Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 1 of 17 PageID #: 12
`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 1 of 17 PageID #: 12
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`EXHIBIT A
`EXHIBIT A
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 1 of 17 PageID #: 12
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`EXHIBIT A
`EXHIBIT A
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 2 of 17 PageID #: 13
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`CERTIFIED COPY CERTIFICATE
`STATE OF TEXAS COUNTY OF ANGELINA
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`I hereby certify that the above is a true and correct
` copy of the original record on file in my office
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`Reba Squyres, District Clerk, Angelina CO, TX
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`Kelley, Jill
`By:___________________________________
` Deputy
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 3 of 17 PageID #: 14
`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 3 of 17 PageID #: 14
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`EXHIBIT A-1
`EXHIBIT A-l
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 4 of 17 PageID #: 15
`‘ Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 4 of 17 PagelE;
`iféd %?9/2020 4:00 PM
`District Clerk
`Reba Squyres,
`Angelina County, Texas
`By: Brittany Crawford,
`Deputy Clerk
`
`N0,CV-00296-20-06
`
`IN THE DISTRICT COURT OF
`'
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`, ANGELINA COUNTY
`‘
`.
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`__ JUDICIAL DISTRICT -
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`)
`)
`)
`)
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`) )
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`) )
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`)
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`JOSE MANUEL REQUENA and OSCAR
`REQUENA, Individually and On Behalf of
`the Estate of Maria Hernandez,
`'
`
`PLAINTIFFS,
`
`v.
`
`PILGRIM’S PRIDE CORPORATION,
`
`DEFENDANT.
`
`PLAINTIFFS’ ORIGINAL PETITION
`
`Come now PLAINTIFF S, JOSE MANUEL REQUENA and OSCAR REQUENA,
`
`Individually and On Behalf of the Estate of Maria Hernandez, by and through their undersigned
`
`attorneys, for their Petition against Defendant PILGRIM’S PRIDE CORPORATION related to
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`the exposure of decedent, Maria Hernandez to COVID-19, and in support thereof would show
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`the following:
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`I. JURISDICTION AND VENUE
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`1.
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`This Court has jurisdiction over the subject matter of this lawsuit and over the
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`persons and companies referenced above because they are domiciled in this State and/or have
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`sufficient minimum contacts with this State and Plaintiffs claims arise from those contacts.
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`2.
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`Venue is proper in this Court pursuant to Texas Civil Practice and Remedies
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`Code § 15.002.
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`II. PARTIES
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`1.
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`Plaintiff Jose Manuel Requena is a surviving adult son. of decedent, Maria
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`, Hernandez, and a resident of the State of Texas. He brings this suit individually and on behalf of
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 5 of 17 PageID #: 16
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`the Estate of Maria Hernandez, deceased, pursuant to Chapter 71 of the Texas Civil Practice and
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`Remedies Code.
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`2.
`
`Plaintiff Oscar Requena is a surviving adult son of decedent, Maria Hernandez,
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`and a resident of the State of Texas. He brings this suit individually and on behalf of the Estate
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`of Maria Hernandez, deceased, pursuant to Chapter 71 of the Texas Civil Practice and Remedies
`
`Code.
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`3.
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`Defendant Pilgrim’s Pride Corporation (“Pilgrim’s”) is a Delaware corporation,
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`with its principal place of business at 1770 Promontory Circle Greeley, Colorado 80634.
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`Defendant engaged, and continues to engage,
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`in relevant business activities and services in
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`Texas. Pilgrim’s may be served through its registered agent, Corporation Service Company, at
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`211 E. 7th Street, Suite 620 Austin, Texas 78701.
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`III. DISCOVERY LEVEL
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`4.
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`Plaintiffs request that discovery be conducted under Level 3 of the Texas Rules of
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`Civil Procedure.
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`IV. F_A(;lԤ
`
`5.
`
`While American citizens and businesses across the country were taking
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`extraordinary steps to limit the spread and impact of COVID-l9, Pilgrim’s sent an employee
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`who had worked for the company for over 30 years into the heart of an outbreak at its Lufl<in,
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`Texas, processing plant. The fact that Maria Hernandez, then 63 years old, was at higher risk of
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`succumbing to the effects of COVID-l9 did not stop Pilgrim’s from sending her to a known hot
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`spot for the virus. On April 23, 2020, Pilgrim’s management shifted workers from other
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`departments to the Shipping and Labeling department to fill in for workers who were absent due
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`to a COVID-19 outbreak. Among those workers was Maria Hernandez, who became infected.
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`
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 6 of 17 PagelD #: 17
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`On May 8, 2020, her 64th birthday, Ms. Hernandez became the first Lufldn resident to die of
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`complications related to COVID-19.
