Poultry Wages Settlement
Official Website
(866) 555-5555

If You Received a Notice You Can Update Your Information and Update Your Earnings.

If You Did Not Get a Notice by Email or Postcard You Can Participate Now.

Check to See if You Worked in a Covered Poultry Processing Place Between 2000 and 2021.


A federal court has authorized this. It is not a solicitation from a lawyer.
Did you work in Poultry Processing between 2000 and 2021?
You Could Get Money from Settlements

Poultry workers sued their employers because they believe they were not paid enough. This is called a lawsuit. Some poultry companies agreed to pay these employees $217.25 million to stop the lawsuit. This is called a settlement. If you worked for one of these companies between 2000 and 2021, you may be able to get some of this money.

If you were a poultry employee, you have three options:

1. Do nothing. If you do nothing, you will continue to be part of this lawsuit. Your rights will be affected. You may get money. You may still need to fill out a form to get your money . If you need to fill out a form, you must do it byMonth 00, 202X. You may have some questions about the form. See Questions 16-20.

2. Object to the settlements. You can tell the judge in this case that you do not like the settlements. This is called “objecting.” You have until Month 00, 202X to object to the settlements. You may have some questions about how to object. See Questions 25-28.

3. Opt out of the lawsuit. You can choose to no longer be part of this lawsuit. This is called “opting out.” If you opt out, this lawsuit will not affect your rights. You will not get any money. You have until Month 00, 202X to opt out. You may have some questions about how to opt out. See Questions 22-24.

If you have questions or need help, please go to www.PoultryWages.com or call 1-800-000-0000.

This Notice


1. Why did I get a notice?

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You got a notice because records show you work or used to work for a poultry company that was sued in this lawsuit. Some poultry companies agreed to pay $217.25 million in settlements to stop this lawsuit.

You may be part of the group of people affected, called the “Class.” The Court will hold a hearing on [Month 00, 2024] to decide if it will approve the settlements. Your rights may be affected.


2. What do I do next?

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Read this information to see if you are part of the lawsuit and learn more about the settlements and your choices. Then, decide if you need to take any action.

3. What is this lawsuit about?

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This lawsuit says that some poultry companies talked to each other about how much to pay their workers in a way that was against the law and allowed them to pay workers less money than they should have.

Several workers sued the poultry companies that they say did this. The people who sued – and the people like them - are called the “Plaintiffs.” The poultry companies they sued are called the “Defendants.” The Defendants say they did nothing wrong.

4. What can I do?

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You need to decide if you want to:

Option Summary Important Date Go to Questions:
GET MONEY If you got a notice in the mail or by email, you do not need to do anything to get money. You can update and add your contact, employment and earnings information here.

If you did not get a notice, you need to fill out a participation form to get money.

You can’t sue the Defendants on your own about the claims in this lawsuit.
Month 00, 202X 14-18
OPT OUT Get no money from the settlements. But you can sue the Defendants on your own about the claims in this lawsuit. Month 00, 202X 20-22
OBJECT Tell the Court why you don’t like the Settlements. Month 00, 202X 23-26
DO NOTHING If you got a notice in the mail or by email, you will get money. You can’t sue the Defendants on your own about the claims in this lawsuit. 19
GO TO A HEARING Go to the hearing. Ask the Court if you can speak about the fairness of the Settlement. Month 00, 202X 29-33

5. What is this lawsuit called?

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This lawsuit is called Jien v. Perdue Farms, No. 1:19-cv002521.

6. What Court is this lawsuit in?

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This lawsuit is in the United States District Court for the District of Maryland.

7. Who is the judge?

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The judge in this lawsuit is Judge Stephanie A. Gallagher.

8. What is a class action lawsuit?

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In a class action lawsuit, one or more people sue on behalf of a larger group. The people who represent the group are called “Class Representatives.” The whole group of people is called a “Class.” Individual people in the class are called “Class Members.”

9. Who represents this class?

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The people who represent this class are Judy Jien, Kieo Jibidi, Elaisa Clement, Glenda Robinson, and Emily Earnest.

