Motion for Summary Adjudication in Is Chrystie Management Llc, Devonwood Corporation, Llc v. Adp, Llc| Trellis.Law

On October 29, 2018 a Exhibit,Appendix was filed involving a dispute between Devonwood Corporation, Llc, Is Chrystie Management Llc, and Adp, Llc, for Commercial Division in the District Court of New York County.

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EXHIBIT A
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK: COMMERCIAL DIVISION

IS CHRYSTIE MANAGEMENT LLC and
DEVONWOOD CORPORATION LLC, Index No.: 655374/2018

Plaintiffs,
(Motion Seq. No. ____)
- against -
NOTICE OF MOTION
ADP, LLC,
Oral Argument Requested
Defendant.

PLEASE TAKE NOTICE that, upon the annexed Affirmation of Randall L.

Morrison, Jr., dated June 4, 2021 and the exhibits attached thereto, the Affidavit of John Pender

dated June 4, 2021 and the exhibit attached thereto, the accompanying memorandum of law, the

accompanying Rule 19-a Statement of Undisputed Material Facts, and all prior pleadings and

proceedings had herein, defendant ADP, Inc, (“ADP”), formerly known as ADP, LLC, by its

attorneys, Kelley Drye & Warren LLP, will move this Court at the Courthouse, located at 60

Centre Street, Room 130, New York, New York 10007 on August 6, 2021 at 9:30 a.m., or as

soon thereafter as counsel can be heard, for an Order pursuant to CPLR 3212(b) granting partial

summary judgment to ADP on the sole remaining claim for breach of contract in the Amended

Complaint, and for such other relief as this Court deems just and proper.

PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR 2214(b), any

answering papers or notices of cross-motion, with supporting papers, if any, shall be served upon

the undersigned at least seven days before the return date of this motion and reply papers shall be

served at least one day before the return date of this motion.

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Dated: New York, New York Respectfully submitted,
June 7, 2021
KELLEY DRYE & WARREN LLP

By: /s/ William S. Gyves
William S. Gyves
Randall L. Morrison, Jr.
Robert N. Ward
3 World Trade Center
175 Greenwich Street
New York, NY 10007
Tel.: (212) 808-7800
Fax: (212) 808-7897
Attorneys for Defendant

TO: Y. David Scharf
Latisha Thompson
Joaquin Ezcurra
Amber R. Will
Morrison Cohen LLP
909 Third Avenue
New York, New York 10022
Tel.: (212) 735-8600

Attorneys for Plaintiff
IS Chrystie Management LLC

Devonwood Corporation LLC previously dismissed from this action

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK: COMMERCIAL DIVISION

IS CHRYSTIE MANAGEMENT LLC and
DEVONWOOD CORPORATION, LLC,

Plaintiffs, Index No.: 655374/2018
(Motion Seq. No. 004)
- against -

ADP, LLC,

Defendant.

AFFIRMATION OF RANDALL L. MORRISON, JR.

Randall L. Morrison, Jr., an attorney duly admitted to practice law in the State of New

York, affirms under penalty of perjury, and in accordance with CPLR 2106, as follows:

1. I am an associate with the law firm of Kelley Drye & Warren LLP. We represent

defendant ADP, Inc. (“ADP”), formerly known as ADP, LLC.

2. I respectfully submit this affirmation in support of ADP’s motion for partial

summary judgment.

3. Attached hereto as Exhibit A is a true and correct copy of the Amended

Complaint filed in this action by plaintiff IS Chrystie Management LLC (“IS Chrystie”). (Doc.

No. 39).

4. Attached hereto as Exhibit B is a true and correct copy of the transcript of the

deposition of Joan (O’Connor) Farooqi in this action (“Farooqi Deposition”).

5. Attached hereto as Exhibit C is a true and correct copy of IS Chrystie’s

Objections and Responses to ADP’s Second Set of Interrogatories. Therein, in response to

ADP’s Interrogatory Nos. 15 and 16, IS Chrystie identified Ms. Farooqi as the only person with

knowledge of facts concerning each component of its alleged damages in this case.

