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`UNITED STATES DISTRICT COURT
`DISTRICT OF NEW JERSEY
`
`ANIBAL MEJIAS, DENNIS MINTER,
`JERRY FULLER, and JOSE PENA, on
`behalf of themselves and those similarly
`situated,
`
`
`Plaintiffs,
`
`
` v.
`
`GOYA FOODS, INC., ROBERT I.
`UNANUE, FRANCISCO R. UNANUE,
`JOSEPH PEREZ, PETER UNANUE,
`DAVID KINKELA, REBECCA
`RODRIGUEZ, CARLOS G. ORTIZ,
`MIGUEL A LUGO, JR., CONRAD
`COLON, JOHN DOES 1 - 10 (said
`names being fictitious, real names
`unknown), ABC COMPANIES 1 - 10
`(said names being fictitious, real names
`unknown),
`
`
`Defendants.
`
`
`No. 3:20-cv-12365-BRM-TJB
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`DEFENDANTS’ NON-OPPOSITION TO PLAINTIFFS’ MOTION
`TO AMEND THE COMPLAINT
`
`
`Ryan T. Warden
`Kevin P. Hishta (pro hac vice)
`Margaret Santen (pro hac vice)
`OGLETREE, DEAKINS, NASH,
`SMOAK & STEWART, P.C.
`10 Madison Avenue, Suite 400
`Morristown, New Jersey 07960
`Tel: (973) 656-1600
`Fax: (973) 656-1611
`Email: ryan.warden@ogletree.com
`
`Attorneys for Defendants
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`Case 3:20-cv-12365-BRM-TJB Document 28 Filed 11/23/20 Page 2 of 2 PageID: 789
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`Defendants do not agree with the factual and jurisdictional allegations in
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`Plaintiffs’ proposed second amended complaint (“PSAC”). Nor do Defendants
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`believe that any of the causes of action in the PSAC have merit. Indeed, Defendants
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`have concurrently filed an opposition to Plaintiffs’ motion to remand and intend to
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`move to dismiss several of the claims in the PSAC. Nonetheless, Defendants have
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`elected to not oppose Plaintiffs’ request to file the PSAC. In doing so, Defendants
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`expressly reserve their rights to challenge the allegations and claims in the PSAC.
`
`Dated: November 23, 2020
` Morristown, New Jersey
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`OGLETREE, DEAKINS, NASH,
`SMOAK & STEWART, P.C.
`
`/s/ Ryan T. Warden
`Ryan T. Warden
`10 Madison Avenue, Suite 400
`Morristown, New Jersey 07960
`Telephone: (973) 656-1600
`Fax: (973) 656-1611
`Email: ryan.warden@ogletree.com
`
`
`Attorneys for Defendants
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`1
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