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`UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`IN RE BROILER CHICKEN ANTITRUST
`LITIGATION
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`THIS DOCUMENT RELATES TO:
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` Amory Investments LLC v. Agri Stats, Inc.,
` Case No. 1:21-cv-06600;
`John Soules Foods, Inc., et al. v. Agri Stats, Inc.,
`Case No. 21-cv-00054.
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`No. 1:16-cv-08637
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`District Judge Thomas M. Durkin
`Magistrate Judge Jeffrey T. Gilbert
`Special Master Maura R. Grossman
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`CERTAIN DEFENDANTS’ MOTION FOR LEAVE TO FILE UNDER SEAL THEIR
`OPPOSITION TO AMORY AND JOHN SOULES’ OCTOBER 27, 2025 OBJECTIONS
`TO THE SPECIAL MASTER’S OCTOBER 17, 2025 RULINGS AND DECLARATION
`AND EXHIBITS THERETO
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` Certain Defendants respectfully request that the Court enter an order granting their Motion
`to File Under Seal the unredacted version s of Defendants’ Opposition to Amory Investments and
`John Soules’ October 27, 2025 Objections to the Special Master’s October 17, 2025 Rulings ( the
`“Opposition”) and the Declaration of Ryan Swindall in support of Certain Defendant’s Opposition
`to the Amory-JSF Objections, and the below Exhibits to that declaration. In support of this motion,
`Certain Defendants state as follows:
`1. The Opposition and the Swindall declaration contain quotations from and
`discussions of documents that are designated Confidential or Highly Confidential by parties in the
`above-captioned action under the Agreed Confidentiality Order, ECF No. 202.
`2. On October 28, 2025, Judge Gilbert granted Plaintiffs Amory Investments LLC,
`John Soules, Inc., and John Soules Acquisitions LLC’s Motion for Leave to File Under Seal Their
`Objections to Special Master ’s October 17, 2025 Rulings and Exhibits Thereto , ECF Nos. 8008,
`Case: 1:16-cv-08637 Document #: 8044 Filed: 11/05/25 Page 1 of 4 PageID #:694097
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`8014. This Motion seeks to seal similar information and also information quoted in the Opposition
`that has already been sealed per that order.
`3. Exhibit 1 is an email exchange between Amory and JSF’s counsel and Certain
`Defendants’ counsel discussing discovery requests and the meet and confer process from June 11,
`2025 to July 17, 2025.
`4. Exhibit 2 is an email exchange between Pilgrim’s employees and Director of
`Maine’s Center of the Plate Division, Jack Loomis, regarding wing price negotiations from
`October 31, 2011 through November 3, 2011 produced by Pilgrim’s in discovery at number
`PILGRIMS-0005295001.
`5. Exhibit 3 is a March 27, 2013 email from Loomis sharing competitor information
`and negotiating regarding pricing with Pilgrim’s employees produced by Pilgrims at number
`PILGRIMS-0010417622.
`6. Exhibit 4 is an October 28, 2011 email sent from Pilgrim’s to Loomis, among
`others, regarding an offer for the purchase of fresh chicken produced by Pilgrim’s at number
`PILGRIMS-0005294777.
`7. Exhibit 5 is a March 27, 2013 email from Vice President of Purchasing at Maines,
`Tom Brown to Loomis, with Pilgrim’s employees copied, regarding chicken pricing produced by
`Pilgrim’s at number PILGRIMS-0010417609.
`8. Exhibit 6 is a September 13, 2019 email from Maines Director of Purchasing &
`Category Management Bradley Wanda to his then co -worker Scott Leveille discussing deals on
`poultry products produced by Amory at number Amory_BR_0000057701.
`9. Exhibit 7 is an October 11, 2019 email from Wanda to other Maines employees
`produced by Amory at number Amory_BR_0000062584.
`Case: 1:16-cv-08637 Document #: 8044 Filed: 11/05/25 Page 2 of 4 PageID #:694098
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`10. Exhibit 8 contains excerpts from the deposition transcript of JSF’s 30(b)(6) witness
`Senior Vice President Thomas L. Ellis taken on June 4, 2021.
`11. Exhibit 9 is an October 22, 2008 email exchange forwarded from Ellis to Michael
`Bean, Director of Purchasing, produced by JSF in discovery at number JSF-BR-0000286250.
`12. Exhibit 10 is a September 9, 2009 email from Ellis to Bean regarding purchase of
`chicken produced by JSF at number JSF-BR-0000301829.
`13. Exhibit 11 is a July 14, 2008 email from Ellis to Bean and another JSF employee
`regarding Pilgrim’s chicken sales produced by JSF in discovery at number JSF-BR-0000286352.
`14. Exhibit 12 is a compilation of JSF Director of Purchasing Scott Self’s RFP
`communications with suppliers from 2014 to 2015 produced by JSF in discovery at JSF-BR-
`0000000166.
`15. Exhibit 13 is a January 4, 2016 email exchange between Self and Pilgrim’s
`regarding chicken nugget purchases produced by Pilgrim’s in discovery at PILGRIMS-
`0006017723.
`16. Exhibit 14 is an email exchange from July 29, 2016 between Pilgrim’s and Self
`regarding chicken purchases produced by Pilgrim’s in discovery at PILGRIMS-0007604431 .
`17. Exhibit 16 is an email exchange between Special Master Grossman, Certain
`Defendants’ counsel, and Amory and JSF’s counsel from July 18, 2025 to November 4, 2025.
`18. Exhibit 17 is an email from Pilgrim’s counsel to Amory and JSF’s counsel between
`October 19, 2025 and October 20, 2025, regarding Defendants’ search term proposal following
`the Special Master’s direction to meet and confer on search terms during the October 17, 2025
`hearing.
`Case: 1:16-cv-08637 Document #: 8044 Filed: 11/05/25 Page 3 of 4 PageID #:694099
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` Wherefore, for the foregoing reasons, Certain Defendants’ Motion for Leave to File Under
`Seal should be granted.
`Dated: November 5, 2025
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` Respectfully submitted,
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`/s/ Debra D. Bernstein
`Michael D. Bonanno
` William A. Burck
`Christopher G. Michel
`Kathleen A. Lanigan
`Carl Spilly
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`1300 I Street NW, Suite 900
`Washington, DC 20005
`Phone: (202) 538-8000
`Fax: (202) 538-8100
`mikebonanno@quinnemanuel.com
`williamburck@quinnemanuel.com
`christophermichel@quinnemanuel.com
`katlanigan@quinnemanuel.com
`carlspilly@quinnemanuel.com
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`Debra D. Bernstein
`Ryan F. Swindall
`1200 Abernathy Road, Suite 1500
`Atlanta, GA 30328
`Tel: (404) 482-3502
`debrabernstein@quinnemanuel.com
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`Michelle Schmit
`191 N. Wacker Dr., Suite 2700
`Chicago, IL 60606
`Tel: (312) 705-7400
`michelleschmit@quinnemanuel.com
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`Counsel for Defendant Pilgrim’s Pride
`Corporation
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`Case: 1:16-cv-08637 Document #: 8044 Filed: 11/05/25 Page 4 of 4 PageID #:694100
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