Motion for Writ in Zoryha Norfleet, Lisa Abbas, Valerie Janowski v. Revcore Recovery Center Manhattan Llc, Revcore Recovery Center Of Queens Llc, Revcore Nycats Llc, Revcore Holdings Llc| Trellis.Law

On October 31, 2023 a Motion-Secondary was filed involving a dispute between Lisa Abbas, Valerie Janowski, Zoryha Norfleet, and Revcore Holdings Llc, for Torts - Other (N.Y. Labor Law) in the District Court of Nassau County.

Preview
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
----------------------------------------------------------------------------- X
ZORYHA NORFLEET, LISA ABBAS and VALERIE :
JANOWSKI on behalf of themselves and all others similarly : Index No. 617754/2023
situated, :
: Justice Assigned:
Plaintiffs, : _____________
- against - :
:
REVCORE RECOVERY CENTER MANHATTAN LLC, : Return Date:
REVCORE RECOVERY CENTER OF QUEENS LLC, : November 22, 2023
REVCORE NYCATS LLC, and REVCORE HOLDINGS LLC, :
: Mot. Seq. No. 1
Defendants. :
----------------------------------------------------------------------------- X

AFFIRMATION OF TROY L. KESSLER IN SUPPORT OF PLAINTIFFS’ MOTION
FOR APPROVAL OF THE CLASS ACTION SETTLEMENT

Troy L. Kessler, hereby declares under penalty of perjury:

1. I am a shareholder and co-founder of the law firm of Kessler Matura P.C. (“KM”),

counsel for Plaintiffs Zoryha Norfleet, Lisa Abbas and Valerie Janowski, on behalf of themselves

and all others similarly situated, (collectively, “Plaintiffs”), and the putative class action in the

above-captioned action.

2. I am familiar with the facts and circumstances of this action. I submit this

affirmation to place before the court relevant documents and information in further support of

Plaintiffs’ Motion for Approval of the Class Action Settlement.

Kessler Matura P.C.’s Qualifications

3. Attached as Exhibit C is my CV, which includes an overview of KM’s firm history.

4. Attached as Exhibit D is the CV of Garrett Kaske, a KM associate.

5. Attached as Exhibit E is the CV of Tana Forrester, a KM associate.

1 of 15
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

6. In Rodriguez v. Joseph Eletto Transfer, Inc., the Honorable Jefferey S. Brown,

J.S.C., approved a class action settlement finding that KM’s attorneys have “significant experience

prosecuting employment class actions and their work performed in representing the interests of the

class members.” 2016 NY Slip Op 32592(U), at *3 (Sup. Ct. Dec. 15, 2016)

7. In Garcia v. Pancho Villa’s of Huntington Village, the Hon. E. Thomas Boyle,

U.S.M.J., certified the matter as a class action stating that KM’s attorneys are “experienced labor

and employment litigators, who have successfully represented employees in numerous collective

and class action lawsuits.” 281 F.R.D. 100, 107 (E.D.N.Y. 2011).

8. In Morris v. Affinity Health Plan, the Hon. Andrew L. Carter, Jr., U.S.D.J., certified

a class action and approved a class action settlement stating that KM’s attorneys “have substantial

experience prosecuting and settling wage and hour actions, are well-versed in wage and hour and

class action law, have been class or lead counsel in numerous wage and hour class and collective

actions.” 859 F. Supp. 2d 611, 616 (S.D.N.Y. 2012). Moreover, Judge Carter determined that my

firm consists of “experienced employment lawyers with good reputations among the employment

law bar . . . [and] substantial experience prosecuting large-scale wage and hour class and collective

actions.” Id. at 622.

9. In addition to these cases, local courts have repeatedly found that my firm and I

have served as adequate counsel in collective and class actions. See e.g., Manfredo v. VIP Auto

Group of Long Island, Inc., No. 2:20 Civ. 3728, ECF No. 46 (E.D.N.Y. Jan. 12, 2023); Fishkin v.

