1 JONES DAY Koree B. Wooley, Bar No. 294489 2 [email protected] Cindi L. Ritchey, Bar No. 216899 3 [email protected] Jayce E. Gustafson, Bar No. 344961 4 [email protected] 4655 Executive Drive 5 Suite 1500 San Diego, California 92121.3134 6 Telephone: +1.858.314.1200 Facsimile: +1.844.345.3178 7 Attorneys for Defendant 8 SAPUTO DAIRY FOODS USA, LLC

9 WILSHIRE LAW FIRM Benjamin H. Haber, Bar No. 315664 10 [email protected] Daniel J. Kramer, Bar No. 314625 11 [email protected] 3055 Wilshire Blvd., 12th Floor 12 Los Angeles, California 90010 Telephone: +1.213.381.9988 13 Facsimile: +1.213.381.9989

14 Attorneys for Plaintiff PSALMS MARTINEZ 15 16 UNITED STATES DISTRICT COURT 17 EASTERN DISTRICT OF CALIFORNIA 18 19 PSALMS MARTINEZ, individually, and on Case No. 1:22-cv-01624-DJC-JDP 20 behalf of all others similarly situated, JOINT STIPULATION FOR 21 Plaintiff, DISMISSAL OF ENTIRE ACTION, INCLUDING PLAINTIFF’S 22 v. INDIVIDUAL CLAIMS WITH PREJUDICE AND PRE- 23 SAPUTO DAIRY FOODS USA, LLC, a CERTIFICATION CLASS CLAIMS Delaware limited liability corporation; and WITHOUT PREJUDICE; ORDER 24 DOES 1 through 10, inclusive, Complaint Filed: October 31, 2022 25 Defendants. 26

27 Plaintiff Psalms Martinez (“Martinez” or “Plaintiff”) and Defendant Saputo Dairy Foods 28 1 USA, LLC (“Saputo” or “Defendant”) (collectively, the “Parties”), by and through their 2 respective attorneys of record, hereby stipulate to voluntarily dismiss Plaintiff’s entire case, 3 including her individual claims with prejudice and the pre-certification class claims without 4 prejudice and without notice by the Court, pursuant to Rule 41(a)(1)(A)(ii) and Rule 23(e) of the 5 Federal Rules of Civil Procedure. 6 BACKGROUND 7 1. Plaintiff initially filed this putative class action on October 31, 2022, in Tulare 8 County Superior Court, which Defendant subsequently removed to this Court on December 19, 9 2022, where it remains pending. In this Action, Plaintiff asserts class claims for alleged (1) failure 10 to pay minimum and straight time wages, (2) failure to pay overtime wages, (3) failure to provide 11 meal periods, (4) failure to authorize and permit rest periods, (5) failure to timely pay final wages 12 at termination, (6) failure to provide accurate itemized wage statements, (8) failure to indemnify 13 employees for expenditures, and (9) unfair business practices. 14 2. In addition to the lawsuit filed by Plaintiff, there are four other substantially 15 overlapping class action and representative PAGA action lawsuits involving the same claims on 16 behalf of the same group of current and former employees of Defendant: (1) Psalms Martinez v. 17 Saputo Dairy Foods USA, LLC, Tulare County Superior Court Case No. VCU294960 (“Martinez 18 PAGA Action”); Romero v. Saputo Dairy Foods USA, LLC, Case No. 1:23-cv-00427-DJC-JDP 19 (“Romero Class Action”); Romero v. Saputo Dairy Foods USA, LLC, Case No. VCU298775 20 (“Romero PAGA Action”); and Nataly Lopez Vargas v. Saputo Dairy Foods USA, LLC, U.S.D.C. 21 E.D. Cal. Case No. 1:22-cv-1645- DJC-JDP (“Vargas Class/PAGA Action”) 22 3. On September 19, 2023, the Parties to this Action, the Martinez PAGA Action, 23 Romero Class Action, Romero PAGA Action, and Vargas Class/PAGA Action attended a full 24 day private mediation with mediator David Rotman. The Parties reached a global settlement of 25 the five actions, and entered into a settlement agreement that was fully executed as of March 14, 26 2024 (“Settlement Agreement”).

