Federal Fraud Lawsuit Filed: Hollingsworth v. Sanofi et al.

Filed December 11, 2025 — U.S. District Court, District of Oregon

Case No. 3:25-cv-2308-SB

Filed on December 11, 2025, this federal civil action alleges that the employment relationship presented to Plaintiff was part of a broader corporate structure that concealed the identity of the entities allegedly directing payroll, employment functions, and operational control. The Complaint asserts claims for fraud, fraudulent concealment, civil conspiracy, alter ego liability, successor liability, and related causes of action arising from that alleged structure.

According to the Complaint, Plaintiff’s investigation expanded beyond a single employing entity after reviewing corporate filings, payroll records, business registrations, and other publicly available information. That investigation allegedly revealed a network of affiliated entities through which employment responsibilities, payroll functions, and corporate control were structured in a manner that obscured the identity of the parties ultimately responsible for employment-related decisions.

The Complaint further alleges that this structure has broader implications extending beyond Plaintiff’s individual employment. It contends that the use of multiple affiliated entities may affect employees, whistleblower proceedings, labor claims, regulatory oversight, and other legal obligations by requiring individuals to pursue claims against nominal employing entities while questions remain regarding the role of upstream companies and related organizations. Those allegations also formed the basis for disclosures to multiple government agencies and separate whistleblower proceedings under federal law.

This federal action is distinct from the related JAMS arbitration and Department of Labor whistleblower proceeding. The arbitration is limited to issues arising under an employment arbitration agreement, while the Department of Labor proceeding concerns federal whistleblower protections. By contrast, this case asks the federal court to determine whether the allegations concerning the broader corporate structure, employer identity, and related claims are sufficient to proceed under federal law.

The sections below summarize the procedural history of the case and provide access to the principal court filings, motions, orders, and other publicly filed documents as the litigation has progressed.

Current Status as of July 9, 2026

The case is currently pending before the United States District Court for the District of Oregon.

After briefing on Defendants’ motions to dismiss, a United States Magistrate Judge issued Findings and Recommendation recommending dismissal of the Complaint. Because a Findings and Recommendation is not a final decision of the Court, Plaintiff timely filed objections requesting that the assigned District Judge conduct a de novo review of the challenged portions of the recommendation.

Defendants, represented by Fisher Phillips LLP, Jackson Lewis P.C., and Faegre Drinker Biddle & Reath LLP, have each filed responses urging the District Judge to adopt the Findings and Recommendation and overrule Plaintiff’s objections. The objections and responses are now fully briefed, and the matter is awaiting a final decision from the District Judge.

The District Judge will independently review the challenged portions of the Findings and Recommendation, together with Plaintiff’s objections and Defendants’ responses, before determining whether the case will proceed, whether any claims will remain, or whether the action will be dismissed.

Filing of the Complaint

On December 11, 2025, Plaintiff filed this action in the United States District Court for the District of Oregon against Sanofi-Aventis U.S. LLC, Chattem Inc., Quten Research Institute LLC, AMJ Services LLC, and Steven S. Dickert, in his capacity as Trustee of Basil Management Trust.

The Complaint alleges that the entity identified as Plaintiff’s employer operated within a broader corporate structure involving affiliated companies, shared management, and related business entities. According to the Complaint, that structure concealed the identity of the entities allegedly exercising operational control while limiting accountability to a nominal employing entity.

The Complaint further alleges that public corporate filings, payroll records, business registrations, and other documentary evidence demonstrate coordination among multiple entities and that this structure affected payroll administration, employer identification, and the allocation of legal responsibility. Based on those allegations, the Complaint asserts claims for fraud, fraudulent concealment, civil conspiracy, alter ego liability, successor liability, and related causes of action.

This filing marked the beginning of the federal litigation and placed the alleged corporate structure, supporting public records, and legal theories before the Court for review.

Filed Documents

Appearances of Counsel

Following service of the Complaint, Defendants retained separate national law firms to represent the various entities and individuals named in the action.

Fisher Phillips LLP appeared on behalf of AMJ Services LLC and Steven S. Dickert, in his capacity as Trustee of Basil Management Trust.

Faegre Drinker Biddle & Reath LLP appeared on behalf of Sanofi-Aventis U.S. LLC, Chattem Inc., and Quten Research Institute LLC.

As the litigation progressed, Jackson Lewis P.C. also appeared on behalf of certain Defendants and has since participated in briefing before the Court.