Gourmet Express LTD, No. 610142/2022, NYCEF No. 14 (Sup. Ct. Oct. 20, 2022); Henne v. LI Wax

FD, LLC, et al., No. 200516/2022, NYSCEF No. 20 (Sup. Ct. Oct. 18, 2022); Dawson v. Sterling

Bancorp., Inc., No. 623157/2019, 2020 N.Y. Slip Op. 33715(U), at *4 (Sup. Ct. Oct. 29, 2020)

(Kevins, J.S.C) (“[KM] has established that the law firm has substantial experience and is well

2 of 15
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

versed on the subject matter of the lawsuit.”); Robinson v. Big City Yonkers, Inc., Index No.

600159/2016, 2017 N.Y. Slip Op. 30177(U) (Sup. Ct. Jan. 17, 2017) (Sher, A.J.S.C.); Bijoux v.

Amerigroup New York, LLC, No. 14 Civ. 3891, 2016 WL 2839797, at *1 (E.D.N.Y. May 12,

2016); Sukhnandan v. Royal Health Care of Long Island LLC, No. 12 Civ. 4216, 2014 WL

3778173, at *8 (S.D.N.Y. July 31, 2014).

The Instant Action

Investigation

10. This is a class action lawsuit to recover liquidated damages against Defendants for

violations of the New York Labor Law, Art. 6 §§ 190 et seq. (“NYLL”), on behalf of all Group

Facilitators, Substance Abuse Counselors or Peer Advocates (“Counselors”) at any time between

August 15, 2016 and August 15, 2022 (the “Class Period”), based on Defendants’ violation of the

Fair Labor Standards Act (“FLSA”) and the New York Labor Law (“NYLL”) and appropriate

rules and regulations. NYSCEF No. 1 (Compl.) ¶¶ 1, 53, 59.

11. Before filing the litigation, KM engaged in a robust investigation of the Plaintiffs’

claims, Defendants’ businesses, ownership, and prior litigation, Defendants’ anticipated defenses,

the propriety of maintaining class certification through trial, and the risks associated with litigation.

12. KM conducted in-depth interviews of Plaintiffs and other prospective Class

Members.

13. Based on this investigation and KM’s experience litigating cases on behalf of

workers in this industry, KM believes that Class Members were not paid for all hours worked over

40 at the required rate of time and one half.

3 of 15
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

Settlement Discussions

14. On August 8, 2022, KM wrote Defendants with the goal of entering into pre-suit

settlement discussions.

15. After some preliminary discussions, the parties entered into an agreement, tolling

the running of the statute of limitations from August 15, 2022, until January 20,2023.

16. From August 2022 through September 2023, in addition to sharing documents, the

Parties engaged in a prolonged dialogue, including numerous phone calls and detailed written

exchanges, of the facts and legal issues. Through this candid dialogue, the Parties narrowed the

issues of viable disputes, debated the viability of Plaintiffs’ claims and Defendants’ defenses, the

likelihood of maintaining a class action through trial, explored potential impediments to

settlement, and determined the outer bounds of a potential recovery, and concluded that there were

at least 80 putative class members at issue.

17. Defendants provided summary payroll and personnel data, which KM used to

calculate damages. KM shared their analysis with Defendants’ counsel. (KM modified this model

several times, after receiving additional documentation and information from Defendants after the

mediation.) KM also considered the information gleaned from counsel’s extensive investigation,

including KM’s interviews of the Class Members and internet research on Defendants’ operations.

18. From February 2023 to July 2023, the Parties negotiated and eventually reached an

agreement. Thereafter, the Parties negotiated the Agreement’s terms, and a fully executed

Agreement was signed on October 16, 2023. See generally Ex. A (Agr.).

19. On October 31, 2023, Class Counsel filed the Complaint in the instant action.

4 of 15
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

The Settlement

Fairness of the Settlement

20. The Gross Settlement Fund of $175,000 is a compromise figure. In reaching the

Settlement, KM carefully evaluated the merits of the case and proposed settlement and considered

the risks of establishing liability and maintaining class certification through Defendants’ appeal

and any subsequent trial, and considered the time, delay, and financial repercussions of litigation.

