1 Norman B. Blumenthal, Bar No. 068687 [email protected] 2 Kyle R. Nordrehaug, Bar No. 205975 3 [email protected] Aparajit Bhowmik, Bar No. 248066 4 [email protected] Jeffrey S. Herman, Bar No. 280058 5 [email protected] Sergio J. Puche, Bar No. 289437 6 [email protected] 7 2255 Calle Clara La Jolla, California 92037 8 Telephone: +1.858.551.1223 Facsimile: +1.858.551.1232 9 Attorneys for Plaintiff JUAN ROMERO 10 JONES DAY 11 Koree B. Wooley, Bar No. 294489 [email protected] 12 Cindi L. Ritchey, Bar No. 216899 [email protected] 13 Jayce E. Gustafson, Bar No. 344961 [email protected] 14 4655 Executive Drive, Suite 1500 San Diego, California 92121.3134 15 Telephone: +1.858.314.1200 Facsimile: +1.844.345.3178 16 Attorneys for Defendant 17 SAPUTO DAIRY FOODS USA, LLC

18 UNITED STATES DISTRICT COURT 19 EASTERN DISTRICT OF CALIFORNIA 20 21 JUAN ROMERO, individually, and on behalf Case No. 1:23-cv-00427-DJC-JDP of all others similarly situated, 22 JOINT STIPULATION FOR Plaintiff, DISMISSAL OF ENTIRE ACTION, 23 INCLUDING PLAINTIFF’S v. INDIVIDUAL CLAIMS WITH 24 PREJUDICE AND PRE- SAPUTO DAIRY FOODS USA, LLC, a CERTIFICATION CLASS CLAIMS 25 Delaware limited liability corporation; and WITHOUT PREJUDICE; ORDER DOES 1 through 10, inclusive, 26 Complaint Filed: February 2, 2023 Defendants. 27 28 1 Plaintiff Juan Romero (“Romero” or “Plaintiff”) and Defendant Saputo Dairy Foods USA, 2 LLC (“Saputo” or “Defendant”) (collectively, the “Parties”), by and through their respective 3 attorneys of record, hereby stipulate to voluntarily dismiss Plaintiff’s entire case, including his 4 individual claims with prejudice and the pre-certification class claims without prejudice and 5 without notice by the Court, pursuant to Rule 41(a)(1)(A)(ii) and Rule 23(e) of the Federal Rules 6 of Civil Procedure. 7 BACKGROUND 8 1. Plaintiff initially filed this putative class action on February 3, 2023, in Merced 9 County Superior Court, which Defendant subsequently removed to this Court on March 22, 2023, 10 where it remains pending. In this Action, Plaintiff asserts class claims for alleged (1) unfair 11 competition, (2) unpaid minimum wages, (3) unpaid overtime wages, (4) meal period violations, 12 (5) rest period violations, (6) wage statement violations, (7) unreimbursed business expenses, and 13 (8) failure to pay sick wages. Plaintiff seeks to represent a class consisting of all nonexempt 14 California employees of Defendant. 15 2. Plaintiff later filed a PAGA-only lawsuit on June 1, 2023, in Tulare Superior Court, 16 entitled Romero v. Saputo Dairy Foods USA, LLC, Case No. VCU298775 (“Romero PAGA 17 Action”), asserting claims for civil penalties based on alleged violations of Labor Code §§ 201- 18 204, 210, 221, 226, 226.7, 227.3, 246, 510, 512, 558, 1194, 1197, 1197.1, 1198, 2802, and the 19 applicable IWC Wage Orders, including provisions pertaining to reporting time pay and suitable 20 seating. The Romero PAGA Action is based on substantially the same factual allegations and seeks 21 relief on behalf of the same group of individuals as the instant Action. 22 3. In addition to the two lawsuits filed by Plaintiff, there are three other substantially 23 overlapping class action and representative PAGA action lawsuits involving the same claims on 24 behalf of the same group of current and former employees of Defendant: (1) Psalms Martinez v. 25 Saputo Dairy Foods USA, LLC, U.S.D.C. E.D. Cal. Case No. 1:22-cv-1624-DJC-JDP (“Martinez 26 Class Action”); Psalms Martinez v. Saputo Dairy Foods USA, LLC, Tulare County Superior Court 27 Case No. VCU294960 (“Martinez PAGA Action”); and Nataly Lopez Vargas v. Saputo Dairy 28 1 Foods USA, LLC, U.S.D.C. E.D. Cal. Case No. 1:22-cv-1645- DJC-JDP (“Vargas Class/PAGA 2 Action”). 