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