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`Case 1:20-cv-01690-DAD-JLT Document 78 Filed 06/18/21 Page 1 of 2
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`Mark Selwyn (SBN 244180)
`mark.selwyn@wilmerhale.com
`WILMER CUTLER PICKERING
`HALE AND DORR LLP
`2600 El Camino Real, Suite 400
`Palo Alto, California 94306
`Telephone: (650) 858-6031
`Facsimile: (650) 858-6100
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`Attorney for Plaintiffs
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`IN THE UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF CALIFORNIA
`FRESNO DIVISION
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`UNITED FARM WORKERS and UFW
`FOUNDATION,
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`The National Council of Agricultural Employers and Western Growers Association (“proposed
`intervenors”) waited until June 10, 2021 to seek to intervene in this action—more than six months after
`the complaint was filed, five months after this Court granted a preliminary injunction, and almost five
`months since the Court ordered the U.S. Department of Labor (“DOL)” to notify employers about the
`potential for future wage-adjustment payments. For the reasons stated in plaintiffs’ opposition to
`proposed intervenors’ motion to intervene, intervention should be denied. Accordingly, proposed
`intervenors’ motion to stay should likewise be denied.
`Plaintiffs would be greatly prejudiced by a stay. As plaintiffs have explained, and this Court has
`recognized, the wage adjustment “w[ill] be economically significant for farmworkers toiling for
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`PLS.’ OPP. TO MOT. TO STAY
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`Plaintiffs,
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`THE UNITED STATES DEPARTMENT OF
`LABOR and MARTIN J. WALSH, in his
`official capacity as United States Secretary of
`Labor,
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`Defendants.
`
`Case No. 1:20-cv-01690-DAD-JLT
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`PLAINTIFFS’ OPPOSITION TO
`PROPOSED INTERVENORS’ MOTION
`TO STAY
`Hearing On Motion
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`Date: June 22, 2021
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`Time: 1:30 p.m.
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`Before: Judge Dale A. Drozd
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`Case 1:20-cv-01690-DAD-JLT Document 78 Filed 06/18/21 Page 2 of 2
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`subsistence wages and for their families, who are already forced to choose between necessities.” ECF
`No. 48 at 13; see also ECF No. 58 at 11. Delaying this relief will cause needless harm to these
`farmworkers. For these reasons, plaintiffs respectfully request that the Court deny proposed intervenors’
`motion to stay proceedings in this case.1
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`Dated: June 18, 2021
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`/s/ Mark Selwyn
`MARK SELWYN (SBN 244180)
`Wilmer Cutler Pickering Hale and Dorr LLP
`
`Attorney for Plaintiffs
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`By:
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`1 Plaintiffs note that proposed intervenors’ motion to stay may be moot due to the Court’s sua sponte
`stay. See ECF No. 74 at 7. To the extent proposed intervenors’ motion to stay is still pending, plaintiffs
`formally state their opposition to the motion.
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`PLS.’ OPP. TO MOT. TO STAY
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