Rosas et al v. Alice's Tea Cup, LLC et al
MEMORANDUM AND ORDER granting 21 Motion for Protective Order: The plaintiffs' motion (Docket no. 21), is granted. The plaintiffs' application for a protective order is granted to the extent that the defendants may not seek discovery of the plaintiffs' immigration status, tax returns, or current employers. The plaintiffs are also granted leave to amend the complaint to add Lauren Fox as a defendant, add Teofilio Toribio as a plaintiff, and remove the collective and class action allegations. (Signed by Magistrate Judge James C. Francis on 7/6/2015) Copies Transmitted By Chambers. (tn)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
- - - - - - - - - - - - - - - - - -:
DAVID ROSAS, JUAN PEREZ, IGNACIO
TORRES, JOSE R. MALDONADO, ISABEL :
TORIBIO SOLIS, DAVID RIVERS-SOLIS, :
RAMIRO SALGADO-LANDA, ALFREDO
SALAS-FLORES, and MIGUEL A. RIVERA,:
on behalf of themselves and others :
- against :
ALICE’S TEA CUP, LLC, ATC II LLC, :
and ATCIII, LLC, and/or any other :
business entity doing business as :
“ALICE’S TEA CUP,” located at 102 :
West 73rd Street, New York, New
York, and 156 East 64th Street,
New York, New York, and 220 East
81st Street, New York, New York,
and ZHARIFF MELGOZA, and HALEY
- - - - - - - - - - - - - - - - - -:
JAMES C. FRANCIS IV
UNITED STATES MAGISTRATE JUDGE
14 Civ. 8788 (JCF)
The plaintiffs, current and former employees of Alice’s Tea
Cup, LLC, ATC II LLC, and ATCIII, LLC (all restaurants doing
business under the name “Alice’s Tea Cup”) bring this action
against the three associated entities alleging violations of the
Fair Labor Standards Act (the “FLSA”), 29 U.S.C. §§ 201, et seq.,
and the New York Labor Law (the “NYLL”), N.Y. Lab. Law §§ 190, et
The parties have consented to my jurisdiction for all
purposes pursuant to 28 U.S.C. § 636(c).
In response to discovery
requests from the defendants, the plaintiffs filed a motion for a
The plaintiffs also seek leave to amend the
For the following reasons, both applications are
employment, the defendants failed to pay them overtime compensation
and a “spread of hours” premium for days when the plaintiffs worked
more than ten hours.
(Complaint (“Compl.”), ¶¶ 2, 4).
Complaint asserts claims against the three corporate defendants as
well as Zhariff Melgoza and Haley Fox, who “own the stock of
Alice’s Tea Cup, own Alice’s Tea Cup, and manage and make all
business decisions,” including decisions related to employee hours
(Compl., ¶¶ 110, 111).
In discovery requests dated May 11, 2015, the defendants
immigration status, work authorization documents, federal and state
income tax returns, and documents “sufficient to identify the
current employer” for each plaintiff.
(Defendants’ First Request
for Documents (“Def. Doc. Req.”), attached as Exh. A to Declaration
of Peter H. Cooper dated May 15, 2015 (“Cooper Decl.”), Request
nos. 12-15, 33). The defendants also request admissions related to
the plaintiffs’ immigration status and authorization to work.
(Defendants’ First Request for Admissions to Plaintiffs (“Def.
RFA”), attached as Exh. B to Cooper Decl., Request nos. 1-15, 20).
They ask the plaintiffs to admit that they “supplied false or
fictitious [S]ocial [S]ecurity numbers” to the defendants during
the course of their employment and that “none of the [S]ocial
[S]ecurity numbers [the p]laintiffs provided . . . were actually
(Def. RFA, Request nos. 11, 12).
On May 15, 2015, the plaintiffs filed the instant motion for
a protective order and for leave to amend the complaint.
address these two issues separately.