Although KM believes that Plaintiffs’ claims are strong, we recognize the legal, factual, and

procedural obstacles to recovery, as Defendants have and will continue to contest Plaintiffs’ claims

if the action does not settle. Moreover, even if this case were to proceed to trial, KM recognizes

that the apparent strengths of Plaintiffs’ claims are no guarantee against a complete or partial

defense verdict. Even if a judgment were obtained against Defendants at trial, the relief might be no

greater, and indeed might be less, than that provided by the proposed settlement.

21. As discussed above, the settlement negotiations were always hard fought at arm’s-

length, and they have produced a result that KM believes to be in the best interests to Class

Members in light of the costs and risks of litigation. To fully succeed in this case, Plaintiffs would

have to rebut Defendants’ anticipated defenses, including that: (1) Class Members are not entitled

to overtime pay; (2) Defendants acted in reasonable good-faith, nullifying any claim of liquidated

damages; (3) Class Members did not typically work over 40 hours per week and were already paid

for any such work; (4) Defendants supplied Class Members with an accurate statement of wages

as required by N.Y. Lab. Law § 195. Plaintiffs would also have to affirmatively prove that: (1)

Class Members worked more than the hours recorded by Defendants; (2) Defendants knew Class

Members compensable time beyond their paid hours; (3) the amount of overtime Class Member

worked; and (3) Defendant’s paystubs did not comply with the NYLL.

5 of 15
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

22. Defendants fully deny Plaintiffs’ claims. At all times, Defendants have presented

meritorious factual and legal arguments in support of its defense that its policies and procedures

complied with all state wage-and-hour laws.

23. Knowing these risks and having been involved in negotiations to date, Plaintiffs are

pleased with the settlement and are eager to proceed to the next phase of the settlement process.

24. Considering the strengths and weaknesses of the case, KM believes the settlement

easily falls within the range of reasonableness because it achieves a significant benefit for Plaintiffs

and Class Members in the face of substantial obstacles. Moreover, in our estimation, the settlement

represents a significant percentage of the recovery that Class Members would have achieved had

they prevailed on all their claims, survived an appeal, and succeeded in collecting on the judgment.

By Class Counsel’s estimation, the fund represents about 15 percent of the Class’s best-case

recovery. This assumes that each Class Member worked seven and a half unpaid hours a week,

over the course of a collective 3,800 weeks, with an average blended wage rate of $25.00, and

each Class Member would be entitled to the full measure of liquidated damages and the maximum

$5,000 per-person amount for wage statement claims.

25. As a result, this settlement achieves all the objectives of the litigation, namely a

substantial monetary settlement to Class Members who were subjected to Defendants allegedly

unlawful wage-and-hour policies.

Plaintiffs’ Contributions to the Class

26. Plaintiffs made important contributions to the prosecution and fair resolution of this

action on behalf of the Class.

27. Plaintiffs expended considerable time and effort assisting Class Counsel with the

case, including: informing KM of the facts initially and as the negotiations progressed; providing

6 of 15
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

KM with relevant documents in their possession; and reviewing the terms of the Agreement and

executing same.

28. Throughout the prosecution of these claims, Plaintiffs spoke with other Class

Members to locate witnesses and provided KM with essential information and evidence.

29. Plaintiffs Norfleet, Abbas and Janowski, as the representative plaintiffs, through

their active participation in this lawsuit and their actions before bringing this suit, have

demonstrated that they sought to protect the interests of all Class Members. In addition to the

above, they have placed their names on the lawsuit despite any potential detriment it may have on

their careers.

30. Plaintiffs are also providing Defendants with additional consideration – a general

release – in exchange for the proposed Service Payments.

31. Ultimately, Plaintiffs made important contributions to the prosecution and fair

resolution of this action on behalf of the Class.

32. Plaintiffs faced significant risk by publicly filing claims against their former

employer. In other cases, KM’s clients have reported difficulty getting hired after filing a lawsuit

like this, whether because of employer blackballing or putative employers seeing the lawsuit

pending at the top of a Google search. Recently the lead plaintiff in a class-action case for unpaid

wages, KM’s client, was disparaged by other employees and members of her community on

Facebook after the defendant in that case posted about the case. Unfortunately, before KM

discovered the post and negotiated for its deletion, the post received significant traction on

Facebook: 276 individuals “Liked” it, there were 117 comments made, and 56 individuals shared

it.

