Motion to Dismiss in Nefail Ljubanovic, Jairo Dodic v. Wolfgang'S Steakhouse Inc., Wolf Eastside Llc D/B/A Wolfgang'S Steakhouse, Zmf Restaurants Llc D/B/A Wolfgang'S Steakhouse At Park Avenue, Wolf Gotham Llc D/B/A Wolfgang'S Steakhouse - Gotham Hotel, Wolf On Broadway Llc D/B/A Wolfgang'S Steakhouse, Wolf At Tribeca Inc. D/B/A Wolfgang'S Steakhouse Tribeca, Peter Zweiner, Wolfgang Zweiner, Zizo Doe, Aramo Doe, John Does 1-10| Trellis.Law

On February 22, 2019 a Motion-Secondary was filed involving a dispute between Jairo Dodic, Nefail Ljubanovic, and Aramo Doe, John Does 1-10, Peter Zweiner, Wolf At Tribeca Inc. D B A Wolfgang'S Steakhouse Tribeca, Wolf Eastside Llc D B A Wolfgang'S Steakhouse, Wolfgang'S Steakhouse Inc., Wolfgang Zweiner, Wolf Gotham Llc D B A Wolfgang'S Steakhouse - Gotham Hotel, Wolf On Broadway Llc D B A Wolfgang'S Steakhouse, Zizo Doe, Zmf Restaurants Llc D B A Wolfgang'S Steakhouse At Park Avenue, for Torts - Other (wage and hour claims) in the District Court of New York County.

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INDEX NO. 151956/2019

SUPREME COURT OF NEW YORK
COUNTY OF NEW YORK

NEFAIL LJUBANOVIC and JAIRO DODIC,
on behalf of himself and the Class,

Plaintiffs,
-against-

WOLFGANG'S STEAKHOUSE INC., WOLF EASTSIDE

LLC, d/b/a WOLFGANG'S STEAKHOUSE, ZMF
RESTAURANTS LLC, d/b/a WOLFGANG'S
STEAKHOUSE AT PARK AVENUE, WOLF GOTHAM
d/b/a WOLFGANG'S STEAKHOUSE - GOTHAM
LLC,
HOTEL, WOLF ON BROADWAY LLC, d/b/a
WOLFGANG'S STEAKHOUSE, WOLF AT TRIBECA

INC., d/b/a WOLFGANG'S STEAKHOUSE TRIBECA,
PETER ZWEINER, WOLFGANG ZWEINER, ZIZO DOE
(last name unknown), ARAMO DOE (last name unknown),
JOHN DOES 1-10.,

Defendants.

MEMORANDUM OF LAW IN SUPPORT
DEFENDANTS'
OF MOTION TO DISMISS
THE COMPLAINT PURSUANT TO CPLR

§ 3211(a)(4) AND/OR FOR A STAY
PURSUANTTO CPLR§§3211
AND/OR 2201.

MELTZER, LIPPE, GOLDSTEIN
& BREITSTONE, LLP
Attorneys for the Defendants
190 Willis Avenue

Mineola, N.Y. 11501

(516) 747-0300

Gerald C. Waters, Jr.,Esq.

Dong Phuong V. Nguyen, Esq.

Larry R. Martinez, Esq.

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Table of Contents

Page

Table of Authorities ii
........................................................................................................................

I. PRELIMINARY STATEMENT .........................................................................................1

II. RELEVANT FACTUAL ALLEGATIONS AND PROCEDURAL POSTURE .................3

A. The Federal Action ..............................................................................................................3

B. The State Action ..................................................................................................................5

C. The Federal and State Actions Allege Similar Facts and Wage-and-
Substantively
Hour Violation Predicates....................................................................................................7

III. ARGUMENT.......................................................................................................................8

A. The Court Should Dismiss the Present Action Pursuant to CPLR §

3211(a)(4) ............................. ........................................................................8

i. There is Substantial Identity Between the Parties........................................9

ii. The Two Actions are Sufficiently Similar.................................................10

iii. The Interests of Judicial Economy, Comity and Basic Fairness

Mandate Dismissal.....................................................................................11

B. Absent Dismissal, The Court Should Stay the Present Action

Pursuant to CPLR §§ 3211(a)(4) and/or 2201 .......................................................14

i. Absent Dismissal, This Matter Should be Stayed Pending Final

Resolution of the Federal Action...............................................................15

CONCLUSION..............................................................................................................................17

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TABLE OF AUTHORITIES

Cases

ACE Fire Underwriters Ins. Co. v. ITT Indus.,
2006 WL 3849060 (Sup. Ct. N.Y. Cnty. 2006)..........................................................................
8

Asher v. Abbott Labs.,
307 A.D.2d 211 (1st Dept. 15
2003)..................................................................................
13, 14,

Bridas Intern S.A. v. Repsol S.A.,
975 N.Y.S.2d 708 (Sup. Ct. N.Y. Cnty. 8
2013)...........................................................................

