Case: Pierre v. JBS USA Food Company

Pierre et al. v. JBS USA Food Company et al.

COMPLAINT against JBS USA Food Company, Swift Beef Company (Filing fee $ 405,Receipt Number ACODC-10716330)Attorney Anna Purna Prakash added to party Carolos Saint Aubin(pty:pla), Attorney Anna Purna Prakash added to party Louine Jean-Louis(pty:pla), Attorney Anna Purna Prakash added to party Nesly Pierre(pty:pla), filed by Nesly Pierre, Carolos Saint Aubin, Louine Jean-Louis. (Attachments: # 1 Civil Cover Sheet)(Prakash, Anna) (Entered: 12/16/2025)

1 Civil Cover Sheet

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SUMMONS REQUEST as to Swift Beef Company by Plaintiffs Carolos Saint Aubin, Louine Jean-Louis, Nesly Pierre. (Prakash, Anna) (Entered: 12/16/2025)

SUMMONS REQUEST as to JBS USA Food Company by Plaintiffs Carolos Saint Aubin, Louine Jean-Louis, Nesly Pierre. (Prakash, Anna) (Entered: 12/16/2025)

Case assigned to Magistrate Judge N. Reid Neureiter. Text Only Entry. (echa, ) (Entered: 12/16/2025)

SUMMONS issued by Clerk. (Attachments: # 1 Summons, # 2 Magistrate Judge Consent Form) (echa, ) (Entered: 12/16/2025)

ORDER SETTING SCHEDULING/PLANNING CONFERENCE AND SETTING DEADLINE FOR FILING OF CONSENT/NON-CONSENT FORM The above-captioned case has been directly assigned to Magistrate Judge N. Reid Neureiter pursuant to D.C.COLO.LCivR 40.1(c) - Direct Assignment to Magistrate Judges.IT IS HEREBY ORDERED that Plaintiff shall promptly serve Defendant. On or before March 26, 2026, the parties shall complete and file the Consent/Non-Consent Form (see ECF No. # 5 -2), indicating either unanimous consent of the parties or that consent has been declined. Please note that this date may be earlier than the default deadlines contemplated by D.C.COLO.LCivR 40.1(c)(4). A Scheduling/Planning Conference pursuant to Fed.R.Civ.P.16(b) shall be held on:April 9, 2026 at 11:00 a.m. in Courtroom A-401, Fourth Floor, Alfred A. Arraj United States Courthouse, 901 19th Street, Denver, Colorado 80294. The Scheduling Conference will be conducted via telephone. Five minutes prior to the start of the hearing, the parties are directed to call the conference line as a participant at (571) 353-2301, Access Code 841686937#. If this date is not convenient for any counsel/pro se party, he/she should confer with opposing counsel/pro se party and file a motion to reschedule the conference to a more convenient date. Absent exceptional circumstances, no request for rescheduling any appearance in this court will be entertained unless a motion is filed no less than FIVE (5) business days in advance of the date of appearance. PLEASE READ ATTACHED ORDER. Entered by Magistrate Judge N. Reid Neureiter on 12/16/2025. (norlin, ) (Entered: 12/16/2025)

NOTICE of Entry of Appearance by Joshua R. O'Neill on behalf of Carolos Saint Aubin, Louine Jean-Louis, Nesly PierreAttorney Joshua R. O'Neill added to party Carolos Saint Aubin(pty:pla), Attorney Joshua R. O'Neill added to party Louine Jean-Louis(pty:pla), Attorney Joshua R. O'Neill added to party Nesly Pierre(pty:pla) (O'Neill, Joshua) (Entered: 12/16/2025)

NOTICE of Entry of Appearance by Matthew Hale Morgan on behalf of Carolos Saint Aubin, Louine Jean-Louis, Nesly PierreAttorney Matthew Hale Morgan added to party Carolos Saint Aubin(pty:pla), Attorney Matthew Hale Morgan added to party Louine Jean-Louis(pty:pla), Attorney Matthew Hale Morgan added to party Nesly Pierre(pty:pla) (Morgan, Matthew) (Entered: 12/16/2025)