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`V. COVID-19
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`6.
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`COVID-19, the disease caused by the novel coronavirus SARS-CoV—Z, has led to
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`a global pandemic. The first known case of COVID—19 in the United States was identified on
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`January 21, 2020. By March 13, 2020, Governor Greg Abott had declared a statewide
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`emergency. COVID-19 quickly spread throughout Texas, including to the Pilgrim’s plant in
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`Lufl<in.
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`7.
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`COVID-l9 causes more severe symptoms, and even death, at a significantly
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`higher rate in older individuals. One study has estimated that the infection fatality rate in those
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`aged 60—69 is nearly three times higher than in the overall population.
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`8.
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`COVID—19 spreads rapidly among individuals forced to work in close proximity._
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`Additionally, the virus that causes COVID-l9 thrives in colder temperatures. For those reasons,
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`meatpacking and poultry plants like the Pilgrim’s plant in Luflcin have experienced outbreaks
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`around the country and are often “hot spots” for the virus within their communities. Plant
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`workers are infected at grossly disproportionate rates when compared to the general population.
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`For example, although Pilgrim’s employees account for approximately two percent of employees
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`in Angelina County, as of May 9, 2020, nearly half (50 out of 107) of all confirmed COVID-l9
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`cases in the county were employees of Pilgrim’s. While other employers shut down facilities
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`experiencing outbreaks — even if only temporarily to allow for deep cleaning — as of the time of
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`Ms. Hemandez’s death Pilgrim’s had refused to shut down even 48 hours for additional cleaning.
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`VI. PILGRIM’S PRIDE
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`9.
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`Pilgrim’s Pride Corporation (“Pilgrim’s”) traces its origins back to a feed store
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`founded in Pittsburg, Texas, in 1946 by brothers Aubrey and Lonnie Pilgrim. In 2009, JBS USA
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`-3-
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 7 of 17 PageID #: 18
`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 7 of 17 PageID #: 18
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`Holdings, Inc., a subsidiary of the Brazilian company JBS S.A., acquired majority ownership of
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`the company. Pilgrim’s now operates in 14 states across the United States and distributes
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`chicken and chicken products under various brands. The company claims that “nearly 1 out of
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`every 5 chickens in the US. come from Pilgrim’s.”
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`10.
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`Pilgrim’s proclaims on its website that they “are dedicated to [their]
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`team
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`members” and that their goal is to provide them with “the opportunity for a better future!” In a
`statement to The Lufl<in Daily News, Pilgrim’s declared,. ”The health and safety of our
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`employees is our highest priority.”
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`11.
`
`No later than April 21, 2020, Pilgrim’s management was aware of multiple cases
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`of COVID-19 amongst their employees at the Lufldn plant. Pilgrim’s employees began to miss
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`work, especially in the Shipping and Labeling department. Management responded by shifting
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`workers from other departments into that area, where several employees had already fallen sick.
`Pilgrim’s failed to take adequate precautions to protect these incoming workers and failed to
`account for risk factors such as age when assigning workers.
`A
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`According to a Pilgrim’s employee, as reported in the Lufkin Daily News, the
`12.
`Shipping and Labeling department at Pilgrim’s was consistently understaffed during the
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`pandemic due to illness, employees being tested, or absenteeism. According to another Pilgrim’s
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`employee, speaking to the paper on condition of anonymity, the company pulled people from
`each department
`into Shipping and Labeling despite employees’
`concerns of cross-
`contamination.
`.
`V
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`13.
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`On information and belief,
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`in order to keep employees working, Pilgrim’s ‘
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`understated the number of COVID-19 infections, refused to allow employees to take personal
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`days, and threatened repercussions if employees did not report for work.
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`
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 8 of 17 PageID #: 19
`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 8 of 17 PagelD #: 19
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`14.
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`Nevertheless, Pilgrim’s insisted in a statement that it was “offering support” to
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`team members who tested positive and their families. The company maintained that it was
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`“taking strict precautions at all of [its] facilities to protect the health and safety of [its] team
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`members” and would do “all we can” to keep the virus out of its facilities.
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`15.
`
`The events leading up to Ms. Hernandez’s death tell a different story.
`
`VII. MARIA HERNANDEZ
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`16.
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`Maria Hernandez was born in 1956. For over three decades until her untimely
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`death, she worked the line at the Pilgrim’s plant in Lufl<in, Texas, while raising her two sons. At
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`the time of her death, Ms. Hernandez worked on the Second Processing line as a machine
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`operator.
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`17.