Because different defendants were represented by separate law firms, the case proceeded through multiple motions, responses, replies, and procedural filings. Although the defendants were represented by different counsel, many of the legal arguments presented to the Court addressed overlapping issues concerning jurisdiction, standing, corporate structure, arbitration, and the sufficiency of the Complaint.

The appearance of multiple national law firms marked the beginning of coordinated motion practice that would shape the early stages of the litigation.

Defendants’ Motions to Dismiss

Rather than answering the allegations through discovery, Defendants responded by asking the Court to dismiss the case at the pleading stage. Although filed separately by different law firms representing different groups of Defendants, the motions share a common theme: they argue that this case should not proceed beyond the Complaint.

Throughout their motions, Defendants repeatedly characterize the dispute as nothing more than a small wage dispute involving Plaintiff’s employment with DRVM LLC. According to Defendants, the broader allegations concerning corporate structure, employer identity, fraud, concealment, alter ego liability, and successor liability either fail to state legally cognizable claims or should not be considered by the Court. Defendants also argue that any injury Plaintiff alleges ultimately stems from his employment and therefore belongs exclusively in arbitration rather than federal court.

The motions challenge nearly every aspect of the Complaint, including standing, jurisdiction, the sufficiency of the fraud allegations, and the legal theories asserted against the various Defendants. If granted in full, the motions would end the federal case before discovery, preventing the parties from obtaining additional documents or testimony regarding the allegations set forth in the Complaint.

Fisher Phillips LLP

On February 6, 2026, Fisher Phillips LLP, representing AMJ Services LLC and Steven S. Dickert, in his capacity as Trustee of Basil Management Trust, filed a Motion to Dismiss. In the alternative, the motion requests that the Complaint be stricken or that the dispute be compelled to arbitration.

Among other arguments, Fisher Phillips contends that Plaintiff lacks standing, that the Complaint does not satisfy the pleading standards for fraud, and that AMJ Services LLC and the Trust cannot be held liable under the legal theories asserted. At the same time, the motion argues that if the Court does not dismiss the claims, AMJ Services LLC and the Trust should nevertheless be permitted to enforce the arbitration agreement and require Plaintiff to arbitrate those claims.

The motion is supported by sworn declarations submitted by Steven S. Dickert and defense counsel, placing Defendants’ description of the corporate structure and employment relationship into the federal court record.

Filed Documents

• Motion to Dismiss, or in the Alternative Motion to Strike or Compel Arbitration

    Filed February 6, 2026

• Declaration of Steven S. Dickert

    Filed February 6, 2026

• Declaration of Bobbi J. Edwards

    Filed February 6, 2026

Faegre Drinker Biddle & Reath LLP

On February 18, 2026, Faegre Drinker Biddle & Reath LLP, representing Sanofi-Aventis U.S. LLC, Chattem Inc., and Quten Research Institute LLC, filed a separate Motion to Dismiss.

Faegre Drinker argues that the pharmaceutical defendants have insufficient connections to Oregon and that the Complaint fails to plausibly allege their involvement in the conduct described. The motion also argues that the Complaint attempts to expand what Defendants characterize as an employment dispute into claims against upstream corporate entities without a sufficient legal or factual basis.

Together, the motions present Defendants’ position that the case should be dismissed before discovery and that the litigation should remain limited to the employment relationship with DRVM LLC rather than proceed as a broader challenge to the alleged corporate structure described in the Complaint.

Filed Documents

• Motion to Dismiss

    Filed February 18, 2026

• Declaration of Belia Santos

    President, Quten Research Institute LLC

• Declaration of Colleen Proctor

    North America CFO, Sanofi-Aventis U.S. LLC

• Declaration of Leonardo Ilha

    Executive, Chattem Inc.

Notice of Fraud on the Court and Defendants’ Response

During briefing on Fisher Phillips LLP’s Motion to Dismiss and Motion to Compel Arbitration, a separate dispute arose concerning documents and representations submitted to the Court in support of those motions.

On February 10, 2026, Plaintiff filed a Notice of Fraud on the Court, asking the Court to consider two principal issues. First, the Notice asserted that a different version of the arbitration agreement had been submitted in support of Defendants’ motion than the version previously relied upon during the JAMS arbitration and the earlier federal arbitration proceedings. Second, the Notice argued that statements contained in a sworn declaration materially mischaracterized the scope and effect of the Court’s prior arbitration order, particularly as it related to the distinction between the arbitration proceedings and the broader allegations presented in this federal action. Plaintiff requested that the Court take judicial notice of those issues and preserve them for the record while briefing on the motions to dismiss remained pending.

