housing Instructions

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19 Exhibit 18: Luis Adrian Salazar Lozano Offer Letter

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20 Exhibit 19: Luis Adrian Salazar Lozano Support Letter

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21 Exhibit 20: Luis Adrian Salazar Lozano Consular Interview Instructions

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22 Exhibit 21: Isidro Arellano Chihuahua SPJ Meeting Announcement and Photographs

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23 Exhibit 22: Isidro Arellano Chihuahua Offer Letter

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24 Exhibit 23: Isidro Arellano Chihuahua Support Letter

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25 Exhibit 24: Isidro Arellano Chihuahua Consular Interview Instructions

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26 Exhibit 25: Aaron Hernan Perez Salazar Offer Letter

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27 Exhibit 26: Aaron Hernan Perez Salazar Visa Processing Instructions

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28 Exhibit 27: Aaron Hernan Perez Salazar Second Offer Letter & Support Letter

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29 Exhibit 28: Veronica Olan Castillo Offer Letter

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30 Exhibit 29: Veronica Olan Castillo Support Letter

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31 Exhibit 30: Plaintiff Chart, RICO Enterprise Chart, and Claims Chart

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Mail Returned as Undeliverable. Mail sent to Kristin Greer Love re 68 Order on Motion for Extension of Time, Order on Motion for Leave to File Excess Pages. (jkb) (Entered: 03/28/2023)

MOTION to Stay Discovery and Pretrial Deadlines with Brief In Support by GB2G, Inc., Youngjin Lee, SPJ Connect, Inc.. (Attachments: # 1 Brief in Support of Defendant Youngjin Lee's Motion to Stay Discovery and Pretrial Deadlines, # 2 Exhibit A-March 20, 2023 Email)(Gibbs, John) (Entered: 03/28/2023)

RESPONSE in Opposition re 76 MOTION to Stay Discovery and Pretrial Deadlines filed by Isidro Arellano Chihuahua, Elvis Nahum Cruz Vasquez, Jorge Oswaldo Aquino Martinez, Veronica Olan Castillo, Aaron Hernan Perez Salazar, Jose Maria Ramirez Morales, Luis Adrian Salazar Lozano, Heber Alfonso Zapata Contreras. (Benjamin, Rachel) (Entered: 04/11/2023)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM with Brief In Support by Mobis Alabama, LLC. (Attachments: # 1 Brief [Memorandum of Law in Support of Partial Motion to Dismiss Plaintiffs' Third Amended Class Action Complaint])(Lucas, Michael) (Entered: 04/18/2023)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM with Brief In Support by Total Employee Solution Support, LLC. (Attachments: # 1 Brief Memo of Law ISO MTD)(Kresser, David) (Entered: 04/19/2023)

MOTION to Dismiss Defendant Job Knowledge LLC's Motion to Dismiss Plaintiffs' Third Amended Class Action Complaint with Brief In Support by Job Knowledge, LLC. (Attachments: # 1 JKL's Memo of Law in Support of its Motion to Dismiss 3rd Amended Complaint)(McKnight, Charles) (Entered: 04/19/2023)

Defendant Youngjin Lee's ANSWER to 74 Amended Complaint by GB2G, Inc., Youngjin Lee, SPJ Connect, Inc..(Gibbs, John) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 04/19/2023)

MOTION to Dismiss Plaintiffs' Third Amended Complaint with Brief In Support by GB2G, Inc., SPJ Connect, Inc.. (Attachments: # 1 Brief Brief in Support of Motion to Dismiss)(Gibbs, John) (Entered: 04/19/2023)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM with Brief In Support by Kia Georgia, Inc.. (Attachments: # 1 Defendant Kia Georgia, Inc.'s Memorandum of Law in Support of its Motion for Partial Dismissal of Plaintiffs' Third Amended Class Action Complaint)(Martin, William) (Entered: 04/19/2023)

Certificate of Interested Persons and Corporate Disclosure Statement by Kia Georgia, Inc. identifying Corporate Parent Kia America, Inc. for Kia Georgia, Inc.. (Martin, William) (Entered: 04/19/2023)

Certificate of Interested Persons and Corporate Disclosure Statement by Total Employee Solution Support, LLC. (Kresser, David) (Entered: 04/20/2023)

Clerk's Notation re 84 Certificate of Interested Persons/Corporate Disclosure Statement, 85 Certificate of Interested Persons/Corporate Disclosure Statement. Reviewed and approved by Chief U.S. District Judge Timothy C. Batten, Sr. (usw)

REPLY BRIEF re 76 MOTION to Stay Discovery and Pretrial Deadlines filed by Youngjin Lee. (Gibbs, John) (Entered: 04/24/2023)