Preview
FILED: NEW YORK COUNTY CLERK 12/22/2023 04:51 PM INDEX NO. 153644/2023
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 12/22/2023
EXHIBIT Q
FILED: NEW YORK COUNTY CLERK 12/22/2023 04:51 PM INDEX NO. 153644/2023
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 12/22/2023
From: Adam Sherman adam@jacobspc.com
Subject: Re: Bago, et al. v. La Brochette, Inc., et al., Index No.: 153644/2023 [IWOV-iManage.FID519535]
Date: October 6, 2023 at 3:36 PM
To: Matthew Dorfman mdorfman@vladeck.com
Cc: Jeremiah Iadevaia jiadevaia@Vladeck.com, Stefany Arteaga Stefany@jacobspc.com, Eduard Kushmakov eduard@jacobspc.com
Thank you for your email.
We will be supplementing our production by the end of next week (10/13/23).
On Fri, Sep 29, 2023 at 1:52 PM Matthew Dorfman wrote:
Hello Adam,
Thanks for the call yesterday.
Interrogatory
As discussed, we agree to modify Interrogatory No. 5 as follows for purposes of pre-class certification discovery:
For the period April 20, 2017 to the present, identify any job titles for which the workers, whether employees or
independent contractors, were paid a tipped minimum wage, participated in the tip pool, or otherwise received tips in the
course of Defendants’ business.
As a definition, a “tipped worker” is anybody who performed work in the above job classifications.
For each such individual who performed work as a tipped worker, please specify a pseudonym, job title, and their dates of
employment.
Documents
For documents previously produced, please supplement Defendants’ document production as follows:
Insert pseudonyms in each place where the name of a current or former worker has been redacted;
The pseudonyms should be consistent across all documents/interrogatories such that each unique worker has a
unique pseudonym and that same pseudonym is used wherever that worker’s name appears across all
documents and interrogatories;
Without waiver or limitation to raise additional concerns after class certification is decided, the following documents are missing from
defendants’ production. To the extent that these documents do not exist, please so specify. The relevant time period for all of these
requests, unless otherwise specified, is the time period between April 20, 2017 and the present.
Alexandru Gerea’s employment contract, along with any other documents which identify Gerea’s job duties or notify Gerea
that he was earning below the non-tipped minimum wage;
Any time cards, not already produced, reflecting time worked by any tipped workers;
Any documents, not already produced, reflecting how much each tipped worker received in tips;
Any documents reflecting any formulas used to calculate tip allocations, along with any documents showing that
defendants provided their tipped workers with notice of such formulas;
To the extent that a different formula was used for tips received at catered events, please produce those
documents as well;
Any pay stubs, not already produced, for Bago, Gerea, and any other tipped worker;
Any documents, not already produced, that were used to notify any tipped worker that they were earning below the non-
tipped minimum wage;
Any documents, not already produced, indicating whether each individual tipped worker was designated as an employee
or an independent contractor;
If the status of any individual changed between employee and independent contractor, include any documents
indicating when and why that change occurred; and
Any documents which were provided to customers at catered events held during the relevant time period which informed
the customers that they were going to be charged an administrative fee or that the administrative fee was not a gratuity.
We are working on drafting a motion to extend the deadline for submitting a motion for class certification. Please let us know when
FILED: NEW YORK COUNTY CLERK 12/22/2023 04:51 PM INDEX NO. 153644/2023
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 12/22/2023
We are working on drafting a motion to extend the deadline for submitting a motion for class certification. Please let us know when
you have had a chance to discuss this matter with your client.
Matthew Dorfman
Vladeck, Raskin & Clark, P.C.
Please note our new address:
111 Broadway, Suite 1505
New York, NY 10006
(646)771-9013
mdorfman@vladeck.com
From: Adam Sherman
Sent: Wednesday, September 27, 2023 8:15 PM
To: Jeremiah Iadevaia
Cc: Matthew Dorfman ; Stefany Arteaga ; Eduard Kushmakov
Subject: Re: Bago, et al. v. La Brochette, Inc., et al., Index No.: 153644/2023 [IWOV-iManage.FID519535]
212-229-8503
Sent from my iPhone
On Sep 27, 2023, at 8:13 PM, Jeremiah Iadevaia wrote:
Talk then. What number should we call?