A. Motion for a Protective Order
The plaintiffs seek an order “[p]rotecting plaintiffs from any
discovery demand that involves plaintiffs’ immigration status or
citizenship at the present or any point in time,” barring the
discovery of the plaintiffs’ federal or state income tax returns,
and protecting the plaintiffs from having to disclose their current
(Notice of Motion at 1; Memorandum of Law in Support of
Plaintiffs’ Motion for a Protective Order and Leave to Amend the
Complaint (“Pl. Memo.”) at 2; Reply Memorandum of Law in Further
Support of Plaintiffs’ Motion for a Protective Order and Leave to
Amend the Complaint (“Pl. Reply”) at 6-7).
plaintiffs seek a protective order as to the Defendants’ First
Request for Documents, paragraphs 12-15 and 33, and the Defendants’
First Request for Admissions, paragraphs 1-15 and 20.
at 2). The plaintiffs contend that their immigration statuses, tax
returns, and current employers are irrelevant to the current
(Pl. Memo. at 3-4, 6).
The defendants oppose the
relevant to the plaintiffs’ ability to recover under the FLSA and
the NYLL as well as their credibility, and would explain the
absence of some payroll records.
(Memorandum of Law of Defendants
in Opposition to Plaintiffs’ Motion for a Protective Order and
Leave to Amend the Complaint (“Def. Memo.”) at 12-15).
1. Legal Standard
regarding any nonprivileged matter that is relevant to any party’s
claim or defense.”
Fed. R. Civ. P. 26(b)(1).
relevant if: (a) it has any tendency to make a fact more or less
probable than it would be without the evidence; and (b) the fact is
of consequence in determining the action.”
Fed. R. Evid. 401.
Evidence that is irrelevant or may result in undue prejudice
is outside the scope of discovery.
A court may issue a protective
order for good cause in order to “protect a party or person from
annoyance, embarrassment, oppression, or undue burden or expense.”
Fed. R. Civ. P. 26(c); see Herbert v. Lando, 441 U.S. 153, 177
(1979) (“[T]he district courts should not neglect their power to
restrict discovery where justice requires [protection for] a party
or person from annoyance, embarrassment, oppression, or undue
burden or expense.” (alteration in original)); In re Cooper Tire &
Rubber Co., 568 F.3d 1180, 1188-89 (10th Cir. 2009) (noting that
Rule 26(c)’s “good-cause standard is intended to be flexible”).
If the evidence sought is relevant, “the burden is upon the
party seeking non-disclosure or a protective order to show good
Penthouse International, Ltd. v. Playboy Enterprises, 663
F.2d 371, 391 (2d Cir. 1981).
Good cause is established by
“demonstrating a particular need for protection.” Cipollone v.
Liggett Group, Inc., 785 F.2d 1108, 1121 (3d Cir. 1986); see In re
Terrorist Attacks on Sept. 11, 2001, 454 F. Supp. 2d 220, 222
(S.D.N.Y. 2006) (“Ordinarily, good cause [for a protective order]
exists when a party shows that disclosure will result in a clearly
defined, specific and serious injury.”); Koster v. Chase Manhattan
appropriateness of protective relief from discovery depends upon a
balancing of the litigation needs of the discovering party and any
discovery is sought.” Apex Oil Co. v. DiMauro, 110 F.R.D. 490, 496
(S.D.N.Y. 1985); accord Duling v. Gristede’s Operating Corp., 266
F.R.D. 66, 71-72 (S.D.N.Y. 2010).
2. Immigration Status
Recoverability of Backwages by Undocumented
Workers Under the FLSA and the NYLL
invalid employment authorization documents, their “claims for wages
under New York Labor Law are barred as a matter of law,” and that
evidence regarding their immigration status and work authorization
is therefore relevant.
(Def. Memo. at 12).
In support of their
position, the defendants cite Hoffman Plastic Compounds v. National
Labor Relations Board, 535 U.S. 137, 148-49 (2002), in which the
Supreme Court disallowed an undocumented immigrant from recovering
backpay on a wrongful termination claim under the National Labor
Relations Act (the “NLRA”) because such a result would “run
counter to policies underlying [the Immigration Reform and Control
Act (the “IRCA”), 8 U.S.C.A. § 1324c(a)].”