3 4. On September 19, 2023, the Parties to this Action, the Romero PAGA Action, the 4 Martinez Class Action, Martinez PAGA Action, and Vargas Class/PAGA Action attended a full 5 day private mediation with mediator David Rotman. The Parties reached a global settlement of the 6 five actions, and entered into a settlement agreement that was fully executed as of March 14, 2024 7 (“Settlement Agreement”). 8 5. As part of the class action and PAGA representative action settlement, the Tulare 9 Superior Court granted leave to file an amended complaint in the Martinez PAGA Action adding 10 Romero and Vargas as class and PAGA representatives, and incorporating the class and PAGA 11 claims and allegations on behalf of the putative class and aggrieved employees in the five actions 12 into one complaint. All of the claims asserted in this Action were therefore subsumed within the 13 Martinez PAGA Action. 14 6. The Parties sought preliminary and final approval of the global settlement that 15 includes all of the same claims asserted in this action (“Global Settlement”), through the related 16 Martinez PAGA Action. On March 24, 2025, the Martinez Court granted final approval of the 17 Settlement Agreement and entered a Judgment and Order Granting Plaintiffs’ Motion for Final 18 Approval of Class Action and PAGA Settlement (“Judgment”) that disposes of all of the claims 19 asserted in this Action, the Romero PAGA Action, the Martinez Class Action, Martinez PAGA 20 Action, and the Vargas Class/PAGA Action. Attached as Exhibit 1 is a true and correct copy of the 21 Court Judgment. 22 STIPULATION 23 IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS: 24 1. Subject to Court approval, the Parties stipulate that the voluntary dismissal of the 25 entire action, including pre-certification dismissal of class claims without notice by the Court to 26 putative class members, is appropriate because all of the claims asserted in this Action are barred 27 by the doctrines of res judicata and release, based on the final approval granted by the Tulare 28 County Superior Court of the Global Settlement and the Judgment entered in the Martinez PAGA 1 Action. As part of the approval process for the Settlement Agreement, putative class members in 2 the Martinez PAGA Action received notice of the Settlement Agreement consistent with the 3 requirements of due process and had the opportunity to object or opt out of the settlement of the 4 Martinez PAGA Action. In addition, neither Plaintiff nor his attorneys have made any concessions 5 with respect to the interests of the putative class in order to further their own interests, and the 6 Parties are unaware of any media attention given to this Action. In this Action, the Parties seek a 7 dismissal with prejudice only as to Plaintiff’s individual claims, and seek a dismissal without 8 prejudice of Plaintiff’s class claims, so no notice to putative class members is required in this Action. 9 See, e.g., Rodriguez v. Nationwide Mut. Ins. Co.,

at *9 (C.D. Cal. 10 Nov. 16, 2017) (class notice not required where potential class members not prejudiced by dismissal 11 of the action). 12 2. The Parties hereby stipulate and request that the Court approve this Stipulation of 13 Dismissal, dismissing Plaintiff’s individual claims with prejudice and the putative class claims 14 without prejudice. In accordance with Rule 23(e), the dismissal of the uncertified class may be 15 approved without notice by the Court to members of the proposed class because the dismissal would 16 not prejudice any putative class members. 17 IT IS SO STIPULATED. 18 19 Dated: March 31, 2025 JONES DAY 20 By: /s/ Koree B. Wooley 21 Koree B. Wooley

22 Attorneys for Defendant SAPUTO DAIRY FOODS USA, LLC 23 Dated: March 31, 2025 24 BLUMENTHAL NORDREHAUG BHOWMIK DE BLOUW, LLP 25 26 By: /s/ Sergio J. Puche (as authorized on 3/31/25) Jeffrey S. Herman 27 Sergio J. Puche 28 Attorneys for Plaintiff JUAN ROMERO 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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