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`JUSTIN GARNER
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`vs.
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`JBS LIVE PORK, LLC
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`IN THE UNITED STATES DISTRICT COURT
`WESTERN DISTRICT
`TEXARKANA DIVISION
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`Case No ________
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`COMPLAINT
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`PLAINTIFF
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`DEFENDANT
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`COMES NOW, the Plaintiff, by and through his counsel, and for his Complaint states as
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`follows:
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`PARTIES, JURISDICTION AND VENUE
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`Justin Garner is an adult resident and citizen of Howard County, Arkansas.
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`JBS USA Food Company is one of the world’s largest beef and pork processing
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`1.
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`2.
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`companies and a wholly owned subsidiary of JBS USA Food Company Holdings. JBS is one of
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`the world’s largest food companies with operations in 15 countries, including the U.S. It is the
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`second largest pork producer in the world, with operations in the United States, Brazil, the United
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`Kingdom and Australia. Defendant JBS Live Pork, LLC is a subsidiary of JBS USA Food
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`Company. JBS Live Pork, LLC (“JBS”) is a Delaware limited liability company, which is a
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`subsidiary of JBS USA Food Company. JBS’s principal place of business is 151 N. Main Street,
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`Wichita, Kansas 67202. JBS is a citizen of Delaware and Kansas. JBS is registered to do business
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`in Arkansas and its agent for service of process is the Corporation Service Company, 300 South
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`Spring Street, Suite 900, Little Rock, Arkansas 72201.
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`3.
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`The Court has jurisdiction over this lawsuit under 28 U.S.C. § 1332(a)(1) because
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`Garner and JBS are citizens of different U.S. states, and the amount in controversy exceeds
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`$75,000, excluding interest and costs. Venue is proper in this district under 28 U.S.C. § 1391(b)(2)
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 2 of 18 PageID #: 6
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`because a substantial part of the events or omissions giving rise to Garner’s claims occurred in this
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`district.
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`4.
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`Garner has standing under Article III of the U.S. Constitution because he has
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`suffered a concrete, monetary harm caused by JBS’s conduct described herein.
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`JBS’ contracting procedures with individual farmers
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`JBS employs vertical integration to supply pork to the marketplace.
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`Hog farming has changed drastically over the last 30 years. Instead of thousands of
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`5.
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`6.
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`independent family farms, hogs are now “being raised in concentrated animal feeding operations
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`(CAFOs) — huge barns holding thousands of animals.” 1
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`7.
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`“The auction houses (where the bidding of multiple buyers formerly ensured
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`farmers a fair price) have been replaced by contracts, under which farmers raise animals for a large
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`pork company according to strict specifications, and for prices they have little say in
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`determining.”2
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`8.
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` Farmers who wish to produce pigs for JBS must use concentrated animal feeding
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`operations (factory farms) which comply with JBS’ various requirements.
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`9.
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`JBS requires farmers to enter into adhesion contracts which subject the farmers to
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`strict specifications that benefit JBS.
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`10.
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` Recent litigation involving JBS reveals that the pork industry is horizontally
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`concentrated because only a few companies buy, slaughter and process the majority of hogs.3
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`1 FoodPrint, October 30, 2020. https://foodprint.org/issues/communities-organizing-against-big-
`pork/
`2 Id.
`3 In Re Pork Antitrust Litigation, 2019 WL 3752497, 2019 U.S. Dist. LEXIS 133165 (D.C.
`Minn., Aug. 8, 2019).
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 3 of 18 PageID #: 7
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`11.
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`JBS and three other companies control an almost 70 percent of the U.S. pork
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`industry.4 The largest pork integrators, like JBS, “do not produce their own pigs but instead enter
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`into contracts with independent farmers who raise the pigs until they are ready to be slaughtered.”5
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`12.
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`“Because most of the hogs produced in the U.S. are sold under a multi-year
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`contract, it is difficult for any potential competitor to find pigs to purchase.”6
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`13.
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`“In 2015, JBS acquired Cargill's pork business, combining the third-and fourth-
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`largest pork producers into the second-largest producer.”7
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`14.
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`In 2018, several antitrust class actions against JBS and other pork producers were
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`consolidated for pretrial purposes. The plaintiffs in those cases alleged that the JBS and others
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`“conspired or colluded to artificially raise, fix, or maintain prices in the pork market in violation
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`of federal antitrust laws.”8
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`15.