NOTICE of Entry of Appearance by Melia Amal Bouhabib on behalf of All Plaintiffs Attorney Melia Amal Bouhabib added to party Carolos Saint Aubin(pty:pla), Attorney Melia Amal Bouhabib added to party Louine Jean-Louis(pty:pla), Attorney Melia Amal Bouhabib added to party Nesly Pierre(pty:pla) (Bouhabib, Melia) (Entered: 12/17/2025)

SUMMONS Returned Executed by Nesly Pierre, Carolos Saint Aubin, Louine Jean-Louis. Swift Beef Company served on 12/17/2025, answer due 1/7/2026. (O'Neill, Joshua) (Entered: 12/19/2025)

SUMMONS Returned Executed by Nesly Pierre, Carolos Saint Aubin, Louine Jean-Louis. JBS USA Food Company served on 12/18/2025, answer due 1/8/2026. (O'Neill, Joshua) (Entered: 12/19/2025)

NOTICE of Entry of Appearance by Matthew M. Morrison on behalf of JBS USA Food Company, Swift Beef CompanyAttorney Matthew M. Morrison added to party JBS USA Food Company(pty:dft), Attorney Matthew M. Morrison added to party Swift Beef Company(pty:dft) (Morrison, Matthew) (Entered: 12/31/2025)

NOTICE of Entry of Appearance by Amy Christine Knapp on behalf of JBS USA Food Company, Swift Beef CompanyAttorney Amy Christine Knapp added to party JBS USA Food Company(pty:dft), Attorney Amy Christine Knapp added to party Swift Beef Company(pty:dft) (Knapp, Amy) (Entered: 12/31/2025)

STIPULATION for Extension of Time to Answer or Respond to the Complaint filed Jointly by Defendants JBS USA Food Company, Swift Beef Company. JBS USA Food Company answer due 1/29/2026; Swift Beef Company answer due 1/28/2026. (Morrison, Matthew) (Entered: 01/02/2026)

NOTICE of Entry of Appearance by Juno E. Turner on behalf of All Plaintiffs Attorney Juno E. Turner added to party Carolos Saint Aubin(pty:pla), Attorney Juno E. Turner added to party Louine Jean-Louis(pty:pla), Attorney Juno E. Turner added to party Nesly Pierre(pty:pla) (Turner, Juno) (Entered: 01/06/2026)

NOTICE of Entry of Appearance by Toree Lindblad on behalf of All Plaintiffs Attorney Toree Lindblad added to party Carolos Saint Aubin(pty:pla), Attorney Toree Lindblad added to party Louine Jean-Louis(pty:pla), Attorney Toree Lindblad added to party Nesly Pierre(pty:pla) (Lindblad, Toree) (Entered: 01/06/2026)

Unopposed MOTION for Leave to Exceed Page Limitations by Defendants JBS USA Food Company, Swift Beef Company. (Morrison, Matthew) (Entered: 01/26/2026)

MOTION to Strike 1 Complaint, by Defendants JBS USA Food Company, Swift Beef Company. (Knapp, Amy) (Entered: 01/28/2026)

MOTION to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) by Defendants JBS USA Food Company, Swift Beef Company. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O)(Morrison, Matthew) (Entered: 01/28/2026)

CORPORATE DISCLOSURE STATEMENT identifying Corporate Parent JBS USA Food Company Holdings, Other Affiliate JBS NV for JBS USA Food Company, Swift Beef Company. (Morrison, Matthew) (Entered: 01/29/2026)

MINUTE ORDER In light of the pending motions before the Court, it is hereby ORDERED that the parties shall complete and file the Consent/Non-Consent Form (see ECF No. [5-2]), indicating either unanimous consent of the parties or that consent has been declined, on or before February 6, 2026. PLEASE READ ATTACHED MINUTE ORDER. By Magistrate Judge N. Reid Neureiter on 01/29/2026. (jrobe, ) (Entered: 01/30/2026)