10. Who are the Defendants in this lawsuit?

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The Defendants in this lawsuit are:

• Agri Stats
• Allen Harim
• Amick Farms
• Butterball
• Cargill Meat Solutions
• Case (Case Farms, LLC and Case Foods, Inc.)
• Fieldale Farms
• Foster Farms
• George’s (George’s, Inc. and George’s Foods, LLC)
• Jennie-O Turkey Store
• Keystone Foods
• Koch Foods
• Mountaire Farms
• O.K. Foods
• Peco Foods
• Perdue (Perdue Farms, Inc. and Perdue Foods, Inc.)
• Pilgrim’s Pride
• Sanderson Farms
• Simmons Foods
• Tyson Foods
• Wayne Farms
• Webber, Meng, Sahl and Company (“WMS”)

11. What are the workplaces?

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Click here to see if the place you worked at is on the list.

12. What Defendants have settled in this case?

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This is a list of the Defendants who have settled and the amount they are paying the classes:

• Pilgrim: $29,000,000.00
• Perdue: $60,650,000.00
• Sanderson: $38,300,000.00
• Wayne: $31,500,000.00
• Mountaire: $13,500,000.00
• Cargill: $15,000,000.00
• Simmons: $12,000,000.00
• Peco: $3,000,000.00
• George’s: $5,800,000.00
• Case: $8,500,000.00

One additional defendant, WMS, has settled without payment to the class but has provided cooperation to the benefit of the classes and named plaintiffs.

13. Why are there settlements in this lawsuit?

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The Court has not decided who is right. Instead, both sides agreed to settle. A settlement is an agreement to stop the lawsuit. That way, it avoids the cost of a trial, and the people in the class will get money. The class representatives and the attorneys think the settlement is best.

14. How do I know if I am in the class?

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You are in the class if you:

• Worked at any of the Defendants’ poultry processing complexes, plants, hatcheries, and feed mills,
• In the United States,
• from January 1, 2000 until July 20, 2021.

However, if you only worked for Pilgrim’s Pride, George’s, and/or George’s Foods, you are only part of the class if you worked in poultry processing plants in the United States from January 1, 2009 until July 20, 2021. Employees of these three Defendants who only worked in poultry hatcheries and feed mills are not a part of the class.

If you got a postcard or email notice, records show you are in the class.

If you did not get postcard or email notice, you may still be in the class:

• Click here to see if the records show you are a class member.
• If your name is not in the records, click here to see if your employer or the place you worked at is on the list.

The Settlement Administrator reserves the right to ask Class Members and anyone who seeks to participate in the Class to provide additional documentation. You understand participation in these settlements may be denied if you are unable to provide adequate documentation if asked to do so.

Still not sure? Get free help:

• Call 1-800-000-0000
• Email [XXXX]
• Write to [ADDRESS]

15. What do I get from the settlements?

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If the Court approves the settlements, you will get money. Defendants will pay $217,250,000 total. This money will be paid pro rata to class members, depending on the amount of money each class member earned during the class periods. This is why it is important that you make sure the information we have for you is correct.

This money will be used to pay:

• Money to class members (see Question 16),

• Attorneys’ fees up to 33.33% of the settlements ($72,409,425) plus interest earned on that amount, and costs up to $8.5 million,

• $XXXX Notice and administration costs, and

• An $30,000 award to each class representative.

Defendants also will cooperate with the lawsuit.

16. How much money will I get?

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At this time, it is not known how much money you will get. Money will be paid proportionally (or pro rata) to class members. The amount of money you get will depend on:

• How many people are in the class,
• How long you worked for the Defendant(s),
• How much money you made, and
• The amount of money the Court approves for costs, fees, and awards.

This is why it is important that you make sure the information we have for you is correct.

17. How can I get money?

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If you: To Get Money
Got a postcard or email notice Do nothing. You will get money. You can update and add your contact, employment, and earnings information here to make sure your money gets to you.
Did not get a postcard or email notice You need to fill out and send in a participation form:

• Online: Click here to fill out and submit the participation form.

OR

• Mail: Print the participation form here or call 1-800-000-0000 to ask for one. Fill out the participation form and mail it to:

Poultry Wages Settlement
c/o A.B. Data, Ltd.
P.O. Box 0000
Milwaukee, WI 53217
Your participation form must be submitted online or postmarked by [MONTH 00, 2024.