The Notice was accompanied by multiple exhibits, including the arbitration agreement previously used during the arbitration proceedings, the version submitted in support of Defendants’ Motion to Dismiss, and a comparative exhibit prepared to illustrate the differences identified by Plaintiff. Plaintiff also requested that the Court consider whether the issues raised affected the integrity of the record supporting Defendants’ Motion to Dismiss and Motion to Compel Arbitration.

Fisher Phillips’ Response

On February 24, 2026, Fisher Phillips LLP filed a response disputing every allegation raised in the Notice. The response argues that both arbitration agreements were authentic onboarding documents generated during Plaintiff’s hiring process and that no fraud, forgery, or misconduct occurred. According to Defendants, Plaintiff initially completed onboarding documents using the name “Jorden Timothy” before later executing a second set of onboarding documents reflecting his legal surname, “Jorden Hollingsworth,” after the company reviewed his identification. Fisher Phillips argues that the second agreement—not the first—is the operative arbitration agreement and relies on electronic audit trail records to support that position.

The response also goes beyond the arbitration agreements themselves. Fisher Phillips argues that Plaintiff knowingly used the name “Jorden Timothy” during the initial onboarding process in an effort to conceal his identity and prevent an accurate background review. Plaintiff disputes those assertions. As reflected in the parties’ filings, the disagreement extends beyond the existence of two arbitration agreements to include the significance of the name difference, which agreement governed the parties’ relationship, and whether the later-submitted agreement and related representations accurately reflected the procedural history of the case.

Beyond addressing the arbitration agreements and prior court order, the response expands to Plaintiff’s public discussion of the litigation. Fisher Phillips argues that Plaintiff’s website, social media posts, and TikTok videos contain false and defamatory accusations concerning Defendants and their counsel and characterizes those publications as part of a pattern of harassment. Based on those assertions, Defendants ask the Court to order Plaintiff to remove website and social media content relating to those allegations and to publish a public correction and apology through the same platforms. The response also requests that the Court consider other corrective relief concerning Plaintiff’s filings and public statements.

Why This Filing Matters

Unlike the parties’ motions to dismiss, which ask the Court to determine whether the Complaint states legally sufficient claims, the Notice of Fraud on the Court presents a separate procedural dispute concerning the documents and representations submitted during the motion practice itself. The competing filings place before the Court differing accounts regarding the arbitration agreements, the significance of the prior arbitration order, the onboarding records, and Defendants’ request for relief directed at Plaintiff’s public discussion of the litigation.

Filed Documents

• Plaintiff’s Notice of Fraud on the Court: Submission of Forged Exhibit and Materially False Sworn Testimony

    Filed February 10, 2026

• Exhibit 1 – Original Arbitration Agreement

• Exhibit 2 – Arbitration Agreement Submitted with Defendants’ Motion

• Exhibit 3 – Comparative of the Arbitration Agreements

• Defendants AMJ Services LLC and Steven S. Dickert’s Response to Plaintiff’s Notice of Fraud on the Court

    Filed February 24, 2026

Plaintiff’s Consolidated Opposition

On March 4, 2026, Plaintiff filed a consolidated opposition responding to both Defendants’ motions to dismiss. Rather than filing separate responses, the opposition addressed the overlapping legal arguments advanced by the various Defendants and explained why Plaintiff contends the case should proceed beyond the pleading stage.

At the heart of the opposition is a disagreement over what this case is actually about. Throughout their motions, Defendants repeatedly characterize the litigation as a small wage dispute involving DRVM LLC. Plaintiff argues that this framing overlooks the central issue raised in the Complaint: whether the entity identified as the employer was merely the workforce-facing company while payroll authority, operational control, and enterprise responsibility resided elsewhere.

According to the opposition, employer identity is not simply a technical issue. Plaintiff argues that identifying the legally responsible employer affects wage liability, arbitration, tax reporting, whistleblower protections, access to records, and the ability of any tribunal to provide complete relief. The opposition contends that if the entity confined to arbitration lacks independent authority over payroll and management, meaningful accountability may be impaired.

