`
`
`UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`
`
`
`AMORY INVESTMENTS LLC,
`
`
`Plaintiff,
`
`
`
`
`
`
`
`
`Case No.: 21-cv-1907
`
`JURY TRIAL DEMANDED
`
`Related to In re Broiler Chicken Antitrust
`Litigation, Case No: 16-cv-08637
`
`
`
`
`v.
`
`AGRI STATS, INC., et al.,
`
`
`Defendants.
`
`
`
`
`COMPLAINT
`
`Plaintiff Amory Investments LLC (“Amory”) is a Delaware limited liability
`
`1.
`
`company which, on or around March 31, 2021, acquired various assets of Maines Paper & Food
`
`Service, Inc., and its affiliates (collectively “Maines”), including the claims that are the subject of
`
`this action. Maines was a direct purchaser of Broilers from several producer Defendants.
`
`2.
`
`Amory brings this action under the federal antitrust laws against the Defendants
`
`identified below and incorporates by reference the factual allegations and reservations of rights
`
`contained in the Direct Action Plaintiffs’ Amended Consolidated Complaint and Demand for Jury
`
`Trial, filed in In re Broiler Antitrust Litigation, Civil Action No. 1:16-cv-08637 (ECF 4243; ECF
`
`4244).
`
`3.
`
`Amory joins Section II of the Direct Action Plaintiffs’ Amended Consolidated
`
`Complaint and Demand for Jury Trial, adding the following to specify Amory’s causes of action
`
`and the Defendants in Amory’s action:
`
`1
`
`
`
`Case: 1:21-cv-01907 Document #: 1 Filed: 04/09/21 Page 2 of 3 PageID #:2
`
`Plaintiff Name
`Amory Investments LLC
`
`
`
`
`Named Defendants1
`Agri Stats; Case; Claxton;
`Foster Farms; Harrison;
`House of Raeford;
`Keystone; Koch; MarJac;
`Mountaire; O.K. Foods;
`Perdue; Pilgrim’s Pride;
`Sanderson; Simmons;
`Tyson; Wayne; Rabobank
`
`
`Named Co-Conspirators
`Amick; Fieldale;
`George’s; Peco
`
`Causes of Action
`Count I (Sherman Act
`Claim for all
`Anticompetitive
`Conduct); Count II
`(Sherman Act Claim for
`Output Restriction);
`Count III (Sherman Act
`for GA Dock
`Manipulation)
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiff respectfully requests that the Court:
`
`A.
`
`B.
`
`Enter joint and several judgments against all Defendants in favor of Plaintiff;
`
`Award Plaintiff treble damages, of an amount to be determined at trial, to the
`
`maximum extent allowed under the federal antitrust laws;
`
`C.
`
`Award Plaintiff post-judgment interest as provided by law, with such interest to be
`
`awarded at the highest legal rate;
`
`D.
`
`Award Plaintiff its attorneys’ fees, litigation expenses, and costs, as provided by
`
`law;
`
`E.
`
`Grant Plaintiff such other and further relief to which Plaintiff is entitled.
`
`JURY DEMAND
`
`Pursuant to Federal Rule of Civil Procedure 38, Plaintiff demands a trial by jury on all of
`
`its claims and issues so triable.
`
`
`
`
`
`
`
`
`1 The Defendants and Co-Conspirators named in this Complaint include the entire family of each
`Defendant or Co-Conspirators in this table, identified in Section IV of ECF 4243/4244.
`
`2
`
`
`
`Case: 1:21-cv-01907 Document #: 1 Filed: 04/09/21 Page 3 of 3 PageID #:3
`
`Dated: April 9, 2021
`
`
`
`
`BY: Scott E. Gant
`
`
`
`
`
`Scott E. Gant
`BOIES SCHILLER FLEXNER LLP
`1401 New York Avenue, NW
`Washington, DC 20005
`Tel: (202) 237-2727
`Fax: (202) 237-6131
`Email: sgant@bsfllp.com
`
`Colleen A. Harrison
`BOIES SCHILLER FLEXNER LLP
`333 Main Street
`Armonk, NY 10504
`Tel: (914) 749-8204
`Fax: (914) 749-8300
`Email: charrison@bsfllp.com
`
`Counsel for Amory Investments LLC
`
`Jared Kosoglad
`223 W. Jackson
`Suite 200
`Chicago, IL 60606
`Telephone: (312) 513-6000
`Email: jared@jaredlaw.com
`
`Local Counsel for Amory Investments LLC
`
`
`
`3
`
`
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