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`Plaintiffs alleged that JBS had conspired in restraint of trade, the purpose of which
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`was to suppress competition and to allow it and other pork producers to charge supra-competitive
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`prices for pork products in violation of state and federal laws.9
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`16.
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`Among other things, plaintiffs alleged that part of JBS’ scheme was that “JBS
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`undertook an unspecified reduction in the number of sows it produced despite increased consumer
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`demand."10
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`4 Id.
`5 Id.
`6 Id. (internal quotations omitted).
`7 In re Pork Antitrust Litig., 495 F. Supp. 3d 753, (D.C. Minn. October 16, 2020).
`8 In re Pork Antitrust Litig., 2019 U.S. Dist. LEXIS 20038, 2019 WL 480518 (D. Minn., Feb. 7,
`2019)
`9 http://porkcommercialcase.com/
`10 495 F. Supp. 3d 753 (D.C. Minn. October 16, 2020).
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 4 of 18 PageID #: 8
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`17.
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`The plaintiffs also alleged that JBS decreased overall production which led to
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`increased prices for their products.11
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`18.
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` Last year, while denying liability, JBS agreed to pay $12,750,000 to settle those
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`claims.12
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`19.
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`JBS’ arrangement with farmers like the Plaintiff involves contracts which are
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`extremely favorable to JBS. Farmers are provided with term contracts, drafted by JBS, through
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`which the farmers are paid a set price for animals which they ship during the contract period. JBS
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`establishes the requirements for the physical facilities of the farming operation and farmers like
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`the Plaintiff are saddled with providing the labor and expense of owning and operating the facility
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`and must assume total responsibility for the financing, maintenance and insurance of the farm.
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`The farmers are also fully responsible for the livestock and the enormous waste produced by the
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`animals. JBS dictates the requirements for the farm’s day-to-day operation, the conditions for
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`animals’ care, feeding and medications and the transportation of the animals while the farmers are
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`merely paid a set sum, determined by JBS, for marketable animals that are ultimately shipped to
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`another location.
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`20.
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`Under this business model, independent farmers are essentially converted into
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`contract employees who merely perform work for JBS. Despite bearing the entire investment costs
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`11 In Re Pork Antitrust Litigation, 2019 WL 3752497, 2019 U.S. Dist. LEXIS 133165 (D.C.
`Minn., Aug. 8, 2019).
`12 http://porkcommercialcase.com/ . Also, just last month, JBS confirmed that it had approved a
`$52.5 million settlement in a lawsuit in which the company was accused of conspiring to fix beef
`prices. https://www.meatpoultry.com/articles/26147-jbs-usa-agrees-to-525-million-settlement-in-
`price-fixing-lawsuit.
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 5 of 18 PageID #: 9
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`of a farming facility, the farmers are only paid a set cost per pig as established by JBS. Meanwhile,
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`JBS retains control over the production processes and the amount of production.
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`21.
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`Even under perfect conditions, many farmers are barely able to generate enough
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`revenue under these term contracts to pay their expenses. In this case, JBS unilaterally terminated
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`Garner’s contract two years before the end of the contract term and refused to pay him for the
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`animals it removed.
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`JBS’ dealings with Justin Garner
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`22. In late 2017, Garner was working as a deputy-sheriff for the Howard County Sheriff’s
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`office and also operated a family farm.
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`23. In late 2017, Garner considering the purchase of an existing hog farm facility in
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`Howard County, Arkansas. The facility, which was being used to produce pigs for JBS, was
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`located on a forty-acre tract of property.
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`24. The facility had no value as a hog farm unless JBS agreed to give Garner a production
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`contract.
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`25. JBS advised Garner that it would provide him a contract if he purchased the subject
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`hog farm.
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`26. In November, 2017, JBS supplied Garner with a Letter of Intent as evidence of its
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`commitment to provide him a production contract for a five-year term. Exhibit 1.
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`27. Garner, and his lender, relied on this Letter of Intent in connection with Garner’s efforts
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`to secure the financing necessary to buy the facility.
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`28. Garner relied on JBS’ representations and purchased the hog farm facility.
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`29. After he borrowed money and purchased the farm, JBS entered into a Sow Production
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`Agreement (“contract”) with him in March, 2018. Exhibit 2.
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 6 of 18 PageID #: 10
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`30. JBS established the contract term for a period of five years, through March 14, 2023.