Britt v. Int'I Bus. Servs., Inc.,
255 A.D.2d 143 (1st Dept. 14
1998)..............................................................................................

Chan v. Zoullas,
943 N.Y.S.2d 790 (Sup. Ct. N.Y. Cnty. 2012).........................................................................
16

Cherico, Cherico & Assocs. v. Midollo,
67 A.D.3d 622 (2d Dept. 2009)................................................................................................
11

DaSilva v. Musso,
76 N.Y.2d 436 14
(1990)...............................................................................................................

Delijanin v. Wolfgang's Steakhouse Inc.,
2019 WL 1760154 (S.D.N.Y. Apr. 22, 2019).........................................................................
2, 5

H.M. Hamilton & Co. v. American Home Assur. Co.,
21 A.D.2d 500 (1st Dept. 9
1964)..............................................................................................
8,

Liker v. Grossman,
175 A.D.2d 911 (2d Dept. 1991)..............................................................................................
13

Nat'l Union Fire Ins. Co. of Pittsburgh, PA v. Jordache Enters., Inc.,
205 A.D.2d 342 (1st Dept. 8
1994)................................................................................................

OneBeacon Am. Ins. Co. v. Colgate-Palmolive Co.,
96 A.D.3d 541 (1st Dept. 14
2012)................................................................................................

Procter & Gamble Distrib. Co. v. Lloyd's Underwriters,
255 N.Y.S.2d 361 (Sup. Ct. N.Y. Cnty. 1964).........................................................................
16

USDOL Opinion Letter,
2018 WL 5921455 12
....................................................................................................................

..
11

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Syncora Guar. Inc. v. J.P. Morgan Sec., LLC,
110 A.D.3d 87 (1st Dept. 2013)......................................................................................
9, 10, 11

White Light Prods., Inc. v. On the Scene Prods., Inc.,
231 A.D.2d 90 (1st Dept. 1997)........................................................................................
8, 9, 11

Rules

CPLR § 901..... ..................................................................................................................
4
CPLR § 2201.........................................................................................................................
1, 3, 14
CPLR § 3211(a)(4) ................................................................................................................
passim
Federal Rule of Civil Procedure 23 ........................................................................................
2, 3, 4

...
111

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I. PRELIMINARY STATEMENT

Defendants, Wolfgang's Steakhouse Inc., Wolf Eastside LLC, d/b/a Wolfgang's

Steakhouse, ZMF Restaurants LLC, d/b/a Wolfgang's Steakhouse At Park Avenue, Wolf

Gotham d/b/a Wolfgang's Steakhouse - Gotham Wolf On d/b/a
LLC, Hotel, Broadway LLC,

Wolfgang's Steakhouse, Wolf At Tribeca Inc., d/b/a Wolfgang's Steakhouse Tribeca

(collectively as "the entity Defendants"), Peter Zweiner, and Wolfgang Zweiner (collectively

"Defendants"),l
with the entity Defendants, where appropriate as, submit this Memorandum of

Law in support of their Motion to Dismiss Plaintiffs, Nefail Ljubanovic and Jairo Dodic,

(collectively as "Plaintiffs")'s Complaint (the "State Action") pursuant to New York Civil

Practice Laws and Rules ("CPLR") § 3211(a)(4) or, in the alternative, to stay these proceedings

pursuant to CPLR §§ 3211 and/or 2201 (the "Motion").

The basis for the Motion is Plaintiffs and their counsel have an earlier-filed, substantially

identical class-and-collective action currently pending in the Southern District of New York

styled Elvir Delijanin v. Wolfgang's Steakhouse Inc., et al., Docket No. 18-cv-07854 (RA)

Action.2
(KHP) (the "Federal Action") against the same Defendants as in the State In the

Federal plaintiff alleged identical New York Labor Law wage-
Action, substantively ("NYLL")

and hour class claims, namely overtime, minimum wage, spread of hours, and wage notice and

violations.3
wage statement

Our officedoes not represent Zizo Doe, Aramo Doe, or John Does 1-10.

