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Case: 1:20-cv-02295 Document #: 134 Filed: 02/15/21 Page 1 of 3 PageID #:2940
`
`UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`
`
`OLEAN WHOLESALE GROCERY
`COOPERATIVE, INC., et al.,
`
`
`Plaintiffs,
`
`
`v.
`
`AGRI STATS, INC., et al.,
`
`
`
`SANDEE’S CATERING,
`
`
`
`v.
`
`AGRI STATS, INC., et al.,
`
`
`Defendants.
`
`
`Plaintiff,
`
`Defendants.
`
`
`Case No.: 1:19-cv-08318
`
`Honorable Virginia M. Kendall
`Hon. Gabriel A. Fuentes
`
`
`
`
`
`Case No.: 1:20-cv-02295
`
`Honorable Virginia M. Kendall
`Hon. Gabriel A. Fuentes
`
`
`
`
`
`
`
`
`
`
`DEFENDANTS TYSON FOODS, INC.; TYSON FRESH MEATS, INC.; TYSON
`PREPARED FOODS, INC. AND THE HILLSHIRE BRANDS COMPANY’S
`MOTION FOR JUDGMENT ON THE PLEADINGS
`
`Pursuant to Fed. R. Civ. P. 12(c), Defendants Tyson Foods, Inc., Tyson Fresh Meats,
`
`Inc., Tyson Prepared Foods, Inc., and The Hillshire Brands Company (collectively, “Tyson”)
`
`respectfully submit this Motion for Judgment on the Pleadings seeking judgment in Tyson’s
`
`favor on the pleadings. The reasons for the Motion are set forth in the accompanying
`
`Memorandum of Law in Support of Motion for Judgement on the Pleadings Under Federal Rule
`
`of Civil Procedure 12(c), filed contemporaneously herewith.
`
`
`
`WHEREFORE, Tyson respectfully requests the court issues judgment in Tyson’s favor
`
`on the pleadings.
`
`

`

`Case: 1:20-cv-02295 Document #: 134 Filed: 02/15/21 Page 2 of 3 PageID #:2941
`
`Dated: February 15, 2021
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`\s\Jordan M. Tank
`Jordan M. Tank
`230 West Monroe Street
`Suite 2260
`Chicago, IL 60606
`Telephone: 312.702.0586
`jmt@lipelyons.com
`
`Tiffany Rider Rohrbaugh
`Rachel J. Adcox
`Axinn, Veltrop & Harkrider LLP
`950 F. Street, NW
`Washington, DC 20004
`Telephone: 202.912.4700
`Facsimile: 202.912.4701
`trider@axinn.com
`radcox@axinn.com
`
`Jarod G. Taylor (pro hac vice pending)
`Axinn, Veltrop & Harkrider LLP
`90 State House Square
`Hartford, CT 06103
`Telephone: 860.275.8100
`Facsimile: 860.275.8101
`jtaylor@axinn.com
`
`Counsel for Tyson Foods, Inc., Tyson Fresh
`Meats, Inc., Tyson Prepared Foods, Inc.,
`and The Hillshire Brands Company
`
`
`
`
`
`
`
`
`
`
`
`2
`
`

`

`Case: 1:20-cv-02295 Document #: 134 Filed: 02/15/21 Page 3 of 3 PageID #:2942
`
`CERTIFICATE OF SERVICE
`
`The undersigned, an attorney, hereby certifies that on February 15, 2021, a copy of the
`
`foregoing was electronically filed with the Clerk of the Court using the Court’s CM/ECF system,
`which will send notification of the filing to all counsel of record.
`
`
`
`By: /s/ Jordan M. Tank
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`3
`
`

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