NOTICE OF RELATED ACTIONS- 1 Cairncross & Hempelmann, P.S.

Law Offices

524 Second Avenue, Suite 500

Seattle, Washington 98104-2323

Phone: 206-587-0700 · Fax: 206-587-2308

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Hon. MARY ALICE THEILER

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON AT SEATTLE

HUGO MARTIN RECINOS-RECINOS, et al.,

Plaintiff,

v.

EXPRESS FORESTRY, INC., et al.,

Defendant.

NO. C06-307MAT

NOTICE OF RELATED ACTIONS

Two actions are pending before this Court that are related and should be considered 

together. The two matters are Hugo Martin Recinos-Recinos, et al. v. Express Forestry, Inc., et 

al, Cause Number C06-307MAT, and Escolastico de Leon-Granados, et al. v. Eller and Sons 

Tress, Inc, et al., Cause Number 06-306P. Both of these actions arise in the same context: 

pending in two Federal District Courts (one in the Northern District of Georgia and one in the 

Eastern District of Louisiana) are claims by various Plaintiff migrant agricultural workers 

challenging wage and hour practices of their employers, Defendant agricultural labor contractors 

including Eller and Sons Trees, Inc. and Express Forestry, Inc. 

Seattle-based Plum Creek Timber Co., Inc. (“Plum Creek”) contracted with agricultural 

labor contractors including Eller and Sons Trees, Inc. and Express Forestry, Inc. to provide 

certain agricultural services on its timber land holdings. Eller and Sons Trees, Inc. and Express 

Forestry, Inc. allegedly hired Plaintiffs to perform work on some of such contracts and 
NOTICE OF RELATED ACTIONS- 2 Cairncross & Hempelmann, P.S.

Law Offices

524 Second Avenue, Suite 500

Seattle, Washington 98104-2323

Phone: 206-587-0700 · Fax: 206-587-2308

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purportedly failed to compensate them properly. Plaintiffs are seeking extensive document 

discovery from Plum Creek. The two matters in this Court are Motions to Compel Discovery 

brought by the Plaintiffs against Plum Creek. The parties have filed virtually identical materials 

in each matter, and the matters raise the same legal issues. 

Originally, both matters were assigned to Judge Martinez. However, after Plum Creek 

filed its Responses in Opposition to Plaintiffs’ Motion to Enforce Subpoena Duces Tecum, the 

first of these two actions, Cause Number 06-306P, was reassigned to Judge Pechman, and the 

second, Cause Number C06-307MAT, was reassigned to Magistrate Theiler.1 Because these two 

actions are related, and in fact are virtually identical matters, Third-Party Plum Creek hereby 

notifies the Court of their relatedness so that the actions can be assigned to a single Judge of this 

Court for consideration in accordance with this Court’s Local Rules and operating procedures.

Dated this 10th day of March, 2006 at Seattle, Washington. 

CAIRNCROSS & HEMPELMANN, P.S.

/s/ Rosemary Daszkiewicz

Rosemary Daszkiewicz, WSBA No. 16260

Attorneys for Third-Party Plum Creek Timber 

Company, Inc.

TROUTMAN SANDERS LLP

Robert H. Buckler, GA Bar No. 092650

Pro Hac Vice

Evan H. Pontz, GA Bar No. 583577

Pro Hac Vice

5200 Bank of America Plaza

600 Peachtree Street NE

Atlanta, GA 30308

 

1

It also appears that the Court has mistakenly classified Cause Number C06-307MAT, Hugo Martin RecinosRecinos, et al. v. Express Forestry, Inc., et al., as a new lawsuit, because Judge Theiler has issued the standard new 

case scheduling order. See Docket No. 7.
NOTICE OF RELATED ACTIONS- 3 Cairncross & Hempelmann, P.S.

Law Offices

524 Second Avenue, Suite 500

Seattle, Washington 98104-2323

Phone: 206-587-0700 · Fax: 206-587-2308

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Certificate of Service

I, Marian C. DiPerna, certify under penalty of perjury of the laws of the State of Washington 

that, on March 9, 2006, I caused copies of this Notice of Related Actions to be served via 

CM/ECF electronic notification, with notification sent to the following parties: 

Nicholas Broten Straley nick.straley@columbialegal.org

Andrew H Turner aturner@splcenter.org

Kristi Graunke kgraunke@splcenter.org

Dated this 10th day of March, 2006 at Seattle, Washington.

/s/ Marian C. DiPerna

Marian C. DiPerna, Legal Assistant