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6. Attached hereto as Exhibit D is a true and correct copy of ADP’s Commercial

Division Rule 11-f Deposition Notice served upon IS Chrystie. Therein, at Topic Nos. 13, 14

and 20, ADP requested that IS Chrystie produce a witness designated to testify on its behalf with

respect to the “components of IS Chrystie’s alleged damages”; the “calculation of, and

documentary support for, each component” of those alleged damages; and the factual basis for IS

Chrystie’s assertion that it “has been damaged in an amount … estimated to be at least

$1,000,000” as a result of ADP’s alleged breaching conduct.

7. In response to ADP’s Rule 11-f Deposition Notice, IS Chrystie produced Ms.

Farooqi as the witness designated to testify on its behalf with respect to Topic Nos. 13, 14 and

20.

8. Attached hereto as Exhibit E is a true and correct copy of ADP’s Amended

Commercial Division Rule 11-f Deposition Notice served upon IS Chrystie. Therein, at Topic

Nos. 1, 5, 6 and 20, ADP requested that IS Chrystie produce a witness designated to testify on its

behalf with respect to “IS Chrystie’s understanding of the respective rights and obligations” of

the parties under the controlling contract; the “operation of Public Kitchen”; the “operation of

Public Hotel”; and “the corporate structure of IS Chrystie, including the identity of its principals,

members and/or managers.”

9. Attached hereto as Exhibit F is a true and correct copy of IS Chrystie’s responses

and objections to ADP’s Amended Rule 11-f Deposition Notice. Therein, IS Chrystie designated

Ms. Farooqi as the witness designated to testify on its behalf with respect to Topic Nos. 1, 5, 6

and 20.

10. I have reviewed the website of the Ian Schrager Company available at:

https://www.ianschragercompany.com. Attached hereto collectively as Exhibit G are excerpts

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from that website concerning Ian Schrager’s experience as a hotelier and real estate developer.

On behalf of ADP, I respectfully request that the Court take judicial notice of these documents.

See Guide to NY Evidence Rule 2.01(1), Judicial Notice of Facts,

https://www.nycourts.gov/judges/evidence/2-notice/2.01_judicial%20notice%20of%20facts.pdf

(facts that may be judicially noticed include “facts that are capable of accurate and ready

determination by resort to sources whose accuracy cannot reasonably be questioned”); Wells

Fargo Bank, N.A. v. Wrights Mill Holdings, LLC, 127 F. Supp. 3d 157, 166-67 (S.D.N.Y. 2015)

(court takes judicial notice of information reflected on party’s website); Doron Precision Sys.,

Inc. v. FAAC, Inc., 423 F. Supp. 2d 173, 178-179 n. 8 (S.D.N.Y. 2006) (same).

11. I have reviewed Public Hotel’s website available at: https://publichotels.com/eat-

and-drink. Attached hereto collectively as Exhibit H are excerpts from that website, as of May

24, 2021, reflecting that the food and beverage venues at Public Hotel include The Roof, Public

Diego, Public Lobby Bar and Public Louis. On behalf of ADP, I respectfully request that the

Court take judicial notice of these documents. See Wells Fargo Bank, 127 F. Supp. 3d at 166-

67; Doron Precision Sys., 423 F. Supp. 2d at 178-179 n. 8.

12. On June 1, 2021, The New York Times published an article headlined “Star Chef

From Peru to Head Public Hotel Restaurants.” The article, a true and correct copy of which is

attached hereto as Exhibit I, states that “global hotelier Ian Schrager has completely made over

the restaurants” at Public Hotel and that a new restaurant has replaced Public Kitchen as the

“signature restaurant” at Public Hotel. On behalf of ADP, I respectfully request that the Court

take judicial notice of this document. See In re SAIC Inc. Derivative Litig., 948 F. Supp. 2d 366,

386 n. 8 (S.D.N.Y. 2013) (court takes judicial notice of newspaper article).

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13. I note that Public Kitchen is no longer mentioned on Public Hotel’s website.

Attached hereto as Exhibit J are excerpts from that website, as of June 4, 2021. Instead, the

website references Popular, the new restaurant featured in the article attached as Exhibit I. On

June 4, 2021, I called the telephone number for Public Kitchen and the voicemail now indicates

that the number belongs to Popular. Based on the above, all indications are that Public Kitchen

has been closed. On behalf of ADP, I respectfully request that the Court take judicial notice of

the website excerpts attached as Exhibit J. See Wells Fargo Bank, 127 F. Supp. 3d at 166-67;

Doron Precision Sys., 423 F. Supp. 2d at 178-179 n. 8.