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`Then, if the contract was not terminated by either party, it would continue on a three-year evergreen
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`term.
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`31. Among other things, this astonishingly one-sided contract provided that JBS would
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`supply Garner with 575 gilts and sows. Then, it agreed to pay him a certain sum for each piglet
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`shipped from his farm
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`32. In exchange, the contract (Exhibit 2) required Garner to:
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`Provide and maintain the hog farm facility at his own expense.
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`Provide all equipment required to breed, feed, water and care for the pigs.
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`Pay all maintenance, repairs, utilities and insurance on the facility.
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`Provide all labor.
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`Monitor pig and breeding stock health.
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`Manage the breeding stock and offspring.
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`Manage the animals’ breeding.
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`Follow JBS’ feeding and management policies.
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`Dispose of all waste and manure.
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`Obtain and maintain a “Nutrient Management Plan,” that complied with all federal,
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`state and local laws (a/k/a, a reservoir for the massive amounts of manure produced by JBS’
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`animals).
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`and internet.
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`Dispose of dead animals.
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`Euthanize defective animals.
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`Maintain communication equipment, including an answering machine, computer
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`Load and unload pigs brought to or taken from the facility.
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`Maintain adequate roads to and from the facility.
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`Provide and maintain feeding systems and pig loading equipment.
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`Maintain daily, weekly and monthly records.
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`Subscribe to production record systems as directed by JBS.
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`Allow JBS’ representatives to enter and inspect the facility.
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`Protect the pigs from mortgage, lien or financial encumbrance.
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`Indemnify JBS from claims.
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`Participate in environmental training.
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`Furnish JBS with proof of liability insurance.
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`Be responsible for workers compensation, unemployment, disability and health
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`insurance for himself and any of his workers.
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`Make sure that all pigs meet JBS’ specifications, which required that animals be
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`castrated, tattooed and have docked tails and that the animals not have lice, mange or skin lesions
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`or be wounded, unthrifty, lame, stiff, coughing or anemic.
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`Maintain automatic curtains and ventilation systems, operational flush systems
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`capable of removing animal waste, operational feed delivery systems, and maintain gates, stalls,
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`walls and panels.
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`Pay for any capital investments.
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`Not become bankrupt.
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`33. In addition to saddling Garner with all of these obligations, JBS disclaimed any
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`warranties with respect to feed or supplies delivered, disclaimed any warranties as to the health of
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 8 of 18 PageID #: 12
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`any pigs it delivered to Garner and disclaimed any warranties as to Garner’s profitability.
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`34. While these terms make the contract incredibly one-sided, JBS did not end there. The
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`agreement also declares that JBS reserves “the unilateral right to amend, revise, or eliminate any
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`standard,
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`requirement or policy
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`identified
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`in
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`this Agreement.” Exhibit 2, p. 17.
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`35. Thus, at any point, the agreement purported to allow JBS to delete or amend any
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`provision,
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`including changing
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`the amount
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`it owed Garner
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`for his performance.
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`36. From March, 2018 to November, 2021, Garner complied with the terms of the contract
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`and produced pigs for JBS.
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`37. At no time did Garner breach any terms of the parties’ contract.
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`38. Early in the parties’ dealings, JBS representatives implored Garner to resign as a
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`deputy-sheriff so that he could devote more time to the operation of the hog farm.
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`39. While still maintaining his job as a deputy-sheriff, Garner worked at the farm every
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`day and also employed two persons who worked at the farm on a full-time basis.
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`40. Garner believed that he could effectively manage the farm while maintaining his
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`employment at the sheriff’s office. However, as a result of JBS’ repeated requests, he eventually
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`gave up his position with the sheriff’s office in September, 2021.
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`41. After resigning his deputy-sheriff job, Garner began spending more time working at
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`the hog farm facility and continued to employ two full-time workers.
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`42. During the course of the parties’ dealings, JBS failed to comply with several provisions
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`of the agreement.
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`43. In 2021, JBS unilaterally changed the weight specifications for pigs shipped from the
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`farm. After changing these amounts, JBS began to “dock” Garner $5 per pig for any pig that was
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 9 of 18 PageID #: 13
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`under eight pounds at the time of shipping. This change, which was a deviation from the Sow
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`Production Agreement, caused Garner to suffer thousands of dollars in financial loss.