CONSENT to Jurisdiction of Magistrate Judge by Plaintiffs Carolos Saint Aubin, Louine Jean-Louis, Nesly Pierre All parties do not consent.. (O'Neill, Joshua) (Entered: 02/03/2026)

REASSIGNING JUDGE. Pursuant to ECF 22, this action is randomly reassigned to Judge Regina M. Rodriguez. All future pleadings should be designated as 25-cv-04023-RMR. (Text Only Entry) (cmadr, ) (Entered: 02/04/2026)

ORDER REFERRING CASE to Magistrate Judge N. Reid Neureiter. Pursuant to 28 U.S.C. § 636(b)(1)(A) and (B) and Fed. R. Civ. P. 72(a) and (b), this case is referred to the assigned United States Magistrate Judge to (1) convene a scheduling conference under Fed. R. Civ. P. 16(b) and enter a scheduling order meeting the requirements of Local Civ. R. 16.2, (2) conduct such status conferences and issue such orders necessary for compliance with the scheduling order, including amendments or modifications of the scheduling order upon a showing of good cause, (3) hear and determine pretrial matters, including discovery and other non-dispositive motions, (4) conduct hearings, including evidentiary hearings, and submit proposed findings of fact and recommendations for rulings on dispositive motions, and (5) pursuant to Local Civ. R. 16.6 and at the discretion of the Magistrate Judge, convene such early neutral evaluation and/or settlement conferences and direct related procedures as may facilitate resolution of this case without the necessity of a motion or prior authorization of the undersigned. SO ORDERED by Judge Regina M. Rodriguez on 2/4/2026. Text Only Entry (rmrja) (Entered: 02/04/2026)

ORDER REFERRING MOTIONS: 17 Unopposed MOTION for Leave to Exceed Page Limitations filed by Swift Beef Company, JBS USA Food Company, 19 MOTION to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) filed by Swift Beef Company, JBS USA Food Company, 18 MOTION to Strike 1 Complaint, filed by Swift Beef Company, JBS USA Food Company.Motions referred to Magistrate Judge N. Reid Neureiter by Judge Regina M. Rodriguez on 2/4/2026. Text Only Entry (rmrja) (Entered: 02/04/2026)

Order Referring Motion

Order Referring Case to Magistrate Judge

MINUTE ORDER by Magistrate Judge N. Reid Neureiter on 2/5/2026. It is hereby ORDERED that Defendants JBS USA Food Company (JBS USA) and Swift Beef Companys ("Swift) Unopposed Motion for Leave to Exceed Page Limitations [ECF No. 17] is GRANTED. PLEASE READ ATTACHED MINUTE ORDER. (msmot, ) (Entered: 02/05/2026)

MINUTE ORDER This matter is before the Court on Defendants JBS USA Food Company and Swift Beef Company's (collectively, "Defendants") Motion to Strike (ECF No. 18 ) and Motion to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) (ECF No. 19). It is hereby ORDERED that the Scheduling Conference currently set for April 9, 2026 at 11:00 a.m. shall be RESET to April 9, 2026 at 3:30 p.m. and CONVERTED to a Scheduling Conference/Motion Hearing. The parties should be prepared to present arguments on the above motions. The Scheduling Conference/Motion Hearing will be conducted in person in Courtroom A-401, Fourth Floor, Alfred A. Arraj United States Courthouse, 901 19th Street, Denver, Colorado 80294. PLEASE READ ATTACHED MINUTE ORDER. By Magistrate Judge N. Reid Neureiter on 02/05/2026. (jrobe, ) (Entered: 02/05/2026)

NOTICE of Entry of Appearance by Hannah M. Wolf on behalf of All Plaintiffs Attorney Hannah M. Wolf added to party Carolos Saint Aubin(pty:pla), Attorney Hannah M. Wolf added to party Louine Jean-Louis(pty:pla), Attorney Hannah M. Wolf added to party Nesly Pierre(pty:pla) (Wolf, Hannah) (Entered: 02/10/2026)