14. Attached hereto as Exhibit K is a true and correct copy of the Master Services

Agreement executed by and between ADP and IS Chrystie, and marked as Exhibit C at the

Farooqi Deposition.

15. Attached hereto as Exhibit L is a true and correct copy of a December 19, 2017

letter from the law firm of Fitapelli & Schaffer, LLP (“Fitapelli & Schaffer”) to Public Kitchen

c/o Fox Rothschild LLP (“Fox Rothschild”). IS Chrystie produced this document during

discovery in this case.

16. Attached hereto as Exhibit M is a true and correct copy of ADP’s First Set of

Requests for Admission to IS Chrystie dated May 7, 2021.

17. Attached hereto as Exhibit N is a true and correct copy of IS Chrystie’s

Responses and Objections to ADP’s First Set of Requests for Admission dated May 27, 2021.

18. Attached hereto as Exhibit O is a true and correct copy of a January 10, 2018

tolling agreement executed by Fitapelli & Schaffer and Fox Rothschild concerning the claims

identified in Fitapelli & Schaffer’s letter of December 19, 2017. IS Chrystie produced this

document during discovery in this case.

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19. Attached hereto as Exhibit P is a true and correct copy of a memorandum of

understanding by and between Fitapelli & Schaffer and Fox Rothschild concerning the

settlement of the claims identified in Fitapelli & Schaffer’s letter of December 19, 2017. IS

Chrystie produced this document during discovery in this case.

20. Attached hereto as Exhibit Q is a true and correct copy of the Settlement

Agreement and Release between IS Chrystie and Fitapelli & Schaffer’s client, Dinara

Zhanpiessova. (Doc. No. 6 in Public Kitchen Class Action, as defined below). On behalf of

ADP, I respectfully request that the Court take judicial notice of this publicly-filed document.

See Spencer Stuart Human Resources Consultancy (Shanghai) Co. v. American Indus.

Acquisition Corp., 2017 WL 4570791, at *1 (S.D.N.Y. Oct. 12, 2017) (court takes judicial notice

of publicly-filed documents in U.S. Bankruptcy Court proceedings); MJD Constr., Inc. v.

Woodstock Lawn & Home Maint., 293 A.D.2d 516, 517 (2d Dep’t 2002) (court entitled to take

judicial notice of the record in a related bankruptcy proceeding); People ex rel. Rosenberg v.

Rosenberg, 160 A.D.2d 327, 329 (1st Dep’t 1990) (court may take judicial notice of the ruling of

a court in another jurisdiction).

21. Attached hereto as Exhibit R is a true and correct copy of the Class Action

Complaint filed in the litigation captioned Dinara Zhanpiessova v. Devonwood Corporation,

LLC, Index No. 516028/2018 (N.Y. Supreme Kings Co.) (the “Public Kitchen Class Action”).

(Doc. No. 1). On behalf of ADP, I respectfully request that the Court take judicial notice of this

publicly-filed document. See Spencer Stuart, 2017 WL 4570791, at *1; MJD Constr., 293

A.D.2d at 517; Rosenberg, 160 A.D.2d at 329.

22. Attached collectively hereto as Exhibit S are true and correct copies of the

unopposed motion for preliminary approval of the settlement in the Public Kitchen Class Action

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with supporting brief. (Doc. Nos. 3 and 4). On behalf of ADP, I respectfully request that the

Court take judicial notice of these publicly-filed documents. See Spencer Stuart, 2017 WL

4570791, at *1; MJD Constr., 293 A.D.2d at 517; Rosenberg, 160 A.D.2d at 329.

23. Attached hereto as Exhibit T is a true and correct copy of the proposed Notice of

Class Action Lawsuit Settlement and Fairness Hearing in the Public Kitchen Class Action. (Doc.

No. ). On behalf of ADP, I respectfully request that the Court take judicial notice of this

publicly-filed document. See Spencer Stuart, 2017 WL 4570791, at *1; MJD Constr., 293

A.D.2d at 517; Rosenberg, 160 A.D.2d at 329.

24. Attached hereto as Exhibit U is a true and correct copy of the November 26, 2018

order granting preliminary approval of the settlement in the Public Kitchen Class Action. (Doc.