The opposition further argues that this federal action is distinct from the related arbitration and Department of Labor whistleblower proceeding. According to Plaintiff, each forum addresses different legal questions under different bodies of law. The arbitration concerns claims arising under an employment arbitration agreement, the Department of Labor proceeding concerns federal whistleblower protections, while this federal action challenges the alleged corporate structure, employer identity, and the relationships among the entities identified in the Complaint.

The filing also responds to Defendants’ challenges regarding standing, personal jurisdiction, fraud, alter ego liability, civil conspiracy, successor liability, and the sufficiency of the pleadings. Plaintiff argues that the Complaint, together with the public records and documentary evidence submitted to the Court, plausibly alleges an integrated enterprise operating through multiple affiliated entities and therefore satisfies the pleading standards required for the litigation to proceed into discovery.

In support of the opposition, Plaintiff submitted a declaration attaching 34 exhibits, including Secretary of State filings, public corporate records, payroll documentation, arbitration materials, correspondence, public executive information, business registrations, witness declarations, and other documentary evidence referenced throughout the briefing. Together, those exhibits were offered to provide factual support for the allegations contained in the Complaint and to respond directly to the factual assertions made in Defendants’ motions and supporting declarations.

Why This Filing Matters

This filing serves as Plaintiff’s principal response to the Defendants’ motions to dismiss and presents the legal framework supporting the Complaint. Rather than responding only to individual arguments, the opposition explains Plaintiff’s broader theory that the case concerns employer identity, enterprise structure, and accountability—not simply an individual wage dispute. Plaintiff asks the Court to deny the motions and allow the case to proceed into discovery, where the parties can obtain documents, testimony, and additional evidence concerning the disputed issues raised throughout the Complaint. The filing also brings together the factual and legal issues spanning the federal case, the arbitration proceedings, and the related whistleblower matters while explaining why Plaintiff contends each serves a separate legal purpose.

Filed Documents

• Plaintiff’s Consolidated Opposition to Defendants’ Motions to Dismiss, Motion to Strike, and Motion to Compel Arbitration

    Filed March 4, 2026

• Declaration of Jorden Hollingsworth in Support of Plaintiff’s Opposition

    Filed March 4, 2026

Defendants’ Replies

By the conclusion of motion briefing, the various Defendants were represented by Fisher Phillips LLP, Jackson Lewis P.C., and Faegre Drinker Biddle & Reath LLP. Each firm filed reply briefs asking the Court to dismiss the Complaint before discovery and responding to Plaintiff’s consolidated opposition.

Although the replies address different legal issues depending on the clients represented, they advance a common theme: that the litigation should be viewed exclusively as a dispute involving DRVM LLC and that the broader allegations concerning employer identity, enterprise structure, and affiliated entities do not provide a legal basis for the claims asserted in the Complaint.

Faegre Drinker Biddle & Reath LLP / Jackson Lewis P.C.

On March 18, 2026, Faegre Drinker Biddle & Reath LLP, together with local counsel Jackson Lewis P.C., filed a reply on behalf of Sanofi-Aventis U.S. LLC, Chattem Inc., and Quten Research Institute LLC.

The reply maintains that the Court lacks personal jurisdiction over the pharmaceutical defendants and argues that Plaintiff failed to allege sufficient facts connecting those entities to the conduct described in the Complaint. Defendants contend that the Complaint identifies no actionable misconduct by the pharmaceutical companies themselves and instead attempts to extend liability based upon allegations concerning unrelated entities and corporate acquisitions.

The reply further argues that Plaintiff failed to plausibly plead fraud, fraudulent concealment, civil conspiracy, alter ego liability, successor liability, or any basis for jurisdictional discovery. According to Defendants, the Complaint should be dismissed before discovery because it does not allege facts establishing either jurisdiction or viable claims against the pharmaceutical defendants.

Fisher Phillips LLP

On March 30, 2026, Fisher Phillips LLP filed its reply on behalf of AMJ Services LLC and Steven S. Dickert, in his capacity as Trustee of Basil Management Trust.

The reply reiterates Defendants’ position that Plaintiff lacks Article III standing, has not alleged a legally cognizable injury, and fails to state claims for fraud, fraudulent concealment, alter ego liability, successor liability, or civil conspiracy. Fisher Phillips argues that DRVM LLC was Plaintiff’s employer, that any alleged injuries arise from that employment relationship, and that the dispute should remain confined to the arbitration already pending against DRVM.