27 /// 28 1 4. As part of the class action and PAGA representative action settlement, the Tulare 2 Superior Court granted leave to file an amended complaint in the Martinez PAGA Action adding 3 Romero and Vargas as class and PAGA representatives, and incorporating the class and PAGA 4 claims and allegations on behalf of the putative class and aggrieved employees in the five actions 5 into one complaint. All of the claims asserted in this Action were therefore subsumed within the 6 Martinez PAGA Action. 7 5. The Parties sought preliminary and final approval of the global settlement that 8 includes all of the same claims asserted in this action (“Global Settlement”), through the related 9 Martinez PAGA Action. On March 24, 2025, the Martinez Court granted final approval of the 10 Settlement Agreement and entered a Judgment and Order Granting Plaintiffs’ Motion for Final 11 Approval of Class Action and PAGA Settlement (“Judgment”) that disposes of all of the claims 12 asserted in this Action, the Romero PAGA Action, the Martinez Class Action, Martinez PAGA 13 Action, and the Vargas Class/PAGA Action. Attached as Exhibit 1 is a true and correct copy of 14 the Court Judgment. 15 STIPULATION 16 IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS: 17 Subject to Court approval, the Parties stipulate that the voluntary dismissal of the entire 18 action, including pre-certification dismissal of class claims without notice by the Court to putative 19 class members, is appropriate because all of the claims asserted in this Action are barred by the 20 doctrines of res judicata and release, based on the final approval granted by the Tulare County 21 Superior Court of the Global Settlement and the Judgment entered in the Martinez PAGA Action. 22 As part of the approval process for the Settlement Agreement, putative class members in the 23 Martinez PAGA Action received notice of the Settlement Agreement consistent with the 24 requirements of due process and had the opportunity to object or opt out of the settlement of the 25 Martinez PAGA Action. In addition, neither Plaintiff nor his attorneys have made any concessions 26 with respect to the interests of the putative class in order to further their own interests, and the 27 Parties are unaware of any media attention given to this Action. In this Action, the Parties seek a 28 1 dismissal with prejudice only as to Plaintiff’s individual claims, and seek a dismissal without 2 prejudice of Plaintiff’s class claims, so no notice to putative class members is required in this 3 Action. See, e.g., Rodriguez v. Nationwide Mut. Ins. Co.,

at *9 4 (C.D. Cal. Nov. 16, 2017) (class notice not required where potential class members not prejudiced 5 by dismissal of the action). 6 The Parties hereby stipulate and request that the Court approve this Stipulation of Dismissal, 7 dismissing Plaintiff’s individual claims with prejudice and the putative class claims without 8 prejudice. In accordance with Rule 23(e), the dismissal of the uncertified class may be approved 9 without notice by the Court to members of the proposed class because the dismissal would not 10 prejudice any putative class members. 11 IT IS SO STIPULATED. 12 13 Dated: March 31, 2025 JONES DAY 14 By: /s/ Koree B. Wooley 15 Koree B. Wooley

16 Attorneys for Defendant SAPUTO DAIRY FOODS USA, LLC 17

18 Dated: March 31, 2025 WILSHIRE LAW FIRM

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By: /s/ Daniel J. Kramer 20 Benjamin H. Haber 21 Daniel J. Kramer Attorneys for Plaintiff PSALMS MARTINEZ 22

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28 1 ORDER 2 Having considered the Joint Stipulation between all Parties, and good cause appearing, 3 IT IS ORDERED as follows: 4 1. All of Plaintiff’s individual claims are dismissed with prejudice. The putative 5 class claims, which have not been certified, are dismissed without prejudice; 6 2. The dismissal of the uncertified class claims is approved without notice by the 7 Court to members of the proposed class; and 8 3. This Action is hereby dismissed in its entirety. 9

10 Dated: April 4, 2025 /s/ Daniel J. Calabretta THE HONORABLE DANIEL J. CALABRETTA 11 UNITED STATES DISTRICT JUDGE

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