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`44. There were several times during the term of the contract when JBS failed to provide
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`Garner with gilts. This failure negatively impacted Garner’s ability to produce under the contract
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`and caused him thousands of dollars in damages.
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`45. In September, 2021, JBS advised Garner that he would not be receiving any gilts
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`because the gilts had all been sent to market due to delta coronavirus. JBS further advised Garner
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`that he would not receive any compensation whatsoever as a result of JBS’ failure to provide the
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`gilts. As a direct result of JBS’ failure, this action cost Garner a minimum of $5,405.00.
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`46. During the first week of November, 2021, JBS representatives called Garner and told
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`him that they were going to be in the area and wanted to drop by his farm to see him. Garner was
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`out of town at the time, but advised the JBS representatives that he would be back at the farm on
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`November 8, 2021.
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`47. On November 8, 2021, JBS representatives arrived at his farm and told him that JBS
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`was terminating his contract.
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`48. Prior to November, 2021, Garner had no reason to believe that JBS intended to cancel
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`his contract.
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`49. The JBS representatives provided Garner with a document and told him he had to sign
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`it.
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`50. Before signing the document, Garner requested additional time so that he could
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`properly review the document and seek consultation from others.
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`51. In response, the JBS representatives told Garner that he had to sign the document on
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`November 8, 2021, in their presence.
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 10 of 18 PageID #: 14
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`52. The JBS representatives told Garner that, if he signed the document, he would receive
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`pay for the remaining batches of piglets from his farm but, if he refused to sign the document on
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`November 8, 2021 in the presence of the JBS representatives, JBS would not provide him any
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`payment of any kind.
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`53. Garner did not sign the document and was not given a copy of it. However, he was
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`able to take photographs of the document. Exhibit 3.
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`54. The document was a waiver, drafted by JBS, designed to prevent Garner from
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`exercising any and all legal rights or pursuing any claims against JBS for its unilateral termination
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`of the contract. The document also required Garner to keep its terms “secret and confidential” and
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`precluded him from disclosing its terms to anyone.
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`55. Since Garner declined to sign JBS’ document, JBS subsequently took possession of
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`all the porcine livestock on his farm, and refused to pay him anything.
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`56. JBS gave Garner no opportunity to continue operating under the contract. JBS did not
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`identify any alleged, material problems or give him any opportunity to “cure” any alleged problems
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`that would have allowed him to continue producing animals for JBS.
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`57. As a direct result of JBS’ actions, Garner had no alternative but to shutter the hog farm
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`facility.
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`58. JBS’ unilateral cancellation of the contract placed Garner in a dire financial condition.
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`Not only did he lose revenue as a result of the contract termination and JBS’ failure to compensate
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`him for the animals it removed from his farm, he was faced with the inability to service the debt
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`on the loan he had obtained to purchase the hog farm facility.
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`59. Garner’s hog farm facility was built according to JBS’ specifications and had been
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`approved for the production of pigs for JBS.
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 11 of 18 PageID #: 15
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`60. JBS was, and is, the only company which is involved in industrial pork production in
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`the Howard County area.
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`61. In the absence of a production agreement with JBS, Garner’s hog farm facility had no
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`value.
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`62. Not only did the facility lack value in the absence of a production agreement, the real
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`property where the facility was located was left with a waste lagoon that would require thousands
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`of dollars to remediate.
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`63. When JBS’ representatives were on his farm on November 8, 2021, they made it clear
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`that JBS would not do any further business with him.
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`64. On or around November 9, 2021, a JBS veterinarian came to the farm while JBS was
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`removing the animals. The veterinarian told Garner that the animals “looked good,” but did not
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`provide any further explanation for why JBS had unilaterally decided to cancel the contract.
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`66. JBS has never provided Garner with any credible basis for its unilateral cancelation of
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`the five-year Sow Production Agreement.
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`66. Garner’s hog farm facility became inactive after JBS terminated his contract and
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`removed the livestock.
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`67. When it became clear that the hog farm facility lay fallow, several persons inquired
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`about the possibility of purchasing it and becoming producers for JBS.
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`68. Since Garner had debt problems and had lost his stream of income from the hog farm
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`as a result of JBS’ unilateral termination of his contract, he was keen to sell the facility so that he
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`could attempt to recoup his losses and mitigate his damage.