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`When she became aware of the COVID-19 threat, Ms. Hernandez took
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`precautions to avoid unnecessary social contact. She consistently maintained social distancing
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`and limited contact outside of the workplace. Because of the nature of her job, however, Ms.
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`Hernandez could not avoid being around others while working. And when she was sent to work
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`in the Shipping and Labeling department, a hot spot in the Lufl<in plant known to Pilgrim’s
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`management, she could not avoid the virus that caused her death.
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`18.
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`On or about Thursday, April 23, 2020, instead of working her usual station, Ms.
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`Hernandez was instructed to report to work in the Shipping and Labeling department at the
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`Pilgrim’s plant. Faced with the possibility of losing her job if she refused, Ms. Hernandez
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`complied.
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`19.
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`Soon thereafter, on Friday, May 1, Ms. Hernandez began experiencing COVID-19
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`symptoms. The next day she called in sick. On Monday, May 4, although she was still not
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`feeling well, Ms. Hernandez reported for work rather than risk being penalized by her employer.
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`After an hour or so, Ms. Hernandez was unable to continue working and went to see a company
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`-5-
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 9 of 17 PageID #: 20
`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 9 of 17 PageID #: 20
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`nurse. The nurse suggested Ms. Hernandez see a doctor. Ms. Hemandez’s doctor suspected she
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`had COVID-l9 and performed a test for the coronavirus. He also recommended that she
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`quarantine.
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`20.
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`That same day, too late to be of any help to Ms. Hernandez, Pilgrim’s sent home
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`all workers 60 years of age or older from the Lufl<in plant.
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`21.
`
`Ms. Hernandez received positive results from her coronavirus test just days before
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`her death.
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`22.
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`On Friday, May 8, 2020, her 64th birthday, Ms. Hernandez died of complications
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`related to COVID—19 -- less than three weeks after being sent to work in the heart of an outbreak.
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`VIII. COUNT I
`
`Negligence
`
`23.
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`Plaintiffs incorporate the allegations contained in the foregoing paragraphs as if
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`fully set forth in the following paragraphs.
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`24.
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`Pilgrim’s owed Maria Hernandez a nondelegable duty to provide a safe
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`workplace.
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`25.
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`Pilgrim’s OWed Maria Hernandez a duty to warn her of the fact that Pilgrim’s
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`employees had tested positive for COVID-19, and specifically that the Shipping and Labeling
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`department was a “hot spot” with a higher number of cases relative to other areas of the Lufldn
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`plant.
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`26.
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`Pilgrim’s owed Maria Hernandez a duty to consider reasonable risk factors, such
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`as age, before assigning her to an area of the plant where employees had been infected.
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`27.
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`Pilgrim’s 0Wed Maria Hernandez a duty not to place her in harm’s way by
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`exposing her unnecessarily to increased risk of exposure to COVID-19 without adequate
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`personal protective equipment.
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`
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 10 of 17 PageID #: 21
`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 10 of 17 PagelD #: 21
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`28.
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`Pilgrim’s owed Maria Hernandez a duty to implement and enforce safety
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`protocols to prevent the spread of, and exposure to, COVID-l9.
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`29.
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`Pilgrim’s owed Maria Hernandez a duty to seek out and remove sources of harm
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`on the premises of the Lufl<in plant that Pilgrim’s controlled.
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`30.
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`Pilgrim’s breached its duties to Maria Hernandez by sending her to work in a
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`known “hot spot” for COVID-l9 without warning or adequate protection and without taking
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`reasonable steps to render the area safe.
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`31.
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`As a direct and proximate result of Defendant’s actions, Plaintiffs suffered
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`injuries and damages.
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`32.
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`Pursuant to Texas Rule of Civil Procedure 47, Plaintiffs state that they are seeking
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`monetary relief over $1,000,000.
`
`IX. COUNT II
`
`Gross Negligence
`
`33.
`
`Plaintiffs incorporate the allegations contained in the foregoing paragraphs as if
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`fully set forth in the following paragraphs.
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`34.
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`Pilgrim’s was aware at all relevant times, and certainly no later than April 21,
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`2020, of the outbreak of COVID-19 in the Shipping and Labeling department of its Lufl<in plant.
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`Pilgrim’s created an extreme risk of harm by failing to adequately address the outbreak before
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`sending additional workers from other departments into the Shipping and Labeling department.
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`35.
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`Pilgrim’s created an extreme risk of harm by failing to account for risk factors
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`such as age when assigning employees to areas where infected workers had previously been
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`assigned.
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 11 of 17 PageID #: 22
`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 11 of 17 PageID #: 22
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`36.