NOTICE of Filing Amended Pleading by Plaintiffs Carolos Saint Aubin, Louine Jean-Louis, Nesly Pierre (Attachments: # 1 Exhibit 1 - Redline)(Prakash, Anna) (Entered: 02/18/2026)

NOTICE of Filing Amended Pleading Corrected Ex 1 by Plaintiffs Carolos Saint Aubin, Louine Jean-Louis, Nesly Pierre (Attachments: # 1 Exhibit 1 - Corrected Redline)(Prakash, Anna) (Entered: 02/18/2026)

AMENDED COMPLAINT against JBS USA Food Company, Swift Beef Company Attorney Anna Purna Prakash added to party Magdala Santus(pty:pla), filed by Nesly Pierre, Carolos Saint Aubin, Louine Jean-Louis, Magdala Santus.(Prakash, Anna) (Entered: 02/18/2026)

STIPULATION re 19 MOTION to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6), 18 MOTION to Strike 1 Complaint, by Plaintiffs Carolos Saint Aubin, Louine Jean-Louis, Nesly Pierre, Magdala Santus. (Prakash, Anna) (Entered: 02/18/2026)

MINUTE ORDER In light of the parties' Stipulation to Withdraw Motions Without Prejudice (ECF No. 32 ), it is hereby ORDERED that the Defendants' Motion to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) (ECF No. 19) and Motion to Strike (ECF No. 18 ) are DENIED as moot. PLEASE READ ATTACHED MINUTE ORDER. By Magistrate Judge N. Reid Neureiter on 02/19/2026.(jrobe, ) (Entered: 02/19/2026)

Unopposed MOTION for Leave to Exceed Page Limitations by Defendants JBS USA Food Company, Swift Beef Company. (Attachments: # 1 Proposed Order (PDF Only))(Morrison, Matthew) (Entered: 02/26/2026)

ORDER REFERRING MOTION: 34 Unopposed MOTION for Leave to Exceed Page Limitations filed by Swift Beef Company, JBS USA Food Company.Motion referred to Magistrate Judge N. Reid Neureiter by Judge Regina M. Rodriguez on 2/26/2026. Text Only Entry (rmrja) (Entered: 02/26/2026)

MINUTE ORDER It is hereby ORDERED that Defendants' Unopposed Motion for Leave to Exceed Page Limitations (ECF No. 34 ) is GRANTED. It is further ORDERED that Defendants may jointly file, pursuant to Fed. R. Civ. P. 12(b)(6) and with a 30-page limitation, a motion to dismiss Plaintiffs' First Amended Class Action Complaint (ECF No. 31 ). PLEASE READ ATTACHED MINUTE ORDER. By Magistrate Judge N. Reid Neureiter on 02/26/2026.(jrobe, ) (Entered: 02/27/2026)

Order Referring Motion

MOTION to Strike 31 Amended Complaint by Defendants JBS USA Food Company, Swift Beef Company. (Knapp, Amy) (Entered: 03/04/2026)

ORDER REFERRING MOTION: 37 MOTION to Strike 31 Amended Complaint filed by Swift Beef Company, JBS USA Food Company.Motion referred to Magistrate Judge N. Reid Neureiter by Judge Regina M. Rodriguez on 3/4/2026. Text Only Entry (rmrja) (Entered: 03/04/2026)

MOTION to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) by Defendants JBS USA Food Company, Swift Beef Company. (Attachments: # 1 Appendix)(Morrison, Matthew) (Entered: 03/04/2026)

Order Referring Motion

ORDER REFERRING MOTION: 39 MOTION to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) filed by Swift Beef Company, JBS USA Food Company.Motion referred to Magistrate Judge N. Reid Neureiter by Judge Regina M. Rodriguez on 3/5/2026. Text Only Entry (rmrja) (Entered: 03/05/2026)

