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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF ILLINOIS
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`GABRIELLE STUVE and JESSICA
`NICODEMO, on behalf of themselves and all
`others similarly situated,
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`Case No. 1:21-CV-01845
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`The Hon. Rebecca R. Pallmeyer
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`Plaintiffs,
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`vs.
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`THE KRAFT HEINZ COMPANY a/k/a
`KRAFT HEINZ FOODS COMPANY,
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`Defendant.
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`THE KRAFT HEINZ COMPANY’S
`MOTION TO DISMISS PLAINTIFFS’ CLASS ACTION COMPLAINT
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`PLEASE TAKE NOTICE that the undersigned attorneys for Defendant The Kraft Heinz
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`Company hereby move, pursuant to Federal Rule of Civil Procedure 12(b)(6), for an order
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`dismissing Plaintiffs Gabrielle Stuve and Jessica Nicodemo’s Class Action Complaint for failure
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`to state a claim on which relief can be granted.
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`Kraft Heinz’s motion is based on this motion, the accompanying Memorandum of Law,
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`the accompanying Request for Judicial Notice and Exhibits 1-6 thereto, any reply or supplemental
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`briefing Kraft Heinz may submit, and any further evidence or argument (including oral argument)
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`that the Court may invite Kraft Heinz to present in connection with this motion.
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`WHEREFORE, Kraft Heinz respectfully requests that the Court dismiss Plaintiffs’ Class
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`Action Complaint with prejudice and without leave to amend.
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`Case: 1:21-cv-01845 Document #: 17 Filed: 06/07/21 Page 2 of 3 PageID #:64
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`Dated: June 7, 2021
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`Respectfully submitted,
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`By: /s/ Dean N. Panos
` Dean N. Panos (ARDC No. 6203600)
`JENNER & BLOCK LLP
`353 N. Clark Street
`Chicago, IL 60654-3456
`Telephone: (312) 923-2765
`Facsimile: (312) 527-0484
`dpanos@jenner.com
`Attorneys for Defendant
`The Kraft Heinz Company
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`Case: 1:21-cv-01845 Document #: 17 Filed: 06/07/21 Page 3 of 3 PageID #:65
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing document was filed on June
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`7, 2021 with the Clerk of the Court by using the CM/ECF system, which will effect electronic
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`service on all parties and attorneys registered to receive notifications via the CM/ECF system.
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`Dated: June 7, 2021
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`By: /s/ Dean N. Panos
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