If your participation form is approved, you will get money.

18. How do I update my contact, employment, and earnings information

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To update or change your contact, employment, and earnings information, you can:

• Click here to search for your information in the records. When your information appears, you can update or change your contact, employment, and/or earnings information.
• Call 1-800-000-0000.
• Email XXXXX.

19. How will my information be used?

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If you give personal information to make sure you get the correct payment, your information will be treated as confidential. The Court decided that any information you will only be used by the claims administrator and cannot be given to anyone else without a Court order.

20. When will I get paid?

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You will get paid after the settlements are approved and any appeals end. This process can take time. Please check this website for updates.

21. What happens if I stay in the class?

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If you stay in the class (and if you do nothing), you may get money. But, you will also “release” or give up all the claims made in this lawsuit. That means you cannot sue the Defendants on your own for these same claims.

These claims you are giving up are described in documents called “Settlement Agreements.” They are available here.

22. What does it mean to “opt out”?

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Opting out means to leave the class. You can opt out of the class if you want to sue the Defendants on your own about the claims in this lawsuit with your own lawyer. You will not get money from the settlements, and you will not be able to object to the settlements. This lawsuit will not affect you if you opt out.

23. How do I opt out?

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To opt out, you must mail a letter to the Settlement Administrator by [Month 00, 2024]. You may opt out of one, more than one, or all the settlements.

Your letter must include:

• Your name,
• Your address,
• Your notice ID number (if you have one),
• A sentence saying, “I want to opt out from the class in Jien v. Perdue Farms.” If you only want to opt-out of some settlements, write the name(s) of those Defendant(s), and
• Your signature (you must sign the letter).

You must mail your opt out request postmarked no later than [Month 00, 2024], to:

Poultry Wages Settlement
Opt Out
c/o A.B. Data, Ltd.,
PO Box 0000
Milwaukee, WI 53217

24. If I opt out, can I still get money from the settlements?

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No. If you opt out, you will not get money from the settlements.

25. What does it mean to “object”?

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Objecting is when you tell the Court that you don’t like something about the settlements. You give reasons why you think the Court should not approve it. The Court will consider your views. You can hire your own lawyer to help you, but you don’t have to.

26. How do I object?

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To object, you must mail a letter to the Court. Your letter must include:

• Your name,
• Your address,
• Your telephone number,
• Your notice ID number (if you have one),
• The reason(s) you object to the settlements,
• Your lawyer’s name (if you have one),
• A statement saying that you object to Jien v. Perdue Farms,
• A statement saying if you (or your lawyer) want to speak at the hearing, and
• Your signature (you must sign the letter).

You must mail your objection postmarked no later than [Month 00, 2024] to these two addresses:

Court Settlement Administrator
Clerk
United States District Court
District of Maryland
101 West Lombard Street
Chambers 7C
Baltimore, MD 21201
Poultry Wages Settlement
Objections
c/o A.B. Data, Ltd.,
PO Box 0000
Milwaukee, WI 53217

27. If I object, will the judge change the settlements?

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No. The judge cannot change the settlement terms. She can only approve or not approve the settlements as they are. If the judge agrees with your objection, she may not approve the settlements.

28. Can I object if I opt out?

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No. You cannot object if you opt out. Only class members can object to the settlements. If you opt out, you will no longer be in the class.

29. Do I have a lawyer in this lawsuit?

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Yes. The judge assigned lawyers from three law firms to represent you and the other class members in this lawsuit. The law firms are Hagens Berman Sobol Shapiro LLP; Handley Farah & Anderson PLLC; and Cohen Milstein Sellers & Toll PLLC. These lawyers are called “Class Counsel.”

You will not be charged for these lawyers, and you can contact them for free. If you want to be represented by your own lawyer, you can hire one, but you may have to pay them.

30. Do I have to pay the lawyers in this lawsuit?

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No. Class Counsel will ask the judge for attorneys’ fees up to 33.33% of the settlements ($72,409,425) plus interest earned on that amount and costs up to $8.5 million. They have not been paid yet for their work on this lawsuit.

Class Counsel will also ask the judge for a $30,000 award for each of the class representatives. Awards are given to the class representatives for their help. If the judge approves any attorneys’ fees and costs or service awards, the settlements will pay them.