However, federal courts have made “clear that the protections
of the FLSA are available to citizens and undocumented workers
Flores v. Albertsons, Inc., CV 01-00515, 2002 WL 1163623,
at *5 (C.D. Cal. April 9, 2002); see also
Colon v. Major Perry
Street Corp., 987 F. Supp. 2d 451, 459 (S.D.N.Y. 2013) (“FLSA’s
mandatory language leaves no discretion for courts to alter the
status.”); Contreras v. Corinthian Vigor Insurance Brokerage, Inc.,
25 F. Supp. 2d 1053, 1056 (N.D. Cal. 1998).
Therefore, in the
context of wage and hour violations under both the FLSA and the
immigration status irrelevant to both FLSA and NYLL claims);
Francois v. Mazer, No. 09 Civ. 3275, 2012 WL 1506054, at *1
(S.D.N.Y. April 24, 2012) (“This Court finds that evidence of
immigration status is irrelevant and therefore not admissible
regarding any issue with respect to any [FLSA or] New York state
law claim.”); Flores v. Amigon, 233 F. Supp. 2d 462, 464-65
(E.D.N.Y. 2002); Liu v. Donna Karan International, Inc., 207 F.
Supp. 2d 191, 192 (S.D.N.Y. 2002) (“[C]ourts addressing the issue
plaintiff-workers’ immigration status in cases seeking unpaid wages
Thus, courts distinguish between “undocumented workers seeking
backpay for wages actually earned,” as in FLSA wage and hour
violations, and “those seeking backpay for work not performed,” as
in a termination in violation of the NLRA.
Flores, 233 F. Supp. 2d
protection of the FLSA would “permit abusive exploitation of
workers” and “create an unacceptable economic incentive to hire
undocumented workers by permitting employers to underpay them,” in
violation of the spirit of the IRCA.
Contreras, 25 F. Supp. 2d at 1056).
Id. at 463-64 (quoting
This distinction was clear
before Hoffman and has been reiterated since.
See Colon, 987 F.
overwhelmingly distinguished NLRA precedents from FLSA doctrine”).
For this reason, the defendants’ contentions regarding the
plaintiffs’ NYLL claims fail.
In arguing that a worker who
violates the IRCA is barred from recovery, the defendants rely only
on cases in which plaintiffs sought backpay for work not performed.
(Def. Memo. at 9-12); see Madeira v. Affordable Housing Foundation,
Inc., 469 F.3d 219, 222-23 (2d Cir. 2006) (holding that employee
was not barred from recovering lost future wages due to work site
undocumented workers); Ambrosi v. 1085 Park Avenue, LLC, No. 06
Civ. 8163, 2008 WL 4386751, at *13 (S.D.N.Y. Sept. 25, 2008)
violation of IRCA could not recover lost future wages in personal
injury action under NYLL); Balbuena v. IDR Realty LLC, 6 N.Y.3d
338, 363, 812 N.Y.S.2d 416, 430 (2006) (holding that employee could
recover lost future wages in personal injury action in absence of
proof of IRCA violation).
These cases are inapplicable where a
plaintiff seeks backpay under the NYLL for work actually performed.
See Akin v. Anion of Greenlawn, Inc., 35 F. Supp. 3d 239, 241-42
(E.D.N.Y. 2014) (holding that Hoffman and its progeny do not bar
recovery of backpay for work actually performed under NYLL or
FLSA); Colon, 987 F. Supp. 2d at 464-65 (finding plaintiffs’
immigration status irrelevant to both FLSA and NYLL wage and hour
claims and therefore denying discovery request).
Because the plaintiffs here seek payment under the FLSA and
the NYLL only for work already performed (Pl. Reply at 5), the IRCA
has no bearing on their ability to recover backpay.
Relevance of Immigration Status to Absence of
The defendants also assert that information regarding the
plaintiffs’ immigration status is relevant and discoverable because
it will “explain why [the plaintiffs] were satisfied with the
manner in which [the d]efendants initially documented their wages,
through the use of cash sheets, and only took action after [the
d]efendants sought to move them to payroll.”
(Def. Memo. at 13).
In making this argument, the defendants rely solely on Campos v.
Lemay, No. 05 Civ. 2089, 2007 WL 1344344 (S.D.N.Y. May 7, 2007).
(Def. Memo. at 14-15).
In that case, the court ruled that a
plaintiff’s immigration status was discoverable notwithstanding
“the in terrorem effect of inquiring into a party’s immigration
status” because it explained why the plaintiff’s wages had been
paid in cash and had not been recorded, thereby undercutting the
credibility of the plaintiff’s claims of underpayment.
