`FOR THE NORTHERN DISTRICT OF IOWA
`EASTERN DIVISION
`
`
`
`
`
`
`
`
`PLAINTIFFS,
`
`
`
`
`
`
`Case No. 6:20-cv-02055-KEM
`
`
`
`
`PLAINTIFFS’ MOTION TO REMAND
`
`
`HUS HARI BULJIC INDIVIDUALLY AND AS
`ADMINISTRATOR OF THE ESTATE OF SEDIKA
`BULJIC, HONARIO GARCIA INDIVIDUALLY AND
`AS ADMINISTRATOR OF THE ESTATE OF
`REBERIANO LENO GARCIA, AND ARTURO DE
`JESUS HERNANDEZ AND MIGUEL ANGEL
`HERNANDEZ AS CO-ADMINISTRATORS OF THE
`ESTATE OF JOSE AYALA,
`
`
`
` V.
`
`TYSON FOODS, INC., TYSON FRESH MEATS,
`INC., JOHN H. TYSON, NOEL W. WHITE, DEAN
`BANKS, STEPHEN R. STOUFFER, TOM BROWER,
`MARY A. OLEKSIUK, ELIZABETH CROSTON,
`TOM HART, HAMDIJA BEGANOVIC, JAMES
`COOK, RAMIZ MUHELJIC, GUSTAVO CABAREA,
`PUM PISNG, ALEX BUFF, WALTER CIFUENTES,
`MUWI HLAWNCEU, CODY BRUSTKERN, MARK
`SMITH, AND JOHN/JANE DOES 1-10,
`
`
`
`
`
`
`DEFENDANTS.
`
`
`
`Plaintiffs, through counsel, respectfully request, for the reasons set forth in the Brief filed
`
`contemporaneously herewith, that the Court (1) remand this action to the District Court for Black
`
`Hawk County, Iowa, and (2) enter a judgment against Defendants imposing costs and attorneys’
`
`fees associated with this action.
`
`DATED this 26th day of August 2020.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`_/s/ Thomas P. Frerichs_____________
`Thomas P. Frerichs (AT0002705)
`Frerichs Law Office, P.C.
`106 E. 4th Street, P.O. Box 328
`Waterloo, IA 50704-0328
`319.236.7204 / 319.236.7206 (fax)
`tfrerichs@frerichslaw.com
`
`Case 6:20-cv-02055-LRR-KEM Document 15 Filed 08/26/20 Page 1 of 3
`
`
`
`John J. Rausch
`Rausch Law Firm, PLLC
`3909 University Ave., P.O. Box 905
`Waterloo, IA 50704-0905
`319.233.3557 / 319.233.3558 (fax)
`rauschlawfirm@dybb.com
`
`Mel C. Orchard, III
`G. Bryan Ulmer, III
`Gabriel Phillips
`The Spence Law Firm, LLC
`15 S. Jackson Street
`P.O. Box 548
`Jackson, WY 83001
`307.337.1283 / 307.337.3835 (fax)
`orchard@spencelawyers.com
`ulmer@spencelawyers.com
`phillips@spencelawyers.com
`
`Attorneys for the Plaintiffs
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`PLAINTIFFS’ MOTION TO REMAND — PAGE 2 OF 3
`Case 6:20-cv-02055-LRR-KEM Document 15 Filed 08/26/20 Page 2 of 3
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 26th day of August 2020, a true and correct copy of the above
`
`and foregoing Plaintiffs’ Motion to Remand was served via CM/ECF Electronic Transmission on
`
`the following:
`
`
`Kevin J. Driscoll
`Finley Law Firm, P.C.
`699 Walnut Street, Suite 1700
`Des Moines, Iowa50309
`Email: kdriscoll@finleylaw.com
`
`Christopher S. Coleman
`Perkins Coie LLP
`2901 N. Central Avenue
`Suite 2000
`Phoenix, Arizona 85012
`Email: CColeman@perkinscoie.com
`
`Mary Gaston
`Perkins Coie LLP
`1201 Third Avenue
` Suite 4900
`Seattle, Washington 98101-3099
`Email: MGaston@perkinscoie.com
`
`Attorneys for Defendants Tyson Foods, Inc.
`and Tyson Fresh Meats, Inc.
`
`
`
`
`
`_/s/ Thomas P. Frerichs_____________
`Thomas P. Frerichs
`Frerichs Law Office, P.C.
`
`PLAINTIFFS’ MOTION TO REMAND — PAGE 3 OF 3
`Case 6:20-cv-02055-LRR-KEM Document 15 Filed 08/26/20 Page 3 of 3
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