7 of 15
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

33. Plaintiffs worked diligently to achieve this class-wide recovery. Plaintiffs worked

with KM to investigate the claims, contact witnesses and putative class members, and prepare for

the Parties’ mediation. Further, all Plaintiffs reviewed and executed the Agreement.

34. Plaintiffs’ interests are aligned with those of the Class and there is no known

conflict.

Other Factors to Consider

35. Based on KM’s research and investigation, there are no similar cases pending and

that the interest in prosecuting individual actions is minimal, not to mention inefficient, given the

relatively small value of the claim in comparison to the time and expense of prosecuting these

claims.

36. Nassau County is an appropriate forum, considering that the Parties agreed to

proceed here and KM’s investigation has not uncovered any reason to believe that the Court cannot

manage this class-action settlement.

Settlement Administrator

37. KM solicited bids from trusted settlement administrators in advance of setting the

maximum settlement administration amount of $ 8,500 in the Agreement.

38. In proposing and selecting Xpand Legal Consulting, LLC . (“Xpand Legal”), KM

considered its own experience working with Xpand Legal’s staff, the reasonableness of Xpand

Legal’s bid as compared to its competitors, and Xpand Legal’s reputation in class action

administration.

39. The Settlement Administrator agreed to and is expected to administer this

settlement for a total cost of $ 8,500. Ex. A (Agr.) § 4.6(A).

8 of 15
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

Attorneys’ Fees and Costs

40. Class Counsel has significant experience prosecuting wage-and-hour matters on

behalf of individuals and classes, and that experience was directly responsible for bringing about

the positive settlement and weighs in favor of approval of that portion of the Settlement that

represents attorney’s fees. See supra ¶¶ 3-9. Mr. Kaske, Ms. Forrester, and I have litigated against

similar employers in this industry and have favorably resolved claims for employees in similar

positions. See, e.g., Lawson v. Realization Center, Inc., No. 613219/2021, NYSCEF No. 27 (Sup.

Ct. Nassau County Feb. 23, 2022) (approving class-action settlement in unpaid overtime case);

Edmond v. New York Therapeutic Communities Inc., No. 22 Civ. 5712, ECF No. 21 (E.D.N.Y.

Mar. 10, 2023) (multi-plaintiff settlement approved).

41. As of November 10, 2023, Class Counsel has spent over 81.5 hours investigating,

negotiating, and settling this case. See Ex. F (Summary). These hours were compiled from

contemporaneous time records maintained by each attorney participating in the case. See Ex. G

(Time Records).

42. KM is a relatively small firm consisting of six attorneys, and three support staff

members, including part-time staff. As such, we have made every effort to use our resources

wisely, including in allocating work to be performed by an attorney with the lowest hourly rate

who was able to effectively perform it.

43. For instance, KM excluded or reduced the time our attorneys spent performing

administrative tasks, such as e-filing, copying, scanning, or preparing hard-copy materials, which

could have been performed by support staff at a lesser hourly rate. KM also excluded some of the

time I spent, though billable and valuable to achieving this result recovery, because that time was

either duplicative of the associates’ work or advisory.

9 of 15
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

44. As of the date of this motion, KM will have accrued over $390.71 in actual litigation

costs and expenses. See Ex. F (Summary). Further, KM is not seeking reimbursement for other

commonly recovered costs, such as printing and copying costs, and shipping costs associated with

this motion and the administration of the settlement.

45. As of November 10, 2023, KM’s total lodestar exceeded $33,253.21, exclusive of

costs, and $34,253.21 inclusive of costs. See Ex. F (Summary).