Id. at *7with
overwhelming weight of authority,” Marquez v. Erenler, Inc., No. 12
Civ. 8580, 2013 WL 5348457, at *1 n.1 (S.D.N.Y. Sept. 20, 2013),
but is inapplicable here; unlike in Campos, 2007 WL 1344344, at *2,
the plaintiffs in this case were not paid exclusively in cash, and
the defendants have maintained payroll records.
attached as Exh. C to Letter of Kurt D. Olender dated Oct. 17, 2014
(attached as Exh. A to Declaration Of Howard A. Matalon dated June
Relevance of Immigration Status to Credibility
immigration status is relevant to the plaintiffs’ credibility.
However, “[w]hile it is true that credibility is always at issue,
that ‘does not by itself warrant unlimited inquiry into the subject
of immigration status when such examination would impose an undue
burden on private enforcement of employment discrimination laws.’”
Rengifo v. Erevos Enterprises, Inc., No. 06 Civ. 4266, 2007 WL
894376, at *3 (S.D.N.Y. March 20, 2007) (quoting Avila-Blum v. Casa
de Cambio Delgado, Inc., 236 F.R.D. 190, 192 (S.D.N.Y. 2006)).
Even if evidence regarding immigration status were relevant, “the
risk of injury to the plaintiffs if such information were disclosed
outweighs the need for its disclosure” because of the danger of
intimidation and of undermining the purposes of the FLSA. Liu, 207
F. Supp. 2d at 192-93; see also Flores, 233 F. Supp. 2d at 464-65
(“[T]he potential for prejudice far outweighs whatever minimal
probative value  information [about plaintiffs’ immigration
status] would have.”); Fed. R. Evid. 403 (allowing courts to
exclude relevant evidence if its probative value is substantially
outweighed by danger of unfair prejudice).
In the instant case,
because “[d]iscovery into a FLSA plaintiff’s immigration status is
irrelevant and impermissible,” Colon, 987 F. Supp. 2d at 464, the
plaintiffs’ application for a protective order is granted, and the
plaintiffs’ immigration status and work authorization.
3. Tax Returns
The defendants also seek discovery of the plaintiffs’ federal
and state income tax returns.
(Def. Doc. Req., Request nos. 14,
15; Def. RFA, Request nos. 14, 15).
Income tax returns are not
inherently privileged. However, “courts are typically reluctant to
compel their disclosure because of both the private nature of the
sensitive information contained therein and the public interest in
encouraging the filing by taxpayers of complete and accurate
Uto v. Job Site Services Inc., 269 F.R.D. 209, 212
In order for a court to compel discovery of
income tax returns, a two-pronged test must be met: “first, the
court must find that the returns are relevant to the subject matter
of the action; and second, that there is a compelling need for the
returns because the information contained therein is not otherwise
Cymaticolor Corp., 106 F.R.D. 545, 547 (S.D.N.Y. 1985); accord
Rengifo, 2007 WL 894376, at *2.
Modern courts tend to place the
relevancy and a compelling need.”
Uto, 269 F.R.D. at 212; see,
e.g., Ellis v. City of New York, 243 F.R.D. 109, 111-12 (S.D.N.Y.
relevance or a compelling need.
While the defendants contend that
“the returns will further corroborate [the] [d]efendants’ position
that [the plaintiffs] were paid the amount of compensation required
by state and [f]ederal law” (Def. Memo. at 16), “the corporate
defendants possess relevant data on hours and compensation, and
there is no reason to assume that [the] defendants’ records are
less reliable than any records maintained by [the plaintiffs].”
Rengifo, 2007 WL 894376, at *2.
Indeed, the plaintiffs’ tax
returns would only include total income and not details that would
be relevant in an FLSA and NYLL suit, such as weekly wages and
specific hours worked.
Rather, “tax information from plaintiffs
would serve no obvious purpose other than intimidation.”
2013 WL 5348457, at *2.
The plaintiffs’ income tax returns need
not be disclosed.
4. Identity of Current Employers
Finally, the defendants request that the plaintiffs identify
their current employers and admit that they are being paid in cash.
(Def. Doc. Req., Request no. 33; Def. RFA, Request no. 20).
Generally, information from or about plaintiffs’ current employers
violated wage and hour laws.
See Campos v. Zopounidis, No.
3:09 CV 1138, 2011 WL 4852491, at *3 (D. Conn. Oct. 13, 2011)
“inadmissible because it is wholly irrelevant to issue of whether
Defendants”); Wagner v. Viacost.com, No. 06 81113 CIV, 2007 WL
1879914, at *1-2 (S.D. Fla. June 29, 2007) (holding that documents
from plaintiff’s current employer “are not relevant to the defense
of this [FLSA] lawsuit”); Barrington v. Mortage IT, Inc., No.