Throughout the reply, Fisher Phillips characterizes the litigation as an attempt to transform a wage dispute into a broader challenge involving multiple affiliated entities and maintains that the Complaint should be dismissed before discovery. The reply also responds extensively to Plaintiff’s arguments regarding employer identity, corporate structure, arbitration, standing, and the legal significance of DRVM’s business registration.

Plaintiff’s Notice of Related Proceeding

Later that same day, Plaintiff filed a Notice of Related Proceeding informing the Court of developments in the parallel Department of Labor whistleblower case.

According to the Notice, the filing was intended to ensure that the Court had an accurate understanding of the procedural posture of the whistleblower proceeding while the motions to dismiss remained under consideration. Plaintiff asserted that the matter had advanced under the Sarbanes-Oxley Act and the Taxpayer First Act, and that the status of the proceeding differed from the characterization presented in Defendants’ briefing.

Why These Filings Matter

These reply briefs completed the motion-to-dismiss briefing and represented the parties’ final substantive arguments before the Court issued its Findings and Recommendation.

By this stage, the parties had presented fundamentally different views of the litigation. Defendants argued that the Complaint should be dismissed before discovery as a legally deficient dispute arising from Plaintiff’s employment with DRVM LLC. Plaintiff, in contrast, maintained that the case presents broader questions concerning employer identity, enterprise structure, and corporate accountability that require factual development through discovery rather than dismissal at the pleading stage.

With briefing complete, the motions were submitted to the Court for decision.

Filed Documents

• Reply Memorandum in Support of Defendants Sanofi-Aventis U.S. LLC, Chattem Inc., and Quten Research Institute LLC’s Motion to Dismiss

    Filed March 18, 2026

• Reply to Plaintiff’s Opposition to Defendants’ Motion to Dismiss, Motion to Strike, or Motion to Compel Arbitration (AMJ Services LLC and Steven S. Dickert)

    Filed March 30, 2026

• Plaintiff’s Notice of Related Proceeding

    Filed March 30, 2026

Findings and Recommendation

After considering the Complaint, the parties’ motions, Plaintiff’s consolidated opposition, the reply briefs, and the accompanying declarations and exhibits, the assigned United States Magistrate Judge issued Findings and Recommendation on June 11, 2026, addressing the pending motions to dismiss.

A Findings and Recommendation is not a final judgment. In the District of Oregon, a magistrate judge may recommend how a case should be resolved, but the final decision rests with the assigned United States District Judge. Either party may file written objections, requiring the District Judge to conduct an independent (de novo) review of the challenged portions of the recommendation before issuing a final ruling.

The Findings and Recommendation recommends that the Complaint be dismissed for lack of Article III standing. According to the recommendation, Plaintiff failed to plausibly allege that the named Defendants caused a concrete injury independent of the employment relationship with DRVM LLC. The recommendation concludes that the Complaint does not establish a sufficient basis to proceed against the upstream Defendants and recommends dismissal of the action with prejudice.

A significant portion of the recommendation relies on the Court’s earlier decision in Plaintiff’s petition to compel arbitration. The recommendation explains that the earlier proceeding rejected Plaintiff’s attempt to include the upstream entities in the arbitration because it concluded that the alleged corporate structure was not sufficiently connected to Plaintiff’s claimed injury. Relying on that prior ruling, the recommendation concludes that Plaintiff likewise failed to plausibly allege that the upstream Defendants caused the injuries asserted in this federal action. As a result, the recommendation concludes that Plaintiff lacks standing to pursue claims against those Defendants.

The Findings and Recommendation also addresses Plaintiff’s previously filed Notice of Fraud on the Court. The recommendation states that the Notice contains “serious and demonstrably false allegations” against Defendants and their counsel and orders that the Notice be stricken from the record. The recommendation references Defendants’ request that Plaintiff be required to remove website and social media content and publish a public correction and apology. Although the recommendation declines to order removal of the website or social media posts, it warns Plaintiff that knowingly publishing false statements may subject him to civil liability.

Finally, the recommendation concludes that this federal action represents Plaintiff’s second attempt to hold the upstream Defendants responsible for the underlying wage dispute involving DRVM LLC. Based on that conclusion, the Magistrate Judge recommends dismissing the Complaint with prejudice, stating that further amendment would be futile and characterizing the claims against the Defendants as frivolous.