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`As a direct and proximate result of Pilgrim’s gross negligence, Plaintiffs suffered
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`injuries and damages.
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`X. DAMAGES
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`37.
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`Plaintiffs incorporate the allegations contained in the foregoing paragraphs as if
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`fully set forth in the following paragraphs.
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`38.
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`The facts set out above demonstrate that, as a direct and proximate result of
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`Pilgrim’s conduct, Plaintiffs have individually suffered damages including, without limitation,
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`pecuniary loss, both past and future, the loss of care, support, advice, and counsel. Plaintiffs
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`suffered loss of companionship and society, both past and future, for the loss of the positive
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`benefits flowing from the love, comfort, companionship, and society that Plaintiffs would have
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`received from their beloved mother had she lived. Plaintiffs suffered mental anguish both past
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`and future for the torment and emotional devastation of losing their mother, because of both her
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`untimely death and the fact that she died alone in her home. Plaintiffs also suffered a loss of
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`inheritance for the loss of the value of assets that Maria Hernandez would have added to the
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`estate and left to her survivors upon her natural death.
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`39.
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`The facts set out above demonstrate that, as a direct and proximate result of
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`Pilgrim’s conduct, the Estate of Maria Hernandez is entitled to recover all damages recoverable
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`under Texas law including, without
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`limitation, damages for reasonable funeral and burial
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`expenses of the Estate of Maria Hernandez and for the conscious, emotional and physical pain,
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`torment, anguish and suffering experienced or sustained by Maria Hernandez prior to her death.
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`40.
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`Plaintiffs further seek all other actual damages available under applicable law, the
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`costs of this suit, and such further relief as this Court deems necessary, just and proper
`
`
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`t
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 12 of 17 PageID #: 23
`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 12 of 17 PageID #: 23
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`XI.W'
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`41.
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`Plaintiffs hereby demand a jury trial.
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`XII. REQUEST FOR DISCLOSURE
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`42.
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`Plaintiffs request that Defendant disclose, within fifty days of service of this
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`Request for Disclosure, the information and/or material described in Rule 194.2.
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`XIII. RULE 193.7 NOTICE
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`43.
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`Plaintiffs provide notice under Texas Rule of Civil Procedure 193.7 to use any
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`and all documents produced by Defendant.
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`XIv. w
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`WHEREFORE, Plaintiffs ask that Defendant Pilgrim’s Corporation be cited to appear
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`and answer herein. That upon final trial, Plaintiffs have judgment against Defendant Pilgrim’s
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`Corporation, in excess of this Court’s jurisdictional requisite for actual damages, costs of court,
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`and any other relief that will fairly and adequately compensate for the losses herein alleged.
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`Respectfully submitted,
`
`WILLIAMS HART BOUNDAS
`
`EASTERBY, LLP
`
`/ s / William R. Langley
`JIM HART
`
`State Bar No. 09147400
`
`WILLIAM R. LANGLEY
`
`State Bar No. 24102061
`
`8441 Gulf Freeway, Suite 600
`Houston, Texas 77 017-5001
`(713) 230-2326 — Telephone
`(713) 643-6226 — Facsimile
`PIDept@whlaw.com
`
`
`
`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 13 of 17 PageID #: 24
`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 13 of 17 PageID #: 24
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`George Chandler
`State Bar No. 04094000
`PO. Box 340
`
`Luflcin, Texas 75902-0340
`(936) 632-7778 —— Phone
`(936) 632-1304 —— Fax
`gchandler@cmzlaw.net
`
`ATTORNEYS FOR PLAINTIFFS
`
`-10-
`
`
`
`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 14 of 17 PageID #: 25
`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 14 of 17 PageID #: 25
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`EXHIBIT A-2
`EXHIBIT A-2
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 15 of 17 PageID #: 26
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`Notice of Service of Process
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`Primary Contact:
`
`Kimberly Pryor
`JBS USA Holdings, Inc.
`1770 Promontory Cir
`Greeley, CO 80634-9039
`
`null / PERINJ
`Transmittal Number: 21614032
`Date Processed: 06/12/2020
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`Entity:
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`Entity Served:
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`Title of Action:
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`Document(s) Type:
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`Nature of Action:
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`Court/Agency:
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`Case/Reference No:
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`Jurisdiction Served:
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`Date Served on CSC:
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`Pilgrim's Pride Corporation
`Entity ID Number 3265617
`
`Pilgrim's Pride Corporation
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`Jose Manuel Requena vs. Pilgrim's Pride Corporation
`
`Citation/Petition
`
`Personal Injury
`
`Angelina County District Court, TX
`
`CV-00296-20-06
`
`Texas
`
`06/11/2020
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`Answer or Appearance Due:
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`10:00 am Monday next following the expiration of 20 days after service
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`Originally Served On:
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`How Served:
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`Sender Information:
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`CSC
`
`Personal Service
`
`William R. Langley
`713-230-2326
`
`Information contained on this transmittal form is for record keeping, notification and forwarding the attached document(s). It does not
`constitute a legal opinion. The recipient is responsible for interpreting the documents and taking appropriate action.