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`69. Just like with Garner, any prospective purchaser would not be able to use the hog farm
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`facility for any other purposes except as a producer for JBS. Consequently, prospective purchasers
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 12 of 18 PageID #: 16
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`contacted JBS to inquire about whether JBS would provide them a contract if they purchased
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`Garner’s facility.
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`70. Some prospective purchasers were simply told by JBS that it would not provide a
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`contract for the production of pigs at Garner’s farm.
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`71. JBS told at least one individual that it was not interested in giving a contract to anyone
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`who purchased Garner’s farm because the farm was “out-of-date” and because it would be cost-
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`prohibitive to ship animals from the farm to JBS’ other facilities.
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`72. As a result of JBS’ comments to prospective purchasers, JBS actively discouraged
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`anyone from buying the facility and actively interfered with Garner’s attempts to sell it.
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`73. Garner’s hog farm facility, which he is unable to sell, now sits idle. While he has lost
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`any source of revenue from the facility, he is forced to deal with the debt on the farm and faces the
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`prospect of being required to remediate the environmental issues related to the waste created by
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`the animals which he had produced for JBS.
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`CAUSES OF ACTION
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`I.
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`Breach of Contract
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`74. Plaintiff realleges the foregoing Paragraphs as if set forth herein, word for word.
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`75. JBS breached one or more terms of its contract with Garner.
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`76. Garner suffered damages as a result of these breaches.
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`77. Garner is entitled to judgment for his actual, incidental and consequential damages.
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`78. Garner is entitled to judgment for his reasonable attorney’s fees and costs of litigation.
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`II.
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`Estoppel
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`79. Plaintiff realleges the foregoing Paragraphs as if set forth herein, word for word.
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 13 of 18 PageID #: 17
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`80. Garner relied on JBS’ representations that it would contract with him and pay him for
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`animals over a term of years. Based on that reliance, he borrowed money and purchased the farm.
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`81. JBS knew that Garner was relying on its representations and that he took action as a
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`result of that reliance.
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`82. During the course of his dealings with JBS, JBS never told Garner that his farm was
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`out-of-date or that, because of its location, it was cost-prohibitive for JBS to ship animals from his
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`farm. If JBS had made these representations to Garner back in March, 2018, Garner would have
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`never borrowed money to purchase the hog fam facility, entered into any contract with JBS or
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`resigned his job as a deputy-sheriff.
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`83. Because of Garner’s detrimental reliance, JBS should be estopped from unilaterally
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`canceling the contract and failing to pay him for the animals he produced.
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`84. Garner has suffered damages as a result of his reliance on JBS’ representations.
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`85. Garner is entitled to judgment for his damages, reasonable attorneys fees and costs of
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`litigation.
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`III. Tortious Interference
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`86. Plaintiff realleges the foregoing Paragraphs as if set forth herein, word for word.
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`87. JBS knew that it’s unilateral termination of Garner’s contract would place Garner in a
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`dire financial situation.
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`88. JBS knew that Garner would have potential legal claims as a result of its termination
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`of his contract.
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`89. JBS tried to pressure Garner into abandoning his legal rights by trying to coerce him
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`into signing a written waiver on the same day that it advised him that it was canceling his contract.
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 14 of 18 PageID #: 18
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`90. JBS refused to allow Garner additional time to review the waiver or to seek counsel
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`from others before signing it. JBS’s representatives told Garner that he was required to sign the
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`waiver in their presence and that the company would not pay him if he refused to sign.
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`91. After Garner refused to sign JBS’ waiver, JBS decided to discourage prospective
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`purchasers from buying Garner’s facility. Among other things, JBS did this to exact additional
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`pressure on Garner and to further decrease the likelihood that he would file suit and pursue his
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`legal claims against the company.
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`92. JBS lacked any legitimate basis for preventing prospective purchasers from buying
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`Garner’s farm.
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`93. JBS’ intentional conduct has prevented several interested buyers from purchasing
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`Garner’s hog farm facility.
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`94. JBS’ conduct constitutes tortious interference with Garner’s business activities and has
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`directly damaged Garner.
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`95. Garner is entitled to judgment for his damages as a result of JBS’ tortious interference.
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`96. JBS’ actions were intentional and malicious.
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`97. Garner is entitled to judgment against JBS for exemplary damages to punish JBS and
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`to deter JBS and others from engaging in similar activity in the future.
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`IV. Conversion
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`98. Plaintiff realleges the foregoing Paragraphs as if set forth herein, word for word.