No. 10). On behalf of ADP, I respectfully request that the Court take judicial notice of this

publicly-filed document. See Spencer Stuart, 2017 WL 4570791, at *1; MJD Constr., 293

A.D.2d at 517; Rosenberg, 160 A.D.2d at 329.

25. Attached collectively hereto as Exhibit V are true and correct copies of the

unopposed motion for final approval of the settlement in the Public Kitchen Class Action with

supporting affirmation. (Doc. Nos. 12 and 13). On behalf of ADP, I respectfully request that the

Court take judicial notice of these publicly-filed documents. See Spencer Stuart, 2017 WL

4570791, at *1; MJD Constr., 293 A.D.2d at 517; Rosenberg, 160 A.D.2d at 329.

26. Attached hereto as Exhibit W is a true and correct copy of the March 26, 2019

order granting final approval of the settlement in the Public Kitchen Class Action. (Doc. No.

21). On behalf of ADP, I respectfully request that the Court take judicial notice of this publicly-

filed document. See Spencer Stuart, 2017 WL 4570791, at *1; MJD Constr., 293 A.D.2d at 517;

Rosenberg, 160 A.D.2d at 329.

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27. Attached hereto as Exhibit X is a true and correct copy of a January 25, 2019

letter from Fitapelli & Schaffer to Public Hotel c/o Fox Rothschild concerning claims related to

employees assigned to certain food and beverage venues in the Public Hotel other than Public

Kitchen, including The Roof, Public Arts, Public Diego, Public Lobby and Lobby Bar, and

Public Louis. IS Chrystie produced this document during discovery in this case.

28. Attached hereto as Exhibit Y is a true and correct copy of the April 10, 2019

tolling agreement executed by Fitapelli & Schaffer and Fox Rothschild concerning the claims

identified in Fitapelli & Schaffer’s letter of January 25, 2019. IS Chrystie produced this

document during discovery in this case.

29. IS Chrystie commenced this action on October 29, 2018.

30. The Amended Complaint in this action is focused on ADP's services with respect

to IS Chrystie employees assigned to Public Kitchen.

31. Public Kitchen is referenced in the Amended Complaint fifty-five times.

32. Public Hotel is referenced in the Amended Complaint once in describing the

physical location of Public Kitchen.

33. The Roof, Public Arts, Public Diego, Public Lobby and Lobby Bar, and Public

Louis are not referenced in the Amended Complaint.

34. The Amended Complaint was filed nearly three months before Public Hotel’s

receipt of Fitapelli & Schaffer’s letter of January 25, 2019 relating to tipped employees at The

Roof, Public Arts, Public Diego, Public Lobby and Lobby Bar, and Public Louis.

35. IS Chrystie has neither sought nor obtained leave to amend or supplement the

Amended Complaint.

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36. Attached hereto as Exhibit Z is a true and correct copy of the transcript of the

deposition of Scott Englund of New York Hospitality LLC (“New York Hospitality”) in this

action.

37. In response to an amended deposition subpoena ADP served on New York

Hospitality, New York Hospitality produced Mr. Englund as its corporate representative

designated to testify on its behalf pursuant to Commercial Division Rule 11-f. Attached hereto

as Exhibit AA is a true and correct copy of ADP’s amended deposition subpoena served on New

York Hospitality.

38. Mr. Englund was designated to testify concerning, among other things, the

services New York Hospitality provided with respect to Public Hotel.

Dated: New York, New York
June 4, 2021 Randall L. Morrison, Jr.

