Jirek, et al. v. AstraZeneca Pharmaceuticals LP
Case No. 1:21-cv-06929
United States District Court for the North District of Illinois
NOTICE OF PENDENCY OF LAWSUIT
TO: ALL PRESENT AND FORMER PHARMACEUTICAL SALES REPRESENTATIVES OR PHARMACEUTICAL SALES SPECIALISTS EMPLOYED BY ASTRAZENECA PHARMACEUTICALS LP FROM FEBRUARY 15, 2020 TO THE PRESENT.
THIS IS A COURT AUTHORIZED NOTICE. THIS IS NOT A SOLICITATION FROM A LAWYER. THE COURT TAKES NO POSITION REGARDING THE MERITS OF THE PLAINTIFFS’ CLAIMS OR DEFENDANT’S DEFENSES.
Read this notice, this lawsuit may affect your rights.
INTRODUCTION
The purpose of this Notice is to inform you of a collective action lawsuit that you may be eligible to join, to advise you of how your rights might be affected by this lawsuit, and to instruct you on the procedures to opt into the lawsuit if you choose to do so.
DESCRIPTION OF THE ACTION
On December 30, 2021 a Complaint was filed against the Defendant AstraZeneca Pharmaceuticals LP (“AstraZeneca” or “Defendant”) in the US District Court for the Northern District of Illinois, entitled Natalie Jirek, et al. v. AstraZeneca Pharmaceuticals, LP, Case No. 1:21-cv-06929 (the “Lawsuit”). The Lawsuit includes claims by the named Plaintiffs on behalf of all other allegedly similarly situated individuals who worked for Defendant as a Pharmaceutical Sales Representative or Pharmaceutical Sales Specialist (collectively “Sales Representatives”) in the United States from February 15, 2020 through the present.
PLAINTIFFS’ POSITION
Plaintiffs seek to bring claims on behalf of themselves and these Sales Representatives under the Equal Pay Act of 1963, as amended, 29 U.S.C. § 206(d) (“EPA”). Plaintiffs claim that the Defendant paid them and other female Sales Representatives less than they paid male Sales Representatives for performing the same or substantially the same work for jobs the performance of which required substantially similar skill, effort, and responsibility, and which were performed under similar working conditions.
DEFENDANT’S POSITION
Defendant denies Plaintiffs’ claims, denies that it has violated the law, and denies that this Lawsuit ultimately can proceed on behalf of Sales Representatives other than the named Plaintiffs.
The Court will decide all of these issues as the Lawsuit proceeds, and has not made any ruling on any of these issues as of the present time.
COMPOSITION OF THE POTENTIALLY SIMILARLY SITUATED GROUP
The Plaintiffs all worked as Sales Representatives during their employment with Defendant. The Plaintiffs seek to sue on behalf of themselves and other individuals with whom they claim to be similarly situated. Specifically, they seek to sue on behalf of any and all individuals who meet the following requirements:
- You are female;
- You worked in a non-managerial, Sales Representative or Sales Specialist position for AstraZeneca in the United States at any point from February 15, 2020 to the present; and
- you believe you have been paid less than male Sales Representatives or Sales Specialists who performed equal or substantially equal work as you because of your gender.
YOUR RIGHT TO PARTICIPATE IN THIS LAWSUIT
If you fit the description above, you may choose to join this Lawsuit by mailing, faxing, or emailing the Consent Form to the Administrator, Analytics Consulting:
Jirek v. AstraZeneca
c/o Analytics Consulting LLC
PO Box 2002
Chanhassen, MN 55317-2002
Telephone: 877-883-8435
Fax: (952) 404-5750
Email: azepalawsuit@noticeadministrator.com
The Consent Form must be received by the Administrator on or before Monday, August 19, 2024 for you to participate in this case.
If you do not submit the Consent Form within 60 days, you will not be able to join this Lawsuit.
EFFECT OF JOINING OR NOT JOINING THIS ACTION
If you join this Lawsuit, the Court will determine later in the Lawsuit whether the named Plaintiffs may sue on behalf of Sales Representatives other than themselves, including you. If the Court decides at some point that Plaintiffs may sue on behalf of other Sales Representatives including you, you and the Defendant will be bound by any ruling, judgment, award, or settlement, whether favorable or unfavorable. If you do not join this Lawsuit, or if the Court decides that the Plaintiffs may not sue on behalf of others including you, you will not be bound by any ruling, judgment, award, or settlement in this case, favorable or unfavorable. If you choose not to join this Lawsuit, you are free to take action on your own or to do nothing at all.
If you join this Lawsuit, you may be required to provide information or to otherwise participate in it, including participating in what is called “discovery.” Such participation may include, for example, complying with and responding to written discovery requests directed to you from Defendant, providing your deposition testimony, participating in a trial, and/or traveling to the Northern District of Illinois, which includes the Chicago, Illinois metropolitan area. As noted, if you file a Consent Form, your continued right to participate in this Lawsuit will depend upon a later decision by the Court that you, the named Plaintiffs, and the other Sales Representatives that seek to join in this Lawsuit are “similarly situated” in accord with applicable law, and that it is appropriate for the case to proceed as a “collective action.”
STATUTE OF LIMITATIONS
The Equal Pay Act has a maximum statute of limitations of three years. If you choose not to join in this Lawsuit or file your own action at a later date, your potential claims under the Equal Pay Act may be barred by the statute of limitations.