Order Referring Motion

MINUTE ORDER This matter is before the Court on Defendants JBS USA Food Company and Swift Beef Company's (collectively, "Defendants") Motion to Strike (ECF No. 37 ) and Motion to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) (ECF No. 39 ).The parties should be prepared to present arguments on the above motions at the Motion Hearing that is currently set for April 9, 2026 at 3:30 p.m.The Motion Hearing will be conducted in person in Courtroom A-401, Fourth Floor, Alfred A. Arraj United States Courthouse, 901 19th Street, Denver, Colorado 80294.It is so ORDERED. by Magistrate Judge N. Reid Neureiter on 03/06/2026. (jrobe, ) (Entered: 03/06/2026)

Unopposed MOTION for Leave to Exceed Page Limitations by Plaintiffs Carolos Saint Aubin, Louine Jean-Louis, Nesly Pierre, Magdala Santus. (Attachments: # 1 Proposed Order (PDF Only))(Prakash, Anna) (Entered: 03/09/2026)

ORDER REFERRING MOTION: 42 Unopposed MOTION for Leave to Exceed Page Limitations filed by Magdala Santus, Nesly Pierre, Carolos Saint Aubin, Louine Jean-Louis. Motion referred to Magistrate Judge N. Reid Neureiter by Judge Regina M. Rodriguez on 3/9/2026. Text Only Entry (kmyha) (Entered: 03/09/2026)

Memorandum

MINUTE ORDER It is hereby ORDERED that Plaintiffs' Unopposed Motion to Exceed Page Limitations (ECF No. 42 ) is GRANTED. By Magistrate Judge N. Reid Neureiter on 03/10/2026.(jrobe, ) (Entered: 03/10/2026)

Unopposed MOTION to Continue Hearing and Scheduling Conference by Plaintiffs Carolos Saint Aubin, Louine Jean-Louis, Nesly Pierre, Magdala Santus. (Attachments: # 1 Proposed Order (PDF Only))(Prakash, Anna) (Entered: 03/10/2026)

ORDER REFERRING MOTION: 45 Unopposed MOTION to Continue Hearing and Scheduling Conference filed by Magdala Santus, Nesly Pierre, Carolos Saint Aubin, Louine Jean-Louis.Motion referred to Magistrate Judge N. Reid Neureiter by Judge Regina M. Rodriguez on 3/10/2026. Text Only Entry (rmrja) (Entered: 03/10/2026)

Order Referring Motion

MINUTE ORDER It is hereby ORDERED that Plaintiffs' Unopposed Motion to Continue Hearing and Scheduling Conference (ECF No. 45 ) is GRANTED.The hearing currently scheduled for April 9, 2026 at 3:30 p.m. shall be RESET to April 23, 2026 at 2:00 p.m. and will be conducted in person in Courtroom A-401, Fourth Floor, Alfred A. Arraj United States Courthouse, 901 19th Street, Denver, Colorado 80294. PLEASE READ ATTACHED MINUTE ORDER. By Magistrate Judge N. Reid Neureiter on 03/11/2026.(jrobe, ) (Entered: 03/11/2026)

RESPONSE to 37 MOTION to Strike 31 Amended Complaint filed by Plaintiffs Carolos Saint Aubin, Louine Jean-Louis, Nesly Pierre, Magdala Santus. (Prakash, Anna) (Entered: 03/25/2026)

RESPONSE to 39 MOTION to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) filed by Plaintiffs Carolos Saint Aubin, Louine Jean-Louis, Nesly Pierre, Magdala Santus. (Attachments: # 1 Appendix to Response)(Prakash, Anna) (Entered: 03/25/2026)

Unopposed MOTION for Leave to File Excess Pages by Defendants JBS USA Food Company, Swift Beef Company. (Attachments: # 1 Proposed Order (PDF Only))(Morrison, Matthew) (Entered: 04/02/2026)

ORDER REFERRING MOTION: 50 Unopposed MOTION for Leave to File Excess Pages filed by Swift Beef Company, JBS USA Food Company.Motion referred to Magistrate Judge N. Reid Neureiter by Judge Regina M. Rodriguez on 4/2/2026. Text Only Entry (rmrja) (Entered: 04/02/2026)