31. What happens next in this lawsuit?

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The judge will hold a hearing to decide if it will approve these settlements. The judge’s decision after the hearing will affect the rights of all class members. The settlements will only go into effect if the judge approves them. If you wish, you may attend the hearing.

The hearing is scheduled for [Month 00, 2024] at X:00 x.m., at:

United States District Court, District of Maryland
101 West Lombard Street, Chambers 7C
Baltimore, MD 21201

The judge may decide to move the hearing to a different date or time. Check www.PoultryWages.com for updates.

32. What happens at the hearing?

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At the hearing, the Court will consider if it will approve the settlements. The Court may consider any objections at that time. The judge will listen to people who have asked to speak at the hearing. The Court may decide how much it wants to pay Class Counsel and the class representatives.

33. What happens after the hearing?

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After the hearing, the Court will decide whether to approve the settlements. We do not know how long this decision will take.

34. Do I have to come to the hearing?

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No. You do not have to come to the hearing, but you are welcome to come at your own cost.

If you mail a written objection to the Court on time, the judge will consider it. This is true even if you do not come to Court to talk about it.

You may also pay your own lawyer to attend, but you do not have to.

35. Can I ask to speak at the hearing?

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Yes. You may ask for permission to talk at the hearing. To ask to speak, you must mail a letter to the Court by [Month 00, 2024].

Your letter must include:

• Your name,
• Your address,
• Your telephone number,
• A statement saying that you (or your lawyer) want to speak in Jien v. Perdue Farms, and
• Your signature (you must sign the letter).

You must mail your letter postmarked no later than [Month 00, 2024] to these two addresses:

Court Settlement Administrator
Clerk
United States District Court
District of Maryland
101 West Lombard Street
Chambers 7C
Baltimore, MD 21201
Poultry Wages Settlement
Objections
c/o A.B. Data, Ltd.,
PO Box 0000
Milwaukee, WI 53217

36. How do I decide what to do?

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Your choices are to:

• Stay in the class and get money.

• If you got a notice in the mail or by email: Do nothing. You will get money. You can update and add your contact, employment and earnings information here to make sure your money gets to you.

• If you did not get a notice by mail or email: Fill out the participation form here to ask for money.

• Stay in the class and object to the settlements and/or ask to speak at the hearing.

• Opt out of the class.

This chart shows the effects of each choice:

Stay in Class Object Opt Out of Class
Can I get money if I . . . YES YES NO
Will the Court’s decisions in this lawsuit affect me if I . . . YES YES NO
Can I sue the Defendants myself for these claims if I . . . NO NO YES

37. How do I get more information?

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This notice is a summary. More details and documents about the settlements can be found here.

You can also get court documents online on the Court Electronic Records (PACER) system or by visiting the Clerk’s office of the Court (address below). If you have more questions:

• Call: 1-800-000-0000
• Email: XXXX
• Write to: Poultry Wages Settlement, c/o A.B. Data, Ltd., PO Box 0000, Milwaukee, WI 53217

What else can I find on this website?

• A tool to check if you are in the class.
• A tool to check and update your contact information.
• A tool to see if the place you worked at is on the list.
• A participation form (if you aren’t sure if you need one, click here for more information).
• Important case documents.
• Contact information.

Resource List

Case website www.PoultryWages.com
Settlement Administrator Poultry Wages Settlement
c/o A.B. Data, Ltd.,
PO Box 0000
Milwaukee, WI 53217
Phone: 1-800-000-0000
Email: XXXXX
Class Counsel
(Contact For Free)
Shana E. Scarlett
Hagens Berman Sobol Shapiro LLP
715 Hearst Avenue
Suite 202
Berkeley, CA 94710
George F. Farah
Handley Farah Anderson Law Firm
33 Irving Place
New York, NY 10003
Brent W. Johnson
Cohen Milstein Sellers & Toll PLLC
1100 New York Ave. NW
Suite 500, West Tower
Washington, DC 20005
Court (DO NOT CONTACT WITH QUESTIONS ABOUT THIS CASE) United States District Court
District of Maryland
101 West Lombard Street
Chambers 7C
Baltimore, MD 21201