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INDEX TO EXHIBITS

Exhibit A: Amended Complaint
Exhibit B: Transcript of the Deposition of Joan (O’Connor) Farooqi
Exhibit C: IS Chrystie’s Objections and Responses to
ADP’s Second Set of Interrogatories
Exhibit D: ADP’s Commercial Division Rule 11-f
Deposition Notice to IS Chrystie
Exhibit E: ADP’s Amended Commercial Division Rule 11-f
Deposition Notice to IS Chrystie
Exhibit F: IS Chrystie’s Responses and Objections to ADP’s Amended
Commercial Division Rule 11-f Deposition Notice
Exhibit G: Excerpts from the website of Ian Schrager Company
Exhibit H: Excerpts from the website of Public Hotel as of May 24, 2021
Exhibit I June 1, 2021 New York Times article headlined “Star Chef From Peru to
Head Public Hotel Restaurants”
Exhibit J: Excerpts from the website of Public Hotel as of June 4, 2021
Exhibit K Master Services Agreement between ADP and IS Chrystie
Exhibit L: Letter of December 19, 2017 from Fitapelli & Schaffer to Public Kitchen
Exhibit M: ADP’s First Set of Requests for Admission to ISC
Exhibit N: IS Chrystie’s Responses and Objections to
ADP’s First Set of Requests for Admission
Exhibit O: Tolling Agreement dated January 10, 2018 between Fitapelli & Schaffer
and Fox Rothschild in the Public Kitchen Class Action
Exhibit P: Memorandum of Understanding between Fitapelli & Schaffer and
Fox Rothschild in the Public Kitchen Class Action
Exhibit Q: Settlement Agreement and Release dated April 30, 2018 in the
Public Kitchen Class Action
Exhibit R: Class Action Complaint in the Public Kitchen Class Action
Exhibit S: Unopposed motion (with supporting brief) for preliminary approval of
the Public Kitchen Class Action settlement
Exhibit T: Proposed Notice of Class Action Lawsuit Settlement
and Fairness Hearing in the Public Kitchen Class Action
Exhibit U: November 26, 2018 order granting preliminary approval to the
Public Kitchen Class Action settlement
Exhibit V: Unopposed motion (with supporting brief) for final approval of the
Public Kitchen Class Action settlement

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Exhibit W: March 26, 2019 order granting final approval of the
Public Kitchen Class Action settlement
Exhibit X: Letter of January 25, 2019 from Fitapelli & Schaffer to Public Hotel
Exhibit Y: Tolling Agreement dated April 10, 2019 between Fitapelli & Schaffer
and Fox Rothschild re Public Hotel
Exhibit Z: Transcript of the Deposition of Scott Englund
Exhibit AA: ADP’s Amended Deposition Subpoena to New York Hospitality LLC

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EXHIBIT A
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
------------------------------------------------------------------------X
:
IS CHRYSTIE MANAGEMENT LLC, DEVENWOOD : Index No. 655374/2018
CORPORATION LLC and DEVONWOOD :
CORPORATION, LLC, :
:
Plaintiffs, :
: AMENDED
-against- : COMPLAINT
:
ADP, LLC :
:
Defendant. :
:
------------------------------------------------------------------------X

Plaintiffs IS Chrystie Management LLC (“IS Chrystie”) and Devonwood Corporation,

LLC (“Devonwood,” together with IS Chrystie, “Plaintiffs”), by and through their undersigned

counsel, Morrison Cohen LLP, as and for their Amended Complaint against Defendant ADP,

LLC (“Defendant” or “ADP”), allege as follows:

INTRODUCTION

1. Plaintiff Devonwood operates and controls the popular, upscale restaurant

Public Kitchen. Public Kitchen, known for its innovative cuisine prepared by a world-renowned

chef, employs dozens of tipped employees such as servers, bartenders and the like. Plaintiff IS

Chrystie, in its role as Public Kitchen’s manager, enters into service contracts on behalf of Public

Kitchen to ensure that Public Kitchen’s essential services are met, including those provided to its

employees.

2. In 2016, IS Chrystie entered into an agreement for ADP to provide critical

payroll services for Public Kitchen’s employees. Pursuant to the agreement, ADP was to, among

other things, process the payroll for Public Kitchen’s employees, deliver pay checks and related

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reports to Public Kitchen and design a system to carry out those payroll services in compliance

with applicable legal and regulatory requirements.

3. At the time it entered into the agreement, ADP not only represented that it

would provide payroll services of the highest quality, but specifically contracted to “be

responsible for the accuracy of” the services to “assist [Public Kitchen] in complying with its

legal and regulatory requirements.” Contrary to its representations, the payroll services provided

by ADP were designed in an improper and haphazard manner, with a reckless and wanton

disregard for the effect on Public Kitchen and its employees and otherwise failed to assist Public

Kitchen in complying with existing law. Among other things, ADP failed to properly process

the payroll of Public Kitchen’s employees and ultimately provided pay checks that failed to

include information required under New York law.

4. As a result of ADP’s willful and reckless failure to perform the payroll

services in conformance with applicable law, Plaintiffs are facing significant liability—all of

which arise out of payroll statements improperly prepared and processed by ADP.