MINUTE ORDER It is hereby ORDERED that Defendants JBS USA Food Company ("JBS USA") and Swift Beef Company's ("Swift") Unopposed Motion for Leave to Exceed Page Limitations (ECF No. 50 ) is GRANTED. PLEASE READ ATTACHED MINUTE ORDER. By Magistrate Judge N. Reid Neureiter on 04/02/2026.(jrobe, ) (Entered: 04/02/2026)

Order Referring Motion

REPLY to Response to 37 MOTION to Strike 31 Amended Complaint filed by Defendants JBS USA Food Company, Swift Beef Company. (Knapp, Amy) (Entered: 04/08/2026)

REPLY to Response to 39 MOTION to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) filed by Defendants JBS USA Food Company, Swift Beef Company. (Attachments: # 1 Supplemental Appendix)(Morrison, Matthew) (Entered: 04/08/2026)

MOTION for Leave to File Sur-Reply in Support of 49 Response to Motion by Plaintiffs Carolos Saint Aubin, Louine Jean-Louis, Nesly Pierre, Magdala Santus. (Prakash, Anna) (Entered: 04/15/2026)

ORDER REFERRING MOTION: 55 MOTION for Leave to File Sur-Reply in Support of 49 Response to Motion filed by Magdala Santus, Nesly Pierre, Carolos Saint Aubin, Louine Jean-Louis.Motion referred to Magistrate Judge N. Reid Neureiter by Judge Regina M. Rodriguez on 4/15/2026. Text Only Entry (rmrja) (Entered: 04/15/2026)

Order Referring Motion

Proposed Scheduling Order by Plaintiffs Carolos Saint Aubin, Louine Jean-Louis, Nesly Pierre, Magdala Santus. (O'Neill, Joshua) (Entered: 04/16/2026)

RESPONSE to 55 MOTION for Leave to File Sur-Reply in Support of 49 Response to Motion filed by Defendants JBS USA Food Company, Swift Beef Company. (Morrison, Matthew) (Entered: 04/16/2026)

MINUTE ORDER Entered by Magistrate Judge N. Reid Neureiter on 04/16/2026. This matter is before the Court on Plaintiffs' Motion for Leave to File a Sur-Reply in Support of Response in Opposition to Defendants' Motion to Dismiss ("Motion") (ECF No. 55 ). The Court shall address Plaintiffs' Motion at the upcoming hearing on April 23, 2026. PLEASE READ ATTACHED MINUTE ORDER. (agryan) (Entered: 04/16/2026)

MINUTE ENTRY for proceedings held before Magistrate Judge N. Reid Neureiter: Oral Argument/Scheduling Conference held on 4/23/2026:Plaintiffs' Motion for Leave to File a Sur-Reply in Support of Response in Opposition to Defendants' Motion to Dismiss (Dkt. # 55 ) is GRANTED.Defendants' Motion to Strike (Dkt. # 37 ) will be DENIED in part and TAKEN UNDER ADVISEMENT, and Defendants' Motion to Dismiss Pursuant to Fed. R. Civ. Pr. 12(b)(6) (Dkt. # 39 ) is TAKEN UNDER ADVISEMENT.Telephonic Status Conference set for 7/30/2026 at 02:00 PM in Courtroom A 401 before Magistrate Judge N. Reid Neureiter. FTR: Courtroom A401. (rvill, ) (Entered: 04/27/2026)

SURREPLY re 39 MOTION to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) filed by Plaintiffs Carolos Saint Aubin, Louine Jean-Louis, Nesly Pierre, Magdala Santus. (Attachments: # 1 Appendix to Sur-Reply)(O'Neill, Joshua) (Entered: 04/27/2026)

Order to Show Cause

Report and Recommendations

Protective Order

Order Referring Motion

Order on Motion for Protective Order

Protective Order

Extension of Time

Order Referring Motion

Order on Motion for Extension of Time to File