Why This Filing Matters

The Findings and Recommendation represents the first judicial evaluation of the Complaint and recommends dismissal of the case in its entirety. However, it is not the final decision of the Court. Instead, it begins the objections process, during which the assigned District Judge must independently review the challenged portions of the recommendation before determining whether to adopt, reject, or modify the Magistrate Judge’s conclusions. Plaintiff timely filed objections challenging multiple aspects of the recommendation, including its standing analysis, its reliance on the earlier petition to compel arbitration, its treatment of the Notice of Fraud on the Court, and its recommendation that the action be dismissed with prejudice.

Filed Document

• Findings and Recommendation

    Issued June 11, 2026

Plaintiff’s Objections to the Findings and Recommendation

On June 25, 2026, Plaintiff timely filed 45 pages of objections to the Magistrate Judge’s Findings and Recommendation, requesting that the assigned United States District Judge reject the recommendation following the required de novo review.

The objections argue that the Findings and Recommendation rests upon a fundamental misunderstanding of the Complaint. According to Plaintiff, the recommendation repeatedly characterizes the case as a routine wage dispute involving DRVM LLC, even though the Complaint alleges independent injuries arising from employer identity, false employment and tax records, corporate concealment, whistleblower rights, post-employment conduct, and the broader enterprise structure. Plaintiff argues that the wage claims remain pending in arbitration and that this federal action concerns separate legal issues that were never presented or decided in the earlier petition to compel arbitration.

A central focus of the objections is the recommendation’s reliance on the earlier federal petition to compel arbitration. Plaintiff argues that the prior proceeding was a limited application under the Federal Arbitration Act to resolve an arbitrator-selection dispute and determine whether non-signatories could be compelled into arbitration. According to the objections, that proceeding did not adjudicate fraud, employer identity, false employment or tax records, whistleblower interference, alter ego liability, successor liability, or the other claims asserted in this action. Plaintiff contends that the Findings and Recommendation improperly imports conclusions from that limited proceeding to effectively shield the same upstream defendants from liability in this separate federal case.

The objections further argue that the recommendation departs from the standards governing a motion to dismiss by resolving disputed factual issues, adopting Defendants’ version of contested events, and making credibility determinations before discovery has occurred. Plaintiff contends that the Court accepted Defendants’ factual narrative regarding employer identity, corporate structure, and the arbitration documents rather than accepting the well-pleaded allegations of the Complaint as true, as required at the pleading stage.

The objections also challenge the recommendation’s treatment of Plaintiff’s Notice of Fraud on the Court. Plaintiff argues that the recommendation improperly resolved disputed factual issues concerning the existence of multiple arbitration agreements, the significance of the differences between documents bearing Plaintiff’s middle name and those bearing his last name, and Defendants’ assertion that Plaintiff intentionally attempted to deceive the Court regarding those documents. According to the objections, those issues remain disputed and should not have been resolved without discovery or an evidentiary record.

The objections further challenge the recommendation’s decision to strike the Notice of Fraud on the Court after characterizing its allegations as “serious and demonstrably false,” as well as the recommendation’s conclusion that the Complaint is frivolous and should be dismissed with prejudice. Plaintiff argues that those findings improperly resolve factual disputes and credibility questions before discovery and without a trial or evidentiary hearing.

Finally, Plaintiff argues that dismissal with prejudice is inconsistent with Ninth Circuit authority because the Findings and Recommendation contains no meaningful analysis explaining why amendment would be futile. According to the objections, even if the District Court were to identify pleading deficiencies, the appropriate remedy would be leave to amend rather than terminating the action before discovery.

Why These Objections Matter

Unlike the earlier briefing before the Magistrate Judge, these objections are directed to the assigned United States District Judge, who must independently review each challenged portion of the Findings and Recommendation before issuing a final decision.

The objections identify seven principal legal errors, including the alleged mischaracterization of Plaintiff’s injuries, reliance on the earlier petition to compel arbitration beyond the issues actually decided there, application of an incorrect Rule 12 standard, erroneous standing analysis, improper resolution of disputed factual issues and credibility determinations, dismissal with prejudice without a finding of futility, and extending the effect of the earlier arbitration proceeding to defendants who Plaintiff contends were neither parties to nor adjudicated in that proceeding.