From: Adam Sherman
Sent: Wednesday, September 27, 2023 8:12 PM
To: Jeremiah Iadevaia
Cc: Matthew Dorfman ; Stefany Arteaga ; Eduard
Kushmakov
Subject: Re: Bago, et al. v. La Brochette, Inc., et al., Index No.: 153644/2023 [IWOV-iManage.FID519535]
2:30 p.m. works
Sent from my iPhone
On Sep 27, 2023, at 6:13 PM, Jeremiah Iadevaia wrote:
How is 12:30, 1:30, or 2:30?
FILED: NEW YORK COUNTY CLERK 12/22/2023 04:51 PM INDEX NO. 153644/2023
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 12/22/2023
From: Adam Sherman
Sent: Wednesday, September 27, 2023 5:45 PM
To: Matthew Dorfman
Cc: Stefany Arteaga ; Eduard Kushmakov ;
Jeremiah Iadevaia
Subject: Re: Bago, et al. v. La Brochette, Inc., et al., Index No.: 153644/2023 [IWOV-
iManage.FID519535]
Please provide times for a call tomorrow.
That seems reasonable.
Thank you.
On Wed, Sep 27, 2023 at 5:43 PM Matthew Dorfman wrote:
Hi Adam,
We are fine having a meet and confer phone call, but unfortunately we don’t have enough
time to wait until next week given the current deadline for submitting briefing. If defendants
would consent to a further extension of the briefing scheduling, next week is fine. If not, we
ask to speak tomorrow.
1. In our email, we acknowledge that some of the information has been produced, but
not all of it. We tried to highlight where there are deficiencies.
2. Regarding the potential class, we are looking for information about the number of
servers and others who received tips during the applicable period. If defendants
are unwilling to give names at this point, we need defendants to provide under oath
the number of individuals who served in those roles, their titles, and dates of
employment.
3. For purposes of the documents, we won’t object for now (subject to class
certification) to redactions of names, but we need some system to decipher how
many people we are talking about. It could be by number or letter (i.e., Employee
A, Employee B, etc.).
Thanks.
From: Adam Sherman
Sent: Wednesday, September 27, 2023 5:00:00 PM
To: Matthew Dorfman
Cc: Stefany Arteaga ; Eduard Kushmakov
; Jeremiah Iadevaia
Subject: Re: Bago, et al. v. La Brochette, Inc., et al., Index No.: 153644/2023 [IWOV-
iManage.FID519535]
Dear Matthew:
I am frankly confused by your email. On one hand, you write that the Plaintiffs are not
seeking the names and contact information of potential class members. On the other hand,
you are seeking the production of documents that would reflect that same information. For
example, you claim entitlement to all putative class members pay records, but those records
would necessarily disclose the names of those class members. Therefore, I am confused.
Jeremiah:
FILED: NEW YORK COUNTY CLERK 12/22/2023 04:51 PM INDEX NO. 153644/2023
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 12/22/2023
Jeremiah:
This piecemeal approach is not efficient. I propose that we have a meet and confer on
these topics on Friday or Monday afternoon.
Moreover, some of the items in your bullet list have already been produced.
Please advise.
Thanks.
On Tue, Sep 19, 2023 at 2:18 PM Matthew Dorfman wrote:
Hi Adam,
We have started reviewing your discovery responses and we
have some concerns. Specifically, for purposes of class
certification, we need the names of all individuals who
would be members of the putative class. Pursuant to
interrogatory 5, please provide a list of all individuals who
have worked for La Brochette, Inc. since December 1, 2017,
in a role that would have entitled the individual to a share of
the tip pool or who were otherwise paid the tipped minimum
wage. This may include, inter alia, servers, bussers, and
hosts. In this list, please include their names, each of their
job titles, and the date range during which each of them were
employed by La Brochette, Inc.
Contrary to defendants’ objections, plaintiffs’ allegations are
far from conclusory, including providing detail as to why
other Servers at La Brouchette would be suitable class
members. For example, the Complaint alleges:
1. Defendants employed Plaintiffs, and others similarly
situated, as tipped employees (or “Servers”) (see
paragraph 3);
2. Defendants improperly classified Servers as
independent contractors (see paragraphs 4, 45);
3. Defendants failed to pay Servers “spread of hours” pay
(see paragraphs 6, 41);
4. Defendants failed to provide Servers with proper
notice of the tipped minimum wage (see paragraphs 7,
40);
5. Defendants failed to advise Servers of the tip pooling
policy in writing (see paragraph 46);
6. Defendants denied Servers the opportunity to earn tips
FILED: NEW YORK COUNTY CLERK 12/22/2023 04:51 PM INDEX NO. 153644/2023
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 12/22/2023
6. Defendants denied Servers the opportunity to earn tips
at private events despite paying them the tipped
minimum wage (see paragraph 9);
7. Defendants forced Servers to share their tips with non-
tipped workers (see paragraph 10);
8. Defendants failed to properly account for tips made by
patrons (see paragraphs 43, 47);
9. Defendants failed to keep records required of
employers (see paragraph 48);
10. Defendants improperly retained gratuities after failing
to notify customers that the charge was intended to be
an administrative charge (see paragraph 44).