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`99. When JBS canceled the contract in November, 2021, there were pigs at Garner’s farm
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`for which he was entitled to payment.
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 15 of 18 PageID #: 19
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`100. JBS knew that it owed Garner for these animals but refused to pay him unless he
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`agreed to sign a “Mutual Termination and Release” on November 8, 2021 while in the presence of
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`JBS’ representatives.
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`101. When Garner was denied any additional time to seek consultation about the “Mutual
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`Termination and Release” document, JBS told him that he would not receive any of the payment
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`he was due, unless he signed the document on that day.
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`102. After Garner declined to sign the “Mutual Termination and Release,” JBS took all of
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`the pigs from his facility without properly compensating him.
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`103. JBS knew that Garner was entitled to compensation for the pigs that it removed from
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`his farm.
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`104. JBS’ failure to compensate Garner constituted intentional conversion.
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`105. JBS’ action was designed not only to prevent Garner from receiving payment for his
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`work, it was also designed as a punitive sanction for his refusal to sign a document, which had
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`been drafted by JBS, waiving any and all of his legal rights and remedies.
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`106. Garner suffered damages as a result of JBS’ failure to pay him for the animals it
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`removed from his farm.
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`107. JBS’ actions were intentional and malicious and were designed to punish Garner.
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`108. Garner is entitled to judgment for his damages and judgment for exemplary damages
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`to punish JBS and to deter JBS and others from engaging in similar activity in the future.
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`DAMAGES
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`109. Garner has suffered damages as a direct result of JBS’ conduct described herein.
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`Garner is entitled to judgment for his actual, consequential and incidental damages. Garner is
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 16 of 18 PageID #: 20
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`entitled to judgment for his reasonable attorney’s fees and costs of litigation and for exemplary
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`damages.
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`110. Garner’s damages include, but are not limited to: his losses resulting from JBS’
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`breaches and lack of compliance with the original terms of the parties’ contract; his losses resulting
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`from the pigs taken from his facility for which he was never paid; his losses as a result of JBS’
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`wrongful termination of the contract; and his losses as a result of JBS’ interference with his
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`attempts to sell the facility.
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`JURY DEMAND
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`111. JBS’ contract contains a provision that purports to cause Garner to waive the right to
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`a trial by jury. However, prior to wrongfully canceling the contract, JBS breached one or more
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`terms of the agreement. As a result of these prior breaches, JBS should not be allowed to enforce
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`the purported waiver of jury trial and Garner demands a trial by jury on all of his legal claims.
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`112. In the alternative, the purported waiver of jury trial is expressly limited to “any action
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`or proceeding to enforce or defend any rights under this agreement.” Exhibit 2, p. 17 (emphasis
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`added). Counts II, III and IV, above, do not involve claims to enforce or defend any rights under
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`the parties’ agreement. Instead, they involve claims related to JBS’ conduct outside the agreement.
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`Therefore, even if the Court determines that the contract claims are subject to a waiver of jury trial,
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`Garner demands a trial by jury on the remaining claims.
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`WHEREFORE, Plaintiff prays that he be granted the relief requested herein, that he be
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`granted judgment against the Defendant for his actual, incidental and consequential damages in an
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`amount greater than that required for federal diversity of citizenship jurisdiction, judgment for his
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`reasonable attorney’s fees and costs, judgment for his exemplary damages, and for any and all
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`other just and proper relief to which he may be entitled.
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 17 of 18 PageID #: 21
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`Respectfully submitted,
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`/s/ Corey D. McGaha
`Corey D. McGaha Ark. Bar No. 2003047
`COREY D. MCGAHA PLLC
`5507 Ranch Drive 104-D
`Little Rock, AR 72223
`Phone: (501) 205-4027
`Fax: (501) 367-8208
`cmcgaha@mcgahalaw.com
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`and
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`Todd M. Turner Ark. Bar No. 92266
`TURNER AND TURNER, PA
`501 Crittenden Street
`P.O. Box 480
`Arkadelphia, AR 71923
`Telephone: (870) 246-9844
`Fax: (888) 866-9897
`todd@tandtlaw.net
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`Attorneys for Plaintiff
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`Case 4:22-cv-04032-SOH Document 3 Filed 04/05/22 Page 18 of 18 PageID #: 22
`Case 4:22-cv-04032-SOH Document3
`Filed 04/05/22 Page 18 of 18 PagelD #: 22
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