5. Plaintiffs have reached out to ADP on numerous occasions seeking

recompense for ADP’s failure to live up to its representations and to provide the contracted

services in a reasonable manner, to no avail. ADP has both refused to return the money it was

paid for its services and to indemnify Plaintiffs for the harm caused by ADP’s willful and

reckless failure to perform the payroll services. As such, Plaintiffs are now compelled to bring

this lawsuit.

6. Upon information and belief, ADP’s willful failure to perform payroll

services in conformance with applicable law is part of a pattern with respect to ADP’s treatment

of its customers that has required other ADP customers and/or their employees to sue ADP.

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Plaintiffs have now been forced to join that line of ADP customers who have been wronged by

ADP’s reckless, grossly negligent service. Plaintiffs should be compensated for ADP’s

misconduct.

PARTIES

7. IS Chrystie is a Delaware limited liability company with its principal place

of business located at 215 Chrystie Street, New York, New York 10002.

8. Devonwood is a Delaware limited liability company with its principal

place of business located at 215 Chrystie Street, New York, New York 10002.

9. Defendant is a Delaware limited liability company with its principal place

of business located at One ADP Boulevard, Roseland, New Jersey 07068.

JURISDICTION AND VENUE

10. Jurisdiction is proper in this Court under New York Civil Practice Law

and Rules (“CPLR”) Sections 301 and 302 because Plaintiff is located and transacts business in

New York, and Defendant transacts business and supplies services in New York and has

committed a tortious act within New York.

11. Venue is proper in New York County pursuant to CPLR Section 503

because Plaintiff’s principal place of business is located in New York County.

FACTUAL ALLEGATIONS

Background of Public Kitchen

12. Public Kitchen is a restaurant located in lower Manhattan that opened in or

about June 2017.

13. Public Kitchen is a world-renowned restaurant, located within New York’s

Public Hotel. Its menu focuses on sustainable seafood, organic poultry and grass-fed meats, as

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well as the use of fresh and organic fruits and vegetables.

14. As is typical for an upscale restaurant, Public Kitchen’s management

employs numerous staff including servers, server assistants, food runners, bartenders, barbacks

and other tipped employees.

15. In order to make sure each of Public Kitchen’s employees would be

properly compensated in full compliance with all applicable federal and state laws, Plaintiffs

began the search for a company to provide payroll processing services for their employees even

before the restaurant’s doors opened.

16. In or about early 2016, Public Kitchen entered into discussions with ADP,

Case Info

Judge

Barry R. Ostrager Track Judge’s New Case

Case No.

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Document Filed Date

October 22, 2021

Case Filing Date

October 29, 2018

County

Parties

ADP, LLC Defendant
DEVONWOOD CORPORATION, LLC Plaintiff
EZCURRA, JOAQUIN J Attorney
EZCURRA, JOAQUIN J Attorney for the Plaintiff
GYVES, WILLIAM S Attorney for the Defendant
IS CHRYSTIE MANAGEMENT LLC Plaintiff
KAMELHAR, JOSEPH JUSTIN Attorney for the Plaintiff
MORRISON, RANDALL L Attorney for the Defendant
New York Hospitality, LLC Non Party
SCHARF, YEHUDA D Attorney for the Plaintiff
THOMPSON, LATISHA V Attorney for the Plaintiff
WARD, ROBERT NICHOLAS Attorney for the Defendant
WILL, AMBER RAE Attorney for the Plaintiff
ALEXANDER LEONARD Attorneys for Defendants
CAROLYN RICHMOND Attorney
ROBERT KRAUS Attorney
DESIREE GUSTAFSON Attorney
BRIAN SCHAFFER Attorney
SUSAN GYVES Attorney
JOEL TENNENBERG Attorney
William Shapiro Attorney
DANIEL KIRSCHENBAUM Attorneys for Plaintiffs
JOSHUA ANDROPHY Attorneys for Plaintiffs
LATISHA THOMPSON Attorney
LAUREN MORRISON Attorney
DALE CENDALI Attorneys for Defendants
LARA MORRISON Attorney
MATTHEW NUNEZ Attorneys for Defendants

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Exhibit,Appendix: Is Chrystie Management Llc, Devonwood Corporation, Llc v. Adp, Llc

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