Please let us know no later than Thursday if Defendants will
provide the requested information. Otherwise, we will raise
the issue with the Court. We are happy to discuss by phone.
We have other concerns, and we will be following up, but for
now, we wanted to address this issue as it is important for
purposes of class certification.
Sincerely,
Matthew Dorfman
Vladeck, Raskin & Clark, P.C.
Please note our new address:
111 Broadway, Suite 1505
New York, NY 10006
(646)771-9013
mdorfman@vladeck.com
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may be unlawful.
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FILED: NEW YORK COUNTY CLERK 12/22/2023 04:51 PM INDEX NO. 153644/2023
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 12/22/2023
Disclaimer
The information contained in this communication from the sender is
confidential. It is intended solely for use by the recipient and others
authorized to receive it. If you are not the recipient, you are hereby
notified that any disclosure, copying, distribution or taking action in
relation of the contents of this information is strictly prohibited and may
be unlawful.
This email has been scanned for viruses and malware, and may have
been automatically archived by Mimecast Ltd, an innovator in Software
as a Service (SaaS) for business. Providing a safer and more useful
place for your human generated data. Specializing in; Security, archiving
and compliance. To find out more Click Here.
Disclaimer
The information contained in this communication from the sender is
confidential. It is intended solely for use by the recipient and others
authorized to receive it. If you are not the recipient, you are hereby notified
that any disclosure, copying, distribution or taking action in relation of the
contents of this information is strictly prohibited and may be unlawful.
This email has been scanned for viruses and malware, and may have been
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Disclaimer
The information contained in this communication from the sender is confidential. It is
intended solely for use by the recipient and others authorized to receive it. If you are not
the recipient, you are hereby notified that any disclosure, copying, distribution or taking
action in relation of the contents of this information is strictly prohibited and may be
unlawful.
This email has been scanned for viruses and malware, and may have been automatically
archived by Mimecast Ltd, an innovator in Software as a Service (SaaS) for business.
Providing a safer and more useful place for your human generated data. Specializing in;
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Disclaimer
The information contained in this communication from the sender is confidential. It is intended solely for
use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby
notified that any disclosure, copying, distribution or taking action in relation of the contents of this
information is strictly prohibited and may be unlawful.
This email has been scanned for viruses and malware, and may have been automatically archived by
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Preview
FILED: NEW YORK COUNTY CLERK 12/22/2023 04:51 PM INDEX NO. 153644/2023 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 12/22/2023 EXHIBIT Q FILED: NEW YORK COUNTY CLERK 12/22/2023 04:51 PM INDEX NO. 153644/2023 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 12/22/2023 From: Adam Sherman adam@jacobspc.com Subject: Re: Bago, et al. v. La Brochette, Inc., et al., Index No.: 153644/2023 [IWOV-iManage.FID519535] Date: October 6, 2023 at 3:36 PM To: Matthew Dorfman mdorfman@vladeck.com Cc: Jeremiah Iadevaia jiadevaia@Vladeck.com, Stefany Arteaga Stefany@jacobspc.com, Eduard Kushmakov eduard@jacobspc.com Thank you for your email. We will be supplementing our production by the end of next week (10/13/23). On Fri, Sep 29, 2023 at 1:52 PM Matthew Dorfman wrote: Hello Adam, Thanks for the call yesterday. Interrogatory As discussed, we agree to modify Interrogatory No. 5 as follows for purposes of pre-class certification discovery: For the period April 20, 2017 to the present, identify any job titles for which the workers, whether employees or independent contractors, were paid a tipped minimum wage, participated in the tip pool, or otherwise received tips in the course of Defendants’ business. As a definition, a “tipped worker” is anybody who performed work in the above job classifications. For each such individual who performed work as a tipped worker, please specify a pseudonym, job title, and their dates of employment. Documents For documents previously produced, please supplement Defendants’ document production as follows: Insert pseudonyms in each place where the name of a current or former worker has been redacted; The pseudonyms should be consistent across all documents/interrogatories such that each unique worker has a unique pseudonym and that same pseudonym is used wherever that worker’s name appears across all documents and interrogatories; Without waiver or limitation to raise additional concerns after class certification is decided, the following documents are missing from defendants’ production. To