Filed Document

• Plaintiff’s Objections to the Findings and Recommendation

    Filed June 25, 2026

Defendants’ Responses to Plaintiff’s Objections

Following Plaintiff’s objections to the Findings and Recommendation, both groups of Defendants filed responses urging the District Judge to adopt the Magistrate Judge’s recommendation in full.

Fisher Phillips LLP

On July 8, 2026, Fisher Phillips LLP, representing AMJ Services LLC and Steven S. Dickert, filed a response arguing that Plaintiff’s objections identify no error requiring de novo review. According to Defendants, the objections merely repeat arguments previously raised during the motion-to-dismiss briefing and continue an effort to transform what they characterize as a wage-penalty dispute with DRVM LLC into broader claims for fraud, concealment, conspiracy, alter ego liability, and successor liability against non-employer defendants.

The response maintains that the Findings and Recommendation correctly relied upon the earlier federal arbitration proceeding, Hollingsworth I, and argues that Plaintiff still fails to identify a concrete injury fairly traceable to Defendants. Fisher Phillips also contends that the objections do not meaningfully address several independent grounds raised in the original Motion to Dismiss, including Rule 9(b), civil conspiracy, alter ego liability, successor liability, and Defendants’ alternative request to compel arbitration. Based on those arguments, Defendants ask the District Judge to adopt the Findings and Recommendation and dismiss the Complaint with prejudice.

Faegre Drinker Biddle & Reath LLP / Jackson Lewis P.C.

On July 9, 2026, Faegre Drinker Biddle & Reath LLP and Jackson Lewis P.C., representing Sanofi-Aventis U.S. LLC, Chattem Inc., and Quten Research Institute LLC, filed a separate response supporting adoption of the Findings and Recommendation.

Like Fisher Phillips, these Defendants argue that Plaintiff’s alleged injuries ultimately arise from his employment with DRVM LLC and do not establish Article III standing against the pharmaceutical defendants. They further contend that Plaintiff’s investigation into the corporate structure, expenditures of time and resources, and participation in other proceedings do not constitute legally cognizable injuries sufficient to maintain this federal action. Defendants also argue that dismissal with prejudice remains appropriate because Plaintiff has not identified any amendment that would cure the alleged defects in the Complaint.

The Parties’ Continuing Disagreement

The responses also highlight a continuing disagreement over the scope of Plaintiff’s objections.

According to Defendants, the objections largely repeat arguments previously presented during the motion-to-dismiss briefing and continue an effort to expand a wage dispute involving DRVM LLC into broader claims against additional entities. Plaintiff disputes that characterization. According to Plaintiff, the objections primarily challenge the legal analysis contained in the Findings and Recommendation itself, including its reliance on the earlier petition to compel arbitration, its characterization of the Complaint and the alleged injuries, its application of the Rule 12 pleading standard, and its recommendation that the action be dismissed with prejudice. Plaintiff further contends that portions of Defendants’ responses devote substantial attention to rearguing the original motions to dismiss rather than addressing the specific legal errors identified in the objections.

Why These Filings Matter

These responses represent the final substantive briefing before the District Judge rules on whether to adopt, reject, or modify the Findings and Recommendation. The briefing now squarely presents two competing positions. Defendants argue that the Magistrate Judge correctly analyzed the Complaint and that the objections merely restate arguments already rejected. Plaintiff maintains that the Findings and Recommendation materially mischaracterizes both the Complaint and the earlier arbitration proceeding, and that those errors should be corrected before any final judgment is entered.

Filed Documents

• Defendants AMJ Services LLC and Steven S. Dickert’s Response to Plaintiff’s Objections to the Findings and Recommendation

    Filed July 8, 2026

• Defendants Sanofi-Aventis U.S. LLC, Chattem Inc., and Quten Research Institute LLC’s Response to Plaintiff’s Objections to the Findings and Recommendation

    Filed July 9, 2026

Current Status

The parties have completed briefing on the Findings and Recommendation. The matter is now before the assigned United States District Judge, who will conduct a de novo review of the portions of the recommendation challenged in Plaintiff’s objections before issuing a final decision.

This page will continue to be updated as new filings, orders, and developments occur. Wherever possible, the updates include the underlying court documents so readers can review the public record for themselves and follow the litigation as it progresses.

Regardless of the District Judge’s ultimate decision, the filings submitted throughout this case form the official federal court record. If further review becomes necessary, that record will provide the foundation for any subsequent proceedings before the United States Court of Appeals.