07 61304 CIV, 2007 WL 4370647, at *4 (S.D. Fla. Dec. 10, 2007)
(“The Court finds that the records of Plaintiffs’ former employers
do not appear relevant to the claims or defenses herein -- whether
Plaintiffs worked for Defendant more than 40 hours a week without
receiving overtime compensation and whether Defendant properly
classified Plaintiffs’ positions as exempt from the FLSA overtime
plaintiffs’ current employers is relevant because the plaintiffs
were “content being paid in cash because of their undocumented
(Def. Memo. at 16).
The defendants seek to prove that
the plaintiffs “are continuing to be paid on a cash basis . . .
precisely because they want to . . . avoid scrutiny.”
But whatever the plaintiffs’ arrangement with their
current employers might be, it says nothing about the hours that
the plaintiffs worked for the defendants or what they were paid.
Thus, the defendants have “failed to offer any valid argument in
support of [their] position that the requested documents are
necessary for the defense of this case.”
Wagner, 2007 WL 1879914,
Accordingly, the plaintiff’s application for a protective
order for the identity of their current employers is granted.
B. Motion for Leave to Amend Complaint
The plaintiffs also seek leave to amend the complaint to add
an additional defendant, add an opt-in plaintiff, and remove the
collective and class action allegations.
(Notice of Motion at 1;
Pl. Memo. at 6; Proposed First Amended Complaint (“Amend. Compl.”),
attached as Exh. C to Cooper Decl., ¶¶ 17, 114-120, 123).
While parties are free to amend their pleadings once as a
matter of course within twenty-one days of serving a complaint or
15(a)(1), “[i]n all other cases, a party may amend its pleading
only with the opposing party’s written consent or the court’s
Fed. R. Civ. P. 15(a)(2).
The Supreme Court has
interpreted this rule liberally, stating:
In the absence of any apparent or declared reason -- such
as undue delay, bad faith or dilatory motive on the part
of the movant, repeated failure to cure deficiencies by
amendments previously allowed, undue prejudice to the
opposing party by virtue of allowance of the amendment,
futility of amendment, etc. -- the leave sought should,
as the rules require, be freely given.
Foman v. Davis,
371 U.S. 178, 182 (1962).
Adding an Employer
The plaintiffs seek to add Lauren Fox as a defendant, arguing
that she served as an employer of the plaintiffs.
¶¶ 17, 123). Motions to amend are generally governed by Rule 15(a)
of the Federal Rules of Civil Procedure.
However, Rule 21 of the
Federal Rules of Civil Procedure controls if the proposed amendment
adds new parties.
Bridgeport Music, Inc. v. UMG Recordings, Inc.,
No. 05 Civ. 6430, 2008 WL 113672, at *2 (S.D.N.Y. Jan. 10, 2008).
Rule 21 states that a party may be added to an action “at any time,
on just terms.”
In deciding whether to permit joinder, courts
apply the “same standard of liberality afforded to motions to amend
pleadings under Rule 15.”
Soler v. G & U, Inc., 86 F.R.D. 524, 528
(S.D.N.Y. 1980); accord Smith v. P.O. Canine Dog Chas, No. 02 Civ.
6240, 2004 WL 2202564, at *12 n.11 (S.D.N.Y. Sept. 28, 2004);
Momentum Luggage and Leisure Bags v. Jansport, Inc., No. 00 Civ.
7909, 2001 WL 58000, at *1
(S.D.N.Y. Jan. 23, 2001); Clarke v.
Fonix Corp., No. 98 Civ. 6116, 1999 WL 105031, at *6 (S.D.N.Y.
March 1, 1999)).
The FLSA defines “employer” as “any person acting directly or
indirectly in the interest of an employer in relation to an
29 U.S.C. § 203(d).
“[C]ontinuous monitoring of
employees, looking over their shoulders at all times, or any sort
of absolute control” is not required, and “[c]ontrol may be
restricted, or exercised only occasionally, without removing the
employment relationship from the protections of the FLSA.”
v. RSR Security Services Ltd., 172 F.3d 132, 139 (2d Cir. 1999).