the extent that these documents do not exist, please so specify. The relevant time period for all of these requests, unless otherwise specified, is the time period between April 20, 2017 and the present. Alexandru Gerea’s employment contract, along with any other documents which identify Gerea’s job duties or notify Gerea that he was earning below the non-tipped minimum wage; Any time cards, not already produced, reflecting time worked by any tipped workers; Any documents, not already produced, reflecting how much each tipped worker received in tips; Any documents reflecting any formulas used to calculate tip allocations, along with any documents showing that defendants provided their tipped workers with notice of such formulas; To the extent that a different formula was used for tips received at catered events, please produce those documents as well; Any pay stubs, not already produced, for Bago, Gerea, and any other tipped worker; Any documents, not already produced, that were used to notify any tipped worker that they were earning below the non- tipped minimum wage; Any documents, not already produced, indicating whether each individual tipped worker was designated as an employee or an independent contractor; If the status of any individual changed between employee and independent contractor, include any documents indicating when and why that change occurred; and Any documents which were provided to customers at catered events held during the relevant time period which informed the customers that they were going to be charged an administrative fee or that the administrative fee was not a gratuity. We are working on drafting a motion to extend the deadline for submitting a motion for class certification. Please let us know when FILED: NEW YORK COUNTY CLERK 12/22/2023 04:51 PM INDEX NO. 153644/2023 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 12/22/2023 We are working on drafting a motion to extend the deadline for submitting a motion for class certification. Please let us know when you have had a chance to discuss this matter with your client. Matthew Dorfman Vladeck, Raskin & Clark, P.C. Please note our new address: 111 Broadway, Suite 1505 New York, NY 10006 (646)771-9013 mdorfman@vladeck.com From: Adam Sherman Sent: Wednesday, September 27, 2023 8:15 PM To: Jeremiah Iadevaia Cc: Matthew Dorfman ; Stefany Arteaga ; Eduard Kushmakov Subject: Re: Bago, et al. v. La Brochette, Inc., et al., Index No.: 153644/2023 [IWOV-iManage.FID519535] 212-229-8503 Sent from my iPhone On Sep 27, 2023, at 8:13 PM, Jeremiah Iadevaia wrote: Talk then. What number should we call? From: Adam Sherman Sent: Wednesday, September 27, 2023 8:12 PM To: Jeremiah Iadevaia Cc: Matthew Dorfman ; Stefany Arteaga ; Eduard Kushmakov Subject: Re: Bago, et al. v. La Brochette, Inc., et al., Index No.: 153644/2023 [IWOV-iManage.FID519535] 2:30 p.m. works Sent from my iPhone On Sep 27, 2023, at 6:13 PM, Jeremiah Iadevaia wrote: How is 12:30, 1:30, or 2:30? FILED: NEW YORK COUNTY CLERK 12/22/2023 04:51 PM INDEX NO. 153644/2023 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 12/22/2023 From: Adam Sherman Sent: Wednesday, September 27, 2023 5:45 PM To: Matthew Dorfman Cc: Stefany Arteaga ; Eduard Kushmakov ; Jeremiah Iadevaia Subject: Re: Bago, et al. v. La Brochette, Inc., et al., Index No.: 153644/2023 [IWOV- iManage.FID519535] Please provide times for a call tomorrow. That seems reasonable. Thank you. On Wed, Sep 27, 2023 at 5:43 PM Matthew Dorfman wrote: Hi Adam, We are fine having a meet and confer phone call, but unfortunately we don’t have enough time to wait until next week given the current deadline for submitting briefing. If defendants would consent to a further extension of the briefing scheduling, next week is fine. If not, we ask to speak tomorrow. 1. In our email, we acknowledge that some of the information has been produced, but not all of it. We tried to highlight where there are deficiencies. 2. Regarding the potential class, we are looking for information about the number of servers and others who received tips during the applicable period. If defendants are unwilling to give names at this point, we need defendants to provide under oath the number of individuals who served in those roles, their titles, and dates of employment. 3. For purposes of the documents, we won’t object for now (subject to class certification) to redactions of names, but we need some system to decipher how many people we are talking about. It could be by number or letter (i.e., Employee A, Employee B, etc.). Thanks. From: Adam Sherman Sent: Wednesday, September 27, 2023 5:00:00 PM To: Matthew Dorfman Cc: Stefany Arteaga ; Eduard Kushmakov ; Jeremiah Iadevaia Subject: Re: Bago, et al. v. La Brochette, Inc., et al., Index No.: 153644/2023 [IWOV- iManage.FID519535] Dear Matthew: I am frankly confused by your email. On one hand, you write that the Plaintiffs are not seeking the names and contact information of potential class members. On the other hand, you are seeking the production of documents that would reflect that same information. For example, you claim entitlement to all putative class members pay records, but those records would