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`UNITED STATES DISTRICT COURT
`DISTRICT OF MARYLAND
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`Case No. 1:19-cv-02521-SAG
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`JUDY JIEN, et al.,
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`Plaintiffs,
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`v.
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`PERDUE FARMS, INC., et al.,
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`Defendants.
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`PLAINTIFFS’ MOTION FOR PRELIMINARY APPROVAL
`OF SETTLEMENT WITH PILGRIM’S PRIDE CORP., CERTIFICATION OF
`SETTLEMENT CLASS, AND APPOINTMENT OF SETTLEMENT CLASS COUNSEL
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`Pursuant to Rule 23(e) of the Federal Rules of Civil Procedure, Plaintiffs Judy Jien, Kieo
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`Jibidi, Elaisa Clement, Glenda Robinson, and Emily Earnest (collectively “Plaintiffs”) hereby
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`move for an Order granting preliminary approval of the settlement reached between Plaintiffs and
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`Defendant Pilgrim’s Pride Corporation (“Pilgrim’s”). The settlement terms are memorialized in a
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`written agreement entered into by the parties on June 14, 2021 (“Settlement Agreement”).
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`Plaintiffs respectfully request that the Court:
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`a) Grant preliminary approval of the Settlement Agreement;
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`b) Certify the proposed Settlement Class;
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`c) Appoint the Named Plaintiffs in this litigation—Judy Jien, Kieo Jibidi, Elaisa Clement,
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`Glenda Robinson, and Emily Earnest—as class representatives of the Settlement Class;
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`d) Appoint the law firms Handley Farah & Anderson PLLC; Cohen Milstein Sellers &
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`Toll, PLLC; and Hagens Berman Sobol Shapiro LLP (which currently serve as Interim
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`Co-Lead Counsel) as Settlement Class Counsel;
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`Case 1:19-cv-02521-SAG Document 481 Filed 07/02/21 Page 2 of 4
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`e) Direct Settlement Class Counsel to submit a motion to approve a plan of notice of the
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`Settlement Agreement at an appropriate time, i.e. after Defendants have produced
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`contact information regarding Settlement Class members and prior to Plaintiffs moving
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`for final approval of the Settlement Agreement; and
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`f) Grant a stay of all proceedings in this litigation against the Released Parties (as defined
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`in the Settlement Agreement) except as necessary to effectuate the Settlement
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`Agreement or otherwise agreed to by the settling parties.
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`This motion is made on the grounds that the Settlement Agreement, which provides a
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`$29,000,000 cash payment for the Settlement Class and material cooperation by Pilgrim’s in the
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`litigation against the remaining Defendants, is fair, reasonable, and adequate, thereby satisfying
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`the requirements of Rule 23(e) of the Federal Rules of Civil Procedure. This motion is based on
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`the Settlement Agreement; the Memorandum in Support of Motion for Preliminary Approval of
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`Settlement with Pilgrim’s Pride Corp., Certification of Settlement Class, and Appointment of
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`Settlement Class Counsel; and the Declaration of George F. Farah (all three of which accompany
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`this motion).
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`Dated: July 2, 2021
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`Respectfully submitted,
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` /s/ George F. Farah
`George F. Farah (admitted pro hac vice)
`Rebecca P. Chang (admitted pro hac vice)
`HANDLEY FARAH & ANDERSON PLLC
`33 Irving Place
`New York, NY 10003
`Telephone: (212) 477-8090
`gfarah@hfajustice.com
`rchang@hfajustice.com
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`2
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`Case 1:19-cv-02521-SAG Document 481 Filed 07/02/21 Page 3 of 4
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`Matthew K. Handley (D. Md. Bar # 18636)
`Stephen Pearson (admitted pro hac vice)
`Rachel E. Nadas (admitted pro hac vice)
`HANDLEY FARAH & ANDERSON PLLC
`200 Massachusetts Avenue, NW, Seventh Floor
`Washington, DC 20001
`Telephone: (202) 559-2433
`mhandley@hfajustice.com
`spearson@hfajustice.com
`rnadas@hfajustice.com
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`William H. Anderson (admitted pro hac vice)
`HANDLEY FARAH & ANDERSON PLLC
`4730 Table Mesa Drive
`Suite G-200
`Boulder, CO 80305
`Telephone: (202) 559-2433
`wanderson@hfajustice.com
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`Daniel A. Small (D. Md. Bar # 20279)
`Benjamin D. Brown (admitted pro hac vice)
`Brent W. Johnson (admitted pro hac vice)
`Daniel Silverman (admitted pro hac vice)
`Alison S. Deich (admitted pro hac vice)
`Zach Glubiak (D. Md. Bar # 20962)
`COHEN MILSTEIN SELLERS & TOLL PLLC
`1100 New York Avenue NW, 5th Floor
`Washington, DC 20005
`Telephone: (202) 408-4600
`Fax: (202) 408-4699
`dsmall@cohenmilstein.com
`bbrown@cohenmilstein.com
`bjohnson@cohenmilstein.com
`adeich@cohenmilstein.com
`zglubiak@cohenmilstein.com
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`Steve W. Berman (admitted pro hac vice)
`Breanna Van Engelen (admitted pro hac vice)
`HAGENS BERMAN SOBOL SHAPIRO LLP
`1301 Second Avenue, Suite 2000
`Seattle, Washington 98101
`Tel: (206) 623-7292
`steve@hbsslaw.com
`breannav@hbsslaw.com
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`3
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`Case 1:19-cv-02521-SAG Document 481 Filed 07/02/21 Page 4 of 4
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`Shana E. Scarlett (admitted pro hac vice)
`Rio R. Pierce (admitted pro hac vice)
`HAGENS BERMAN SOBOL SHAPIRO LLP
`715 Hearst Avenue, Suite 202
`Berkeley, CA 94710
`Tel: (510) 725-3000
`shanas@hbsslaw.com
`riop@hbsslaw.com
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`Interim Co-Lead Counsel for Plaintiffs and the
`Proposed Settlement Class
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`4
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