Whether someone is an employer is analyzed using an “economic
“whether the alleged employer (1) had the power to hire and fire
schedules or conditions of employment, (3) determined the rate and
method of payment, and (4) maintained employment records.”
(citing Carter v. Dutchess Community College, 735 F.2d 8, 12 (2d
“No one of the four factors standing alone is
dispositive” and “the overarching concern is whether the alleged
employer possessed the power to control the workers in question
with an eye to the ‘economic reality’ presented by the facts of
Id. (internal citation omitted); see also Irizarry v.
Catsimatidis, 722 F.3d 99, 103-05 (2d Cir. 2013), cert. denied, 134
S. Ct. 1516 (2014); Moon v. Kwon, 248 F. Supp. 2d 201, 236-37
Individuals may therefore be deemed “employers”
whether or not they have an ownership interest in the employing
corporation as long as they have “operational control” over the
See Herman, 172 F.3d at 140 (finding that non-
controlling shareholder qualified as employer under FLSA); Ling Nan
Zheng v. Liberty Apparel Co., 556 F. Supp. 2d 284, 299 (S.D.N.Y.
2008) (same); Ansoumana v. Gristede’s Operating Corp., 255 F. Supp.
2d 184, 192-93 (S.D.N.Y. 2003).
While the New York Court of
Appeals has not determined whether the employer test is the same
under the NYLL and FLSA, Irizarry, 722 F.3d at 117, “[d]istrict
courts in this Circuit have interpreted the definition of employer
under the [NYLL] coextensively with the definition used by the
FLSA,” Sethi v. Narod, 974 F. Supp. 2d 162, 188 (E.D.N.Y. 2013).
The plaintiffs here have made factual allegations that may
meet the elements of the economic reality test, because they allege
that Ms. Fox “supervised and controlled plaintiffs’ work, 
controlled their compensation” (Pl. Memo. at 6), and was “present
on a daily basis” (Pl. Rep. Memo. at 8).
The plaintiffs may
uncover evidence during discovery to support these allegations.
While the defendants argue that Ms. Fox “was not involved in any of
the Company’s daily operations, particularly employment decisions”
(Def. Memo. at 19), this is an issue for the factfinder to resolve.
In the instant case, the plaintiffs have made sufficient factual
allegations for Lauren Fox to be added as an additional employer in
the amended complaint.
3. “Opt-in” Plaintiff
The plaintiffs also seek to add Teofilio Toribio as an opt-in
plaintiff. (Pl. Memo. at 6). The Federal Rules of Civil Procedure
allows a plaintiff to join a lawsuit if: “(a) they assert any right
to relief jointly, severally, or in the alternative with respect to
or arising out of the same transaction, occurrence, or series of
transactions or occurrences; and (b) any question of law or fact
common to all plaintiffs will arise in the action.”
Fed. R. Civ.
The FLSA requires plaintiffs to submit a consent to
join in writing in order to become a party to the case.
29 U.S.C. § 216(b) (“No employee shall be a party plaintiff to any
such action unless he gives his consent in writing to become such
a party and such consent is filed in the court in which such action
is brought.”). In the instant case, the plaintiffs allege that Mr.
Toribio is asserting a right arising out of the same transaction or
occurrence as the existing claims and there is a common question of
law or fact.
Mr. Toribio has filed a consent to join (Pl. Memo. at
6 n.l), and the defendants do not oppose.
Therefore, Mr. Toribio
may be joined as a plaintiff to the suit.
Collective and Class Action Allegations
The plaintiffs finally seek to remove the collective and class
by the defendants.
(Pl. Memo. at 6).
This issue is not contested
The plaintiffs are granted leave to remove the
collective and class action allegations.
plaintiffs' application for a protective order is granted to the
plaintiffs' immigration status, tax returns, or current employers.
The plaintiffs are also granted leave to amend the complaint to add
Lauren Fox as a defendant, add Teofilio Toribio as a plaintiff, and
remove the collective and class action allegations.
UNITED STATES MAGISTRATE JUDGE
Dated: New York, New York
July 6, 2015
Copies transmitted this date:
Peter H. Cooper, Esq.
Cilenti & Cooper, PLLC
708 Third Ave.
New York, NY 10017
Christian J. Jensen, Esq.
Howard Matalon, Esq.
Olender Feldman LLP
422 Morris Ave.
Summit, NJ 07901
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