case 6:13-cv-01656-ceh-krs document 1 filed 10/24/13 page 1 … · 2017. 8. 1. · case...

Case 6:13-cv-01656-CEH-KRS Document 1 Filed 10/24/13 of 36 PageID 1


fraudulent, unconscionable, or negligent act employed by Defendant as referenced m this

Complaint, or any other amount authorized by statute;

5. Ordering Defendant to disgorge any ill-gotten benefits received from Plaintiff and

members of the Class as a result of Defendant's false, deceptive or misleading packaging,

labeling, and advertising of its "Humanely Raised" and/or "USDA Process Verified" products or

as a result of Perdue's negligent misrepresentation of its products as "Humanely Raised" and/or

"USDA Process Verified";

6. Awarding reasonable costs and attorneys' fees;

7. Awarding applicable pre-judgment or post-judgment interest; and

8. Awarding such other and further relief as the Court may deem necessary or

appropriate.

Dated: October 23, 2013. Respectfully submitted,

[email protected] Jason H. Alperstein Fla. Bar No. 064205 [email protected] 200 S.W. 1st Avenue, 12th Floor Fort Lauderdale, FL 33301 Telephone: (954) 525-4100 Facsimile: (954) 525-4300

Co-Counsel for Plaintiff and the Proposed Class

35

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