The opinion
Le
LEVIN-EPSTEIN & ASSOCIATES, P.C.
60 East 424 Street * Suite 4700 * New York, New York 10165
T: 212.792-0048 * E: Jason@levinepstein.com
December 29, 2023
Via ECF
The Honorable Jessica G. L. Clarke, U.S.D.J
US. 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 on consent of 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 January 5, 2024 to,
through and including, January 12, 2024.
This is the fourth request of its nature. If granted, this request would not affect any other
Court scheduled deadlines.
This letter further serves to request an adjournment of the virtual status conference
scheduled for January 4, 2024, to, through and including a date and time set by the Court after
January 10, 2024.
This is the first request of its nature. If granted, this request would not affect any other
Court scheduled deadlines.
The basis of this request is that the undersigned counsel is in the process of scheduling
conferences with Plaintiffs. The undersigned counsel anticipates being in a position to finalize
these conferences within approximately one (1) week.
In light of the foregoing, it is respectfully requested that the Court: (1) 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 January 5, 2024 to, through and including, January 12,
2024; and (ii) adjourn the virtual status conference scheduled for January 4, 2024, to, through
and including a date and time set by the Court after January 10, 2024.
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 conference scheduled for January 4, 2024 at 2:00 p.m. is hereby rescheduled tc
January 11, 2024 at 2:00 p.m. The settlement agreement remains due January 15, 2024. See ECF No. 58.
ORDERED. |
\e aHCa (KAA
JESSICA G. L. CLARKE
United States District Judge
Dated: January 2, 2024
New York, New York