`
`To avoid potential delay, please do not send your response to CSC
`251 Little Falls Drive, Wilmington, Delaware 19808-1674 (888) 690-2882 | sop@cscglobal.com
`
`
`
`I
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 16 of 17 PageID #: 27
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`CITATION
`
`CLERK OF THE COURT
`
`ATTORNEY FOR PLAINTIFF
`
`Reba Squyres
`District Clerk
`PO. Box 908
`
`Lufldn, Texas 75902
`
`JIM HART
`8441 GULF FREEWAY
`SUITE 600
`
`HOUSTON, TX 77017
`
`THE STATE OF TEXAS
`
`NOTICE TO DEFENDANT: “You have been sued. You may employ an attorney. If you or your attorney
`do not file a written answer with the clerk who issued this citation by 10:00 am. on the Monday next
`following the expiration of twenty days after you were served this citation and petition, a default judgment
`may be taken against you.”
`
`TO: PILGRIM'S PRIDE CORPORATION, Defendant
`
`GREETINGS: You are commanded to appear by filing a written answer to the plaintiff’ s petition at or
`before 10:00 o’clock am. of the Monday next after the expiration of 20 days after the date of service hereof,
`before the 217th Judicial District Court of Texas, at the Courthouse in Lufl<in,'Texas.
`
`Said plaintiff’s petition was filed on June 09, 2020 at 4:00 O'CLOCK RM.
`
`The file number of said suit being CV-00296-20-06.
`
`The style of the case is:
`
`JOSE MANUEL REQUENA AND OSCAR REQUENA, INDIVIDUALLY
`AND ON BEHALF OF THE ESTATE OF MARIA HERNANDEZ
`VS.
`
`PILGRIM'S PRIDE CORPORATION
`
`A copy of plaintiff’s petition accompanies this citation.
`
`Issued on this the 10th day of June, 2020.
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`GIVEN UNDER MY HAND AND SEAL OF SAID COURT, at office in Lufldn, Texas, on this the 10th
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`day of June, 2020.
`
`FEES UNPAID
`RULE 103
`
`Reba Squyres, District Clerk
`Angelina County, Texas
`PO. Box 908
`Lufkin, Texas 75902
`
`By:W—Brittany Craw 0rd, Deputy District Clerk
`
`
`
`Y
`
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`Case 9:20-cv-00147 Document 1-1 Filed 07/02/20 Page 17 of 17 PageID #: 28
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`Cause: CV-00296-20-06
`
`Executed when copy is delivered:
`This is a true copy of the original citation with
`defendant
`, on the
`
`'
`
`day of
`
`was delivered to
`
`, 20
`.
`
`, Officer
`
`, County, Texas
`
`By:
`
`, Deputy
`
`ADDRESS FOR SERVICE:
`
`p
`Defendant:
`PILGRIM'S PRIDE CORPORATION
`
`REGISTERED AGENT: CORPOARTION SERVICE COMPANY
`211 E 7TH ST
`SUITE 620
`
`AUSTIN, TX 78701
`
`_
`
`‘
`
`OFFICER’S RETURN
`
`I
`% —
`.m., and
`, o’clock
`, 20E, at I 3. Z(
`Came to hand on the [a day of 5 [(Me-
`executed in
`County, Texas by delivering to each of the within named de endants in
`person, a true copy of this Citation and
`with the date of delivery endorsed
`thereon, together with the accompanying copy of the plaintiff’s petition, at the following times and places, to-wit:
`‘ Name
`Date/Time
`Place, Course and Distance from Courthouse
`
`And not executed as to the defendant(s),
`
`The diligence used in finding said defendant(s) being:
`
`and the cause or failure to execute this process is:
`
`and the information received as to the whereabouts of said defendant(s) being:
`
`FEES:
`
`Serving Petition and Copy
`Total
`
`9999
`
`, Officer
`
`, County, Texas
`
`,Deputy
`
`By:
`
`Affiant
`
`*Rule 107 Verification: Subscribed and sworn to by the above named
`this the
`day of
`, 20—, to certify which witness my hand and seal of office.
`
`before me
`
`Person Administering Oath
`
`
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