NO RETALIATION PERMITTED
The law prohibits retaliation against employees for exercising their rights under the Equal Pay Act. Therefore, the Defendant is prohibited from discharging you or otherwise retaliating against you in any manner because you choose to participate in this Lawsuit.
YOUR LEGAL REPRESENTATION IF YOU JOIN
If you choose to join the case by filing a Consent Form, you will be agreeing to be represented by Plaintiffs’ Counsel, Caffarelli & Associates Ltd.
Caffarelli & Associates Ltd.
Attn: Alejandro Caffarelli
224 S. Michigan Ave, Ste. 300
Chicago, Illinois 60604
Telephone (312) 763-6880
Plaintiffs’ Counsel has taken this case on a contingency basis. They may be entitled to receive attorneys’ fees and costs from the Defendant, should there be recovery or judgment in Plaintiffs’ favor. If there is a recovery, Plaintiffs’ Counsel will receive a part of any settlement obtained or money judgment entered and may receive fees ordered by the Court. Any payment of fees will require approval of the Court. If there is no recovery or judgment in Plaintiffs’ favor, Plaintiffs’ Counsel will not seek any attorneys’ fees or costs from any of the Plaintiffs.
DEFENSE COUNSEL
Defendant AstraZeneca is represented by attorneys Jonathan D. Lotsoff, Eric C. Kim, and Andrea N. Threet at the law firm of Morgan Lewis & Bockius LLP.
THIS NOTICE AND ITS CONTENTS HAVE BEEN AUTHORIZED BY THE U.S. DISTRICT COURT, NORTHERN DISTRICT OF ILLINOIS, JUDGE SARA L. ELLIS. THE COURT TAKES NO POSITION REGARDING THE MERITS OF THE PLAINTIFFS’ CLAIMS OR DEFENDANT’S DEFENSES.
Do Not Contact the Clerk of the Court
Regarding This Notice.
EFFECT OF JOINING OR NOT JOINING THIS ACTION
If you join this Lawsuit, the Court will determine later in the Lawsuit whether the named Plaintiffs may sue on behalf of Sales Representatives other than themselves, including you. If the Court decides at some point that Plaintiffs may sue on behalf of other Sales Representatives including you, you and the Defendant will be bound by any ruling, judgment, award, or settlement, whether favorable or unfavorable. If you do not join this Lawsuit, or if the Court decides that the Plaintiffs may not sue on behalf of others including you, you will not be bound by any ruling, judgment, award, or settlement in this case, favorable or unfavorable. If you choose not to join this Lawsuit, you are free to take action on your own or to do nothing at all.
If you join this Lawsuit, you may be required to provide information or to otherwise participate in it, including participating in what is called “discovery.” Such participation may include, for example, complying with and responding to written discovery requests directed to you from Defendant, providing your deposition testimony, participating in a trial, and/or traveling to the Northern District of Illinois, which includes the Chicago, Illinois metropolitan area. As noted, if you file a Consent Form, your continued right to participate in this Lawsuit will depend upon a later decision by the Court that you, the named Plaintiffs, and the other Sales Representatives that seek to join in this Lawsuit are “similarly situated” in accord with applicable law, and that it is appropriate for the case to proceed as a “collective action.”
STATUTE OF LIMITATIONS
The Equal Pay Act has a maximum statute of limitations of three years. If you choose not to join in this Lawsuit or file your own action at a later date, your potential claims under the Equal Pay Act may be barred by the statute of limitations.
NO RETALIATION PERMITTED
The law prohibits retaliation against employees for exercising their rights under the Equal Pay Act. Therefore, the Defendant is prohibited from discharging you or otherwise retaliating against you in any manner because you choose to participate in this Lawsuit.
YOUR LEGAL REPRESENTATION IF YOU JOIN
If you choose to join the case by filing a Consent Form, you will be agreeing to be represented by Plaintiffs’ Counsel, Caffarelli & Associates Ltd.
Caffarelli & Associates Ltd.
Attn: Alejandro Caffarelli
224 S. Michigan Ave, Ste. 300
Chicago, Illinois 60604
Telephone (312) 763-6880
Plaintiffs’ Counsel has taken this case on a contingency basis. They may be entitled to receive attorneys’ fees and costs from the Defendant, should there be recovery or judgment in Plaintiffs’ favor. If there is a recovery, Plaintiffs’ Counsel will receive a part of any settlement obtained or money judgment entered and may receive fees ordered by the Court. Any payment of fees will require approval of the Court. If there is no recovery or judgment in Plaintiffs’ favor, Plaintiffs’ Counsel will not seek any attorneys’ fees or costs from any of the Plaintiffs.
DEFENSE COUNSEL
Defendant AstraZeneca is represented by attorneys Jonathan D. Lotsoff, Eric C. Kim, and Andrea N. Threet at the law firm of Morgan Lewis & Bockius LLP.
THIS NOTICE AND ITS CONTENTS HAVE BEEN AUTHORIZED BY THE U.S. DISTRICT COURT, NORTHERN DISTRICT OF ILLINOIS, JUDGE SARA L. ELLIS. THE COURT TAKES NO POSITION REGARDING THE MERITS OF THE PLAINTIFFS’ CLAIMS OR DEFENDANT’S DEFENSES.
Do Not Contact the Clerk of the Court
Regarding This Notice.