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 MATERN LAW GROUP PC Matthew J. Matern, Bar No. 159798 10 [email protected] Mikael H. Stahle, Bar No. 182599 11 [email protected] Irina A. Kirnosova, Bar No. 312565 12 1230 Rosecrans Avenue, Suite 200 Manhattan Beach, California 90266 13 Telephone: +1.310.531.1900 Facsimile: +1.310.531.1901 14 Attorneys for Plaintiff 15 NATALY LOPEZ VARGAS

16 17 UNITED STATES DISTRICT COURT 18 EASTERN DISTRICT OF CALIFORNIA 19 20 NATALY LOPEZ VARGAS, an individual, on Case No. 1:22-cv-01645-DJC-JDP behalf of herself and all others similarly 21 situated, JOINT STIPULATION FOR DISMISSAL OF ENTIRE ACTION, 22 Plaintiff, INCLUDING PLAINTIFF’S INDIVIDUAL CLAIMS WITH 23 v. PREJUDICE AND PRE- CERTIFICATION CLASS CLAIMS 24 SAPUTO DAIRY FOODS USA, LLC, a WITHOUT PREJUDICE; ORDER Delaware limited liability corporation; and 25 DOES 1 through 10, inclusive, Complaint Filed: November 21, 2022 26 Defendants. 27 28 1 Plaintiff Nataly Lopez Vargas (“Vargas” or “Plaintiff”) and Defendant Saputo Dairy 2 Foods USA, LLC (“Saputo” or “Defendant”) (collectively, the “Parties”), by and through their 3 respective attorneys of record, hereby stipulate to voluntarily dismiss Plaintiff’s entire case, 4 including her individual claims with prejudice and the pre-certification class claims without 5 prejudice and without notice by the Court, pursuant to Rule 41(a)(1)(A)(ii) and Rule 23(e) of the 6 Federal Rules of Civil Procedure. 7 BACKGROUND 8 1. Plaintiff initially filed this putative class and representative action on November 9 21, 2022, in Stanislaus County Superior Court, which Defendant subsequently removed to this 10 Court on December 28, 2022, where it remains pending. In this Action, Plaintiff asserts class 11 claims for alleged (1) failure to provide required meal periods, (2) failure to provide required rest 12 periods, (3) failure to pay overtime wages, (4) failure to pay minimum wages, (5) failure to pay 13 all wages due to discharged and quitting employees, (6) failure to furnish accurate itemized wage 14 statements, (7) failure to maintain required records, (8) failure to indemnify employees for 15 necessary expenditures incurred in discharge of duties, (9) unfair and unlawful business practices, 16 and (10) penalties under the Labor Code Private Attorneys General Act (“PAGA”). 17 2. In addition to the lawsuit filed by Plaintiff, there are four other substantially 18 overlapping class action and representative PAGA action lawsuits involving the same claims on 19 behalf of the same group of current and former employees of Defendant: (1) Psalms Martinez v. 20 Saputo Dairy Foods USA, LLC, U.S.D.C. E.D. Cal. Case No. 1:22-cv-1624-DJC-JDP (“Martinez 21 Class Action”); Psalms Martinez v. Saputo Dairy Foods USA, LLC, Tulare County Superior 22 Court Case No. VCU294960 (“Martinez PAGA Action”); Romero v. Saputo Dairy Foods USA, 23 LLC, Case No. 1:23-cv-00427-DJC-JDP (“Romero Class Action”); and Romero v. Saputo Dairy 24 Foods USA, LLC, Case No. VCU298775 (“Romero PAGA Action”). 25 3. On September 19, 2023, the Parties to this Action, the Martinez Class Action, 26 Martinez PAGA Action, Romero Class Action, and Romero PAGA Action attended a full day 27 private mediation with mediator David Rotman. The Parties reached a global settlement of the 28 1 five actions, and entered into a settlement agreement that was fully executed as of March 14, 2 2024 (“Settlement Agreement”). 3 4. As part of the class action and PAGA representative action settlement, the Tulare 4 Superior Court granted leave to file an amended complaint in the Martinez PAGA Action adding 5 Romero and Vargas as class and PAGA representatives, and incorporating the class and PAGA 6 claims and allegations on behalf of the putative class and aggrieved employees in the five actions 7 into one complaint. All of the claims asserted in this Action were therefore subsumed within the 8 Martinez PAGA Action. 9 5. The Parties sought preliminary and final approval of the global settlement that 10 includes all of the same claims asserted in this action (“Global Settlement”), through the related 11 Martinez PAGA Action. On March 24, 2025, the Martinez Court granted final approval of the 12 Settlement Agreement and entered a Judgment and Order Granting Plaintiffs’ Motion for Final 13 Approval of Class Action and PAGA Settlement (“Judgment”) that disposes of all of the claims 14 asserted in this Action, the Romero PAGA Action, the Martinez Class Action, Martinez PAGA 15 Action, and the Vargas Class/PAGA Action. Attached as Exhibit 1 is a true and correct copy of 16 the Court Judgment. 17 STIPULATION 18 IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS: 19 1. Subject to Court approval, the Parties stipulate that the voluntary dismissal of the 20 entire action, including pre-certification dismissal of class claims without notice by the Court to 21 putative class members, is appropriate because all of the claims asserted in this Action are barred 22 by the doctrines of res judicata and release, based on the final approval granted by the Tulare 23 County Superior Court of the Global Settlement and the Judgment entered in the Martinez PAGA 24 Action. As part of the approval process for the Settlement Agreement, putative class members in 25 the Martinez PAGA Action received notice of the Settlement Agreement consistent with the 26 requirements of due process and had the opportunity to object or opt out of the settlement of the 27 Martinez PAGA Action. In addition, neither Plaintiff nor her attorneys have made any concessions 28 1 with respect to the interests of the putative class in order to further their own interests, and the 2 Parties are unaware of any media attention given to this Action. In this Action, the Parties seek a 3 dismissal with prejudice only as to Plaintiff’s individual claims, and seek a dismissal without 4 prejudice of Plaintiff’s class claims, so no notice to putative class members is required in this Action. 5 See, e.g., Rodriguez v. Nationwide Mut. Ins. Co.,

at *9 (C.D. Cal. 6 Nov. 16, 2017) (class notice not required where potential class members not prejudiced by dismissal 7 of the action). 8 2. The Parties hereby stipulate and request that the Court approve this Stipulation of 9 Dismissal, dismissing Plaintiff’s individual claims with prejudice and the putative class claims 10 without prejudice. In accordance with Rule 23(e), the dismissal of the uncertified class may be 11 approved without notice by the Court to members of the proposed class because the dismissal would 12 not prejudice any putative class members. 13 IT IS SO STIPULATED. 14 15 16 Dated: April 1, 2025 JONES DAY 17 By: /s/ Koree B. Wooley 18 Koree B. Wooley

19 Attorneys for Defendant SAPUTO DAIRY FOODS USA, LLC 20 21 Dated: April 1, 2025 MATERN LAW GROUP PC 22 By: /s/ Mikael H. Stahle (as authorized on 4/1/2025) 23 Mikael H. Stahle Attorneys for Plaintiff NATALY LOPEZ VARGAS 24

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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 11 THE HONORABLE DANIEL J. CALABRETTA UNITED STATES DISTRICT JUDGE 12

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