46. In our experience, law firms located in the Second Department representing

plaintiffs in wage-and-hour litigation typically charge their clients at least one-third of their gross

recoveries when representing them on a contingent basis. See, e.g., Osorno v. Avant Gardner LLC,

No. 18 Civ 1513, 2019 WL 6970745, at *2 (E.D.N.Y. Nov. 27, 2019) (“Contingency fees of one-

third in [wage-and-hour] cases are routinely approved in this circuit.”), adopted, 2019 WL

6913576 (E.D.N.Y. Dec. 18, 2019); Varela v Bldg. Serv. Indus., LLC, No. 600037/2016, 2018

N.Y. Slip Op. 33514(U), at *3 (Sup. Ct. June 25, 2018) (Brown, J.) (“An award of one third of the

common fund created by the class litigation is within the range of reasonableness previously

approved in similar cases . . . .”); Wu v. Maxphoto NY Corp., No. 15 Civ. 3050, 2016 WL 7131937,

at *3 (E.D.N.Y. Nov. 15, 2016) (approving attorney’s fees equal to 40% of the settlement; noting

that attorney’s fees equal to one-third of the gross settlement are “reasonable and consistent” with

local norms).

47. KM undertook to prosecute this action without any assurance of payment for their

services, litigating the case on a wholly contingent basis in the face of significant risk. Wage-and-

hour cases of this type are, by their very nature, complicated and time-consuming. KM frequently

undertakes representation of large numbers of affected employees in wage-and-hour actions.

Although this typically requires a tremendous investment of time, energy and resources, these

10 of 15
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

cases help push the law in a direction favorable to employees. This case was no exception. Due

also to the contingent nature our fee arrangement in this case, KM was prepared to and did make

a substantial investment of time and resources with the very real possibility of an unsuccessful

outcome – whether as a result of class and collective decertification or adjudication on the merits

– and no fee of any kind – resulting in an expensive loss.

48. Although much of KM’s work is on a contingent or hybrid fee arrangement, KM

has hourly clients. KM ordinarily and regularly bills clients at rates ranging from $625 to $525

per partner’s hour, $450 to $300 per associate’s hour, and $100 to $150 per hour for support staff.

For example, Mr. Kaske in 2022 worked on an individual’s unpaid wages matter for which KM

billed $400 an hour for his services.

49. With regards to contingency fee cases, for purposes of the crosscheck, courts in the

Eastern District and local Supreme Courts of New York have approved wage-and-hour settlements

in which KM submitted lodestar calculations using rates similar to those included here. For

instance, in approving a FLSA settlement the Honorable Magistrate Judge Tomlinson held that

KM’s attorneys’ “hourly rates . . . fall within the range of reasonable rates within the Eastern

District of New York.” Nunes v. Rob-Glen Enters., Inc., No. 16 Civ. 6207, 2018 WL 3351798, at

*2 (E.D.N.Y. July 5, 2018).1 Other examples include the following:

a. Fishkin v. Gourmet Express, LTD, No. 610142/2022, NYSCEF No. 28 (Sup. Ct.

Mar. 22, 2023) (approving class-action settlement in late-paid wages case);

1
See Summary of Attorneys’ Fees, Nunes v. Rob-Glen Enters., Inc., No. 16 Civ. 6207, ECF
No. 41-3 (E.D.N.Y. June 5, 2018) (calculating lodestar using the following rates: $450 for partner,
Troy Kessler, $250 for associate, Tana Forrester, and $100 for paralegal, Kristine Jimenez).

11 of 15
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

b. Manfredo v. VIP Auto Group of Long Island, Inc., No. 2:20 Civ. 3728, ECF No. 47

(E.D.N.Y. Jan 12, 2023) (approving class-action settlement in unpaid overtime

case);

c. Henne v. LI Wax FD, LLC, No. 200516/2022, NYSCEF No. 20 (Sup. Ct. Oct. 18,

2022) (approving class-action settlement in untimely wage payment case);

d. Lawson v. Realization Center, Inc., No. 613219/2021, NYSCEF No. 27 (Sup. Ct.

Nassau County Feb. 23, 2022) (approving class-action settlement in unpaid

overtime case).2

50. Pursuant to Plaintiffs’ retainer agreements with KM, which provides for KM to

seek up to one-third of the gross settlement as attorneys’ fees, KM has worked without

compensation of any kind, and the fee has been wholly contingent upon the result achieved.