necessarily disclose the names of those class members. Therefore, I am confused. Jeremiah: FILED: NEW YORK COUNTY CLERK 12/22/2023 04:51 PM INDEX NO. 153644/2023 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 12/22/2023 Jeremiah: This piecemeal approach is not efficient. I propose that we have a meet and confer on these topics on Friday or Monday afternoon. Moreover, some of the items in your bullet list have already been produced. Please advise. Thanks. On Tue, Sep 19, 2023 at 2:18 PM Matthew Dorfman wrote: Hi Adam, We have started reviewing your discovery responses and we have some concerns. Specifically, for purposes of class certification, we need the names of all individuals who would be members of the putative class. Pursuant to interrogatory 5, please provide a list of all individuals who have worked for La Brochette, Inc. since December 1, 2017, in a role that would have entitled the individual to a share of the tip pool or who were otherwise paid the tipped minimum wage. This may include, inter alia, servers, bussers, and hosts. In this list, please include their names, each of their job titles, and the date range during which each of them were employed by La Brochette, Inc. Contrary to defendants’ objections, plaintiffs’ allegations are far from conclusory, including providing detail as to why other Servers at La Brouchette would be suitable class members. For example, the Complaint alleges: 1. Defendants employed Plaintiffs, and others similarly situated, as tipped employees (or “Servers”) (see paragraph 3); 2. Defendants improperly classified Servers as independent contractors (see paragraphs 4, 45); 3. Defendants failed to pay Servers “spread of hours” pay (see paragraphs 6, 41); 4. Defendants failed to provide Servers with proper notice of the tipped minimum wage (see paragraphs 7, 40); 5. Defendants failed to advise Servers of the tip pooling policy in writing (see paragraph 46); 6. Defendants denied Servers the opportunity to earn tips FILED: NEW YORK COUNTY CLERK 12/22/2023 04:51 PM INDEX NO. 153644/2023 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 12/22/2023 6. Defendants denied Servers the opportunity to earn tips at private events despite paying them the tipped minimum wage (see paragraph 9); 7. Defendants forced Servers to share their tips with non- tipped workers (see paragraph 10); 8. Defendants failed to properly account for tips made by patrons (see paragraphs 43, 47); 9. Defendants failed to keep records required of employers (see paragraph 48); 10. Defendants improperly retained gratuities after failing to notify customers that the charge was intended to be an administrative charge (see paragraph 44). Please let us know no later than Thursday if Defendants will provide the requested information. Otherwise, we will raise the issue with the Court. We are happy to discuss by phone. We have other concerns, and we will be following up, but for now, we wanted to address this issue as it is important for purposes of class certification. Sincerely, Matthew Dorfman Vladeck, Raskin & Clark, P.C. Please note our new address: 111 Broadway, Suite 1505 New York, NY 10006 (646)771-9013 mdorfman@vladeck.com Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. This email has been scanned for viruses and malware, and may have been automatically archived by Mimecast Ltd, an innovator in Software as a Service (SaaS) for business. Providing a safer and more useful place for your human generated data. Specializing in; Security, archiving and compliance. To find out more Click Here. FILED: NEW YORK COUNTY CLERK 12/22/2023 04:51 PM INDEX NO. 153644/2023 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 12/22/2023 Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. This email has been scanned for viruses and malware, and may have been automatically archived by Mimecast Ltd, an innovator in Software as a Service (SaaS) for business. Providing a safer and more useful place for your human generated data. Specializing in; Security, archiving and compliance. To find out more Click Here. Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. This email has been scanned for viruses and malware, and may have been automatically archived by Mimecast Ltd, an innovator in Software as a Service (SaaS) for business. Providing a safer and more useful place for your human generated data. Specializing in; Security, archiving and compliance. To find out more Click Here. Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. This email has been scanned for viruses and malware, and may have been automatically archived by Mimecast Ltd, an innovator in Software as a Service (SaaS) for business. Providing a safer and more useful place for your human generated data. Specializing in; Security, archiving and compliance. To find out more Click Here. Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. This email has been scanned for viruses and malware, and may have been automatically archived by Mimecast Ltd, an innovator in Software as a Service (SaaS) for business. Providing a safer and more useful place for your human generated data. Specializing in; Security, archiving and compliance. To find out more Click Here.