`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF MISSOURI
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`RURAL COMMUNITY WORKERS ALLIANCE
`and JANE DOE,
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`Plaintiffs,
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`vs.
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`Case No. 5:20-cv-06063-DGK
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`SMITHFIELD FOODS, INC. and SMITHFIELD
`FRESH MEATS CORP.,
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`Defendants.
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`DEFENDANTS’ MOTION TO DISMISS, OR IN THE ALTERNATIVE TO STAY,
`BASED ON PRIMARY JURISDICTION AND/OR BURFORD ABSTENTION
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`Come now Defendants, Smithfield Foods, Inc. and Smithfield Fresh Meats Corp., by and
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`through counsel, and move this Court to dismiss Plaintiffs’ Complaint, or in the alternative stay
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`this proceeding, for the reasons set forth in Defendants’ Suggestions in Support.
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`SMITHFIELD FOODS, INC. and
`SMITHFIELD FRESH MEATS CORP.
`
`
`By: /s/ Jean Paul Bradshaw II
`Jean Paul Bradshaw II (#31800)
`Mara Cohara (#51051)
`Lathrop GPM LLP
`2345 Grand Boulevard, Suite 2200
`Kansas City, Missouri 64108
`Telephone: (816) 460-5507
`Facsimile: (816) 292-2001
`jeanpaul.bradshaw@lathropgpm.com
`mara.cohara@lathropgpm.com
`
`
`
`Alexandra B. Cunningham (admitted PHV)
`Hunton Andrews Kurth LLP
`Riverfront Plaza, East Tower
`951 East Byrd Street
`Richmond, Virginia 23219-4074
`Telephone: (804) 787-8087
`Facsimile: (804) 788-8218
`
`-1-
`Case 5:20-cv-06063-DGK Document 28 Filed 04/27/20 Page 1 of 3
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`acunningham@HuntonAK.com
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`Susan F. Wiltsie (admitted PHV)
`Hunton Andrews Kurth LLP
`2200 Pennsylvania Avenue, NW
`Washington, District of Columbia 20037
`Telephone: (202) 955-1500
`Facsimile: (202) 778-2201
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`
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`Counsel for Defendants
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`-2-
`Case 5:20-cv-06063-DGK Document 28 Filed 04/27/20 Page 2 of 3
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`CERTIFICATE OF SERVICE
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`I hereby certify that on this 27th day of April, 2020, I electronically filed the foregoing
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`with the Clerk of the Court using the CM/ECF system which will send electronic notification of
`the same to the following counsel of record:
`Gina Chiala (#59112)
`Heartland Center for Jobs and Freedom, Inc.
`4047 Central Street
`Kansas City, MO 64111
`Telephone: (816) 278-1092
`Facsimile: (816) 278-5785
`ginachiala@jobsandfreedom.org
`
`David S. Muraskin (admitted pro hac vice)
`Karla Gilbride (admitted pro hac vice)
`Stevie K. Glaberson (admitted pro hac vice)
`Public Justice
`1620 L. Street, NW, Suite 630
`Washington, DC 20036
`Telephone: (202) 797-8600
`Facsimile: (202) 232-7203
`dmuraskin@publicjustice.net
`kgilbride@publicjustice.net
`sglaberson@publicjustice.net
`
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`I hereby certify that I will send copies of the foregoing via electronic mail to Plaintiffs’
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`counsel who have pending motions to appear pro hac vice:
`
`David Seligman (pro hac vice pending)
`Juno Turner
`Towards Justice
`1410 High Street, Suite 300
`Denver, CO 80218
`Telephone: (720) 441-2236
`Facsimile: (303) 957-2289
`david@towardsjustice.org
`juno@towardsjustice.org
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`Counsel for Plaintiffs
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`/s/ Jean Paul Bradshaw II
`An Attorney for Defendants
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`-3-
`Case 5:20-cv-06063-DGK Document 28 Filed 04/27/20 Page 3 of 3
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