`
`
`
`Ryan T. Warden
`Kevin P. Hishta (admitted pro hac vice)
`Margaret Santen (admitted pro hac vice)
`OGLETREE, DEAKINS, NASH,
`SMOAK & STEWART, P.C.
`10 Madison Avenue, Suite 400
`Morristown, New Jersey 07960
`ryan.warden@ogletreedeakins.com
`Tel: (973) 656-1600
`Fax: (973) 656-1611
`Attorneys for Defendants Goya Foods, Inc.
`and A.N.E. Service, Inc.
`
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF NEW JERSEY
`
`
`Hon. Stanley R. Chesler, U.S.D.J.
`Civil Action No. 2:19-cv-19003-SRC-CLW
`
`
`
`DEFENDANTS’ NOTICE OF MOTION
`FOR RECONSIDERATION
`
`
`JOSE ORTIZ, SAUL HERNANDEZ, and
`PEDRO URENA, individually and on behalf
`of all others similarly situated,
`
` Plaintiffs,
`
`v.
`
`
`GOYA FOODS, INC. and A.N.E. SERVICES,
`INC.,
`
` Defendants.
`
`:
`:
`:
`:
`:
`:
`:
`:
`:
`:
`:
`:
`:
`
`
`
`
`PLEASE TAKE NOTICE that on October 19, 2020, the undersigned attorneys for
`
`Defendants A.N.E. Service, Inc. (“ANE”) and Goya Foods, Inc. (“GFI”) shall move before the
`
`United States District Court for the District of New Jersey, the Honorable Stanley R. Chesler,
`
`U.S.D.J., for reconsideration of its September 3, 2020 Order denying Defendants’ Motion to
`
`Dismiss Plaintiffs’ First Amended Complaint [D.E. 59], and for entry of an Order partially
`
`dismissing Plaintiffs’ First Amended Complaint, with prejudice.
`
`
`
`PLEASE TAKE FURTHER NOTICE that in support of this application, Defendants
`
`shall rely on the attached Brief.
`
`
`
`
`
`Case 2:19-cv-19003-SRC-CLW Document 64 Filed 09/17/20 Page 2 of 2 PageID: 778
`
`
`
`
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`PLEASE TAKE FURTHER NOTICE that a proposed form of Order is submitted
`
`herewith; and
`
`
`
`PLEASE TAKE FURTHER NOTICE that Defendants respectfully request oral
`
`argument in this matter if opposition is filed.
`
`Respectfully submitted,
`
`OGLETREE, DEAKINS, NASH,
`SMOAK & STEWART, P.C.
`Attorneys for Defendants
`
`
`s/ Ryan T. Warden
`Ryan T. Warden
`
`
`
`
`
`
`
`By:
`
`
`
`
`
`44174962.1
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`
`
`
`
`
`
`Dated: September 17, 2020
`
`
`
`
`
`
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