UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
MONSANTO COMPANY,
Plaintiff,
v.
JUSTICE FAMILY FARMS, LLC,
Defendant.

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Case No. 4:18-cv-01787

PLAINTIFF MONSANTO COMPANY’S
MOTION TO REQUEST CERTIFIED COPY OF SEALED JUDGMENT
Plaintiff Monsanto Company (“Plaintiff” or “Monsanto”), by and through its undersigned
counsel, respectfully moves this Court for an Order granting Monsanto’s request for a certified
copy of the consent judgment filed under seal in this case for purposes of executing this
judgment against Defendant Justice Family Farms, LLC (“Defendant” or “Justice”) pursuant to
28 U.S.C. § 1963. In support of its motion, Monsanto states the following:
1.

On January 30, 2019, Monsanto moved this Court to enforce the Confidential

Settlement Agreement and Contingent Release of Liability (the “Settlement Agreement”) entered
into by the parties and for entry of the agreed upon Final Consent Judgment in the amount of
$814,444.59, including late fees in amount of 18% APR running from November 25, 2017 until
the full payment is made. See Motion to Enforce Settlement Agreement and Entry of Final
Consent Judgment, at Dkt. No. 6.
2.

Monsanto moved this Court to file its Motion to Enforce Settlement Agreement

and Entry of Final Consent Judgment under seal “because the pleading incorporates and
discusses confidential information related to settlement of this matter.” See Motion for Leave to
File Under Seal, at Dkt. No. 5.

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 3.

On January 31, 2019, this Court granted Monsanto’s Motion for Leave to File

Under Seal. See Order, at Dkt. No. 8.
4.

On September 13, 2019, this Court granted Monsanto’s Motion to Enforce

Settlement Agreement and Entry of Final Consent Judgment and entered the Final Consent
Judgment separately. See Memorandum and Order and Docket Text, at Dkt. Nos. 8 and 9.
5.

Monsanto now seeks to enforce the Final Consent Judgment in, at least, the State

of Virginia where Justice is currently situated.
6.

In order to do so, Monsanto must obtain a certified copy of the sealed Final

Consent Judgment. See 28 U.S.C. § 1963 (“A judgment in an action for the recovery of money
or property entered in any court … may be registered by filing a certified copy of the judgment
in any other district… A judgment so registered shall have the same effect as a judgment of the
district court of the district where registered and may be enforced in like manner.”).
WHEREFORE, Plaintiff Monsanto Company prays for an Order granting Plaintiff’s
Motion to Request Certified Copy of Sealed Judgment, along with a certified copy of the sealed
Final Consent Judgment, and for such other and further relief as the Court deems just and proper.

Respectfully submitted,
HUSCH BLACKWELL LLP
By: /s/ Matthew R. Grant
Matthew R. Grant, #50312MO
190 Carondelet Plaza, Suite 600
St. Louis, MO 63105
(314) 480-1500
(314) 480-1505 (fax)
Matt.grant@huschblackwell.com
Attorneys for Plaintiff Monsanto Company

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 CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the 28th day of February, 2020, the foregoing
was filed electronically with the Clerk of the Court for the United States District Court for the
Eastern District of Missouri, Eastern Division, and was served by U.S. mail, upon the following:
JUSTICE FAMILY FARMS, LLC
c/o CT Corporation System
2 Office Park Ct., STE 103
Columbia, South Carolina 29223
/s/ Matthew R. Grant

DocID: 4838-4162-8086.1