51. KM will continue to invest significant time on this case, including seeking approval

of this settlement and administering the distribution of Plaintiffs’ settlement payments.

Documents

52. Annexed as Exhibit A is a copy the Settlement Agreement (“Agreement” or

“Agr.”), which includes the Parties’ proposed:

a. Exhibit A-1: Notice of Class Action Settlement (“Notice”);

b. Exhibit A-2: Claim Form (“Claim Form”);

2
See Attorneys’ Fees & Costs Summary, Fishkin v. Gourmet Express, LTD, No.
610142/2022, NYSCEF No. 24 (Sup. Ct. Mar. 10, 2023) (calculating lodestar using the rate of
$550 for Troy L. Kessler $400 for Garrett Kaske); Attorneys’ Fees & Costs Summary, Manfredo
v. VIP Auto Group of Long Island, Inc., No. 2:20 Civ. 3728, ECF No. 46-8 (E.D.N.Y. Dec. 13,
2022) ($500 for Troy L. Kessler and $375 for Garrett Kaske); Attorneys’ Fees & Costs Summary,
Henne v. LI Wax FD, LLC, No. 200516/2022, NYSCEF No. 13 (Sup. Ct. Sept. 28, 2022) (same);
Attorneys’ Fees & Costs Summary, Lawson v. Realization Center, Inc., No. 613219/2021,
NYSCEF No. 12 (Sup. Ct. Nassau County Oct. 25, 2021) (same, and $350 for Tana Forrester).

12 of 15
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

c. Exhibit A-3: Service Award Release Form (“Serv. Release Form”);

d. Exhibit A-4: Reminder Notice (“Reminder).

53. Annexed as Exhibit B is a Proposed Order Granting Plaintiffs’ Motion for

Approval of Class Action Settlement (“Proposed Order”).

54. Annexed as Exhibit C is Troy L. Kessler’s curriculum vitae (“Kessler CV”).

55. Annexed as Exhibit D is Garrett Kaske’s curriculum vitae (“Kaske CV”).

56. Annexed as Exhibit E is Tana Forrester’s curriculum vitae (“Forrester CV”).

57. Annexed as Exhibit F is the Attorneys’ Fees & Costs Summary (“Summary”).

58. Annexed as Exhibit G is a chart of KM’s contemporaneous time records (“Time

Records”).

59. Annexed as Exhibit H is the Settlement Administrator’s CV (“Xpand CV”).

* * * *
60. No prior request for the relief requested herein has been made.

Affirmed this 14th day
of November, 2023.

Respectfully submitted,

/s/ Troy L. Kessler
Troy L. Kessler
T
KESSLER MATURA P.C.
Troy L. Kessler
Garrett Kaske
Tana Forrester
534 Broadhollow Road, Suite 275
Melville, New York 11747
Telephone: (631) 499-9100
tkessler@kesslermatura.com
gkaske@kesslermatura.com
tforrester@kesslermatura.com

Attorneys for Plaintiffs and the
Putative Class Action

13 of 15
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

14 of 15
FILED: NASSAU COUNTY CLERK 11/14/2023 04:28 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/14/2023

22 NYCRR § 202.8-b CERTIFICATION

The undersigned certifies that this Affirmation complies with the word count limit set forth
22 NYCRR § 202.8-b, because it contains 3,562 words, excluding the parts exempted by § 202.8-
b(b). In preparing this certification, I relied on the word-count feature of Microsoft Word, which
is the word-processing system used to prepare this memorandum.

Dated: Melville, New York
November 14, 2023

By: /s/ Troy L. Kessler
Troy L. Kessler

15 of 15

Case Info

Judge

Denise Sher Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

November 14, 2023

Case Filing Date

October 31, 2023

County

Parties

For full print and download access, please subscribe at https://www.trellis.law/.

Motion-Secondary: Zoryha Norfleet, Lisa Abbas, Valerie Janowski v. Revcore Recovery Center Manhattan Llc, Revcore Recovery Center Of Queens Llc, Revcore Nycats Llc, Revcore Holdings Llc

Preview

Case Info

Parties