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1
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COMPLAINT
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EXTRACTED KEY WORDS
ILLEGAL IMMIGRANT EMPLOYMENT WAGES HIRING SCHEME RECRUITERS IMMIGRANT HIRING WORKERS FACILITY JOSLIN PLAINTIFFS DEPRESS ILLINOIS KNOWING RICO RACKETEERING ACTIVITY WAGES PAID ACT CLASS MEMBERS PAY CANDIDATES MEAT PROCESSORS VIOLATION HARBORING PURSUANT DISCIPLINE NETWORK HOUSING ENTERPRISE PLANT |
IN THE UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF ILLINOIS
ROCK ISLAND DIVISION
DEBORAH BAKER and RICHARD
ENYEART, individually and on behalf of all
others similarly situated,
Plaintiffs,
No.
v.
IBP, Inc., a Delaware Corporation
Defendant.
COMPLAINT
I. NATURE OF ACTION
1. This is a class action brought on behalf of all persons legally authorized
employed in the United States ("U.S.") who have been employed by defendant IBP, Inc. (IBP),
one of the world's largest producers of fresh beef and pork-related beef products, as hourly wage
earners in its Joslin, Illinois meat processing facility during the last four years.
2. The Complaint contends that all such persons have been victimized by a
perpetrated by IBP to depress the wages paid to its employees by knowingly hiring a workforce
substantially comprised of undocumented illegal immigrants for the express purpose of
depressing wages (hereafter "the Illegal Immigrant Hiring Scheme").
3. IBP perpetrates the Illegal Immigrant Hiring Scheme through a complex and
highly disciplined network of recruiters throughout the world, who obtain illegal immigrants,
provide for their transportation to the U.S., housing in the U.S., documentation and other
necessities of life so that they can be employed and exploited by IBP at depressed wages.
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