Opinion

Brown v. CE Solutions Group, LLC

Court
District Court, S.D. New York
Filed
Dec 12, 2023
Cited by
0 cases
Authority
More cited than 27.7%

The opinion

LEVIN-EPSTEIN & ASSOCIATES, P.C.

60 East 42" Street * Suite 4700 * New York, New York 10165

T: 212.792-0048 * E: Jason@levinepstein.com

December 11, 2023

Via ECF

The Honorable Jessica G. L. Clarke, U.S.D.J MEMO ENDORSED

USS. District Court, Southern District of New York

500 Pearl Street

New York, NY 10007

Re: Brown et al vy. CE Solutions Group, LLC et al

Case No.: 23-cv-03029

Dear Honorable Judge Clarke,

This law firm represents Plaintiffs Darnell Brown, Jeremiah Jones, Ronald Turner, Terri

Coleman, Phillip Barnes, Charles Shokanji, Joseph Miranda, Andres Reyes, Smithfuerte Reyes,

Jadrien Smith, Melissa Thompson and Ticky Rowe (collectively, the “Plaintiffs”) in the above-

referenced matter. This letter is submitted jointly with counsel for Defendants CE Solutions Group,

LLC, CE Solutions Inc. and Jeannine Napoleone-Colbert (collectively, the “Defendants’’).

Pursuant to Your Honor’s Individual Motion Practice Rules, this letter respectfully serves

as a request to extend the parties’ deadline to submit a settlement agreement pursuant to Cheeks

v. Freeport Pancake House, Inc., 796 F.3d 199, 200 (2d Cir. 2015), from December 13, 2023

to, through and including, January 15, 2023.

This is the third request of its nature. If granted, this request would not affect any other

Court scheduled deadlines.

The basis of this request is that the parties are still working on finalizing the necessary

paperwork to effectuate the disposition of this matter. A second, independent basis also

necessitates the instant request. The undersigned law firm is in the process of re-confirming

each individual Plaintiffs commitment to the settlement-in-principle that was previously

reached in this action. As of the date of this filing, the undersigned law firm has re-confirmed

the commitment of six (6) of the Plaintiffs, both orally and in writing.

Of the remaining six (6) Plaintiffs’, the undersigned law firm is in the process of

withdrawing as counsel for Plaintiff Terri Coleman. [See Dckt. Nos. 53-55]. The undersigned

law firm is still in the process of re-confirming the commitment of the remaining five (5)

Plaintiffs.

' To wit, Plaintiffs: (i) Andres Reyes; (ii) Jadrien Smith; (iii) Melissa Thompson; (iv) Phillip Barnes; (v) Ronald

Turner; and (vi) Smithfuerte Reyes.

2 To wit, Plaintiffs: (i) Darnell Brown; (ii) Jeremiah Jones; (iii) Joseph Miranda; (iv) Shokanji Charles; (v) Terri

Coleman; and (vi) Ticky Rowe.

The parties anticipate being in a position to finalize the necessary paperwork to effectuate

the dismissal of the instant action, on or before January 15, 2023.

Thank you, in advance, for your time and attention to this matter.

Respectfully submitted,

LEVIN-EPSTEIN & ASSOCIATES, P.C.

By: /s/ Jason Mizrahi

Jason Mizrahi

60 East 42™ Street, Suite 4700

New York, New York 10165

Tel. No.: (212) 792-0048

Email: Jason@levinepstein.com

Attorneys for Plaintiffs

VIA ECF: All Counsel

Application GRANTED. The deadline is extended to January 15, 2024. Further extensions are unlikely 1

be granted. The Clerk of Court is directed to terminate ECF No. 57.

SO ORDERED.

oN

\e ACA (KAA

JESSICA G. L. CLARKE

United States District Judge

Dated: December 12, 2023

New York, New York

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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