2
A copy of the Complaint filed in the StateAction on February 22, 2019 isannexed to the Declaration of Dong
A."
Phuong V. Nguyen, Esq. dated June 17, 2019 (the"Nguyen Decl."), as "Exhibit A copy ofthe Complaint filed
B."
in theFederal Action on August 28, 2018 is annexed to the Nguyen Decl. as "Exhibit

3
Both the Federal and StateActions are filedon behalf of a proposed class comprised of allnon-exempt tipped
employees for allfive entity Defendants. In doing so, plaintiff
alleged in both the Federal and State Actions, that
Defendants: (1) failedto provide proper tip creditnotices; (2) claimed an improper tip credit based on requiring
employees to perform non-tipped duties during more than twenty percent oftheir work hours; (3) illegallyretained

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In addition to the duplicative nature of the claims, Plaintiff also seeks the same discovery

in the State Action. Specifically, in preparation for his anticipated motion to certify a class

pursuant to Federal Rule of Civil Procedure ("FRCP") 23, Plaintiff sought and received

class-action.4
discovery regarding the viability of a NYLL As directed by the court, the federal

defendants produced records, including payroll, time, and tip records, for allnon-exempt tipped

employees at the Midtown East Wolfgang's Steakhouse, located at 200 East 54th Street, New

York, New York 10022, for the entire six year period under the NYLL. Thus, as will be detailed

Plaintiffs'
below, State Action seeks the same relief sought in the Federal Action; asserts the

same state law causes of action alleged in the Federal Action; asserts substantively identical

factual predicates as the basis for said causes of action; will require the same discovery as that

previously sought and received in the Federal Action; and seeks to certify a substantively

identical class-action as the one sought in the Federal Action.

Moreover, Plaintiffs filed the State Action to forum shop. Plaintiffs filed the instant

action with the clear intent to avoid unfavorable rulings in the Federal Action and bypass the

United States Department of Labor's ("USDOL") recently revised position on whether an

credit"
employer can avail themselves of the "tip when tipped employees perform a certain

work" Plaintiffs' "80/20"
amount of "side (effectively eliminating claim).

gratuities;(4)failed toprovide proper wage statements to indicatetipcredits;and (5) failed to accuratelykeep track
of dailytips.See generallyExhibits A and B to Nguyen Decl.

4
In the federal matter, the court actually denied plaintiff's
motion to conditionally certifyall five named entity
defendants (same entityDefendants as inthe instantmatter) and instead granted conditionalcertificationfor justthe
Midtown East Wolfgang's Steakhouse, located at 200 East 54th Street, New York, New York 10022 ("Midtown

East") only. In doing so, the court rejected plaintiff'sargument that the entity defendants were part of a single
integrated enterprise. Specifically,the court found "there is insufficientproof at thispoint forthe Court to make
determination"
such a and "the other Wolfgang locations [referringto allentity defendants except the Midtown East
entities." WL
location] allappear to be separate corporate Delilâñiñ v. Wolfgang's Steakhouse Inc.,2019 1760154,
at *7 (S.D.N.Y. Apr. 22,2019). For convenience ofthe Court, a copy of the April 22,2019 Order isattached hereto
as Exhibit C to theNguyen Decl.

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Plaintiffs and their counsel bring this duplicative action solely for the purpose of hedging

their chances to procure a favorable ruling in the event the Delijanin federal court denies their

anticipated motion to certify a class under FRCP 23. As such, the purpose of the State Action si

to undermine a potential ruling in an earlier-filed case in violation of the rules of comity.

Accordingly, Defendants respectfully request this Court dismiss the State Action in its entirety

pursuant to CPLR § 3211. Alternatively, and to the extent the State Action is not dismissed in its

entirety, Defendants respectfully request it be stayed pursuant to CPLR § 2201 until final

resolution of the Federal Action is effectuated, in the interests of judicial economy.

IL RELEVANT FACTUAL ALLEGATIONS AND PROCEDURAL POSTURE

A. The Federal Action

On August 28, 2018, Elvir Delijanin, through his counsel, Lee Litigation Group, PLLC,

commenced a putative class-and-collective action in the Southern District of New York on

behalf of himself and all other current and former non-exempt tipped employees, including

bussers, servers, runners, bartenders, and barbacks, employed by Defendants. See Nguyen Decl.,

Exhibit B ("Federal Complaint".) Relevantly, plaintiff Delijanin alleged that individual

defendants, Peter Zweiner, Wolfgang Zweiner, Zizo Doe, and Aramo Doe, were each an

"owner" "employer"
of the entity Defendants and could be considered Delijanin's sufficient to

Defendants'
hold them liable for purported wage-and-hour violations. See id. at ¶ 8. Plaintiff

Delijanin filed the putative class action on behalf of the same putative class against the same five

entity defendants as here. See id. at ¶ 7.

In connection with same, the Federal Action alleges several causes of action. First, it

alleges a claim for minimum wage, overtime violations (including unpaid off-the-clock work),

and improper tip credit under the FLSA (including performing non-tipped activities in excess of

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twenty percent of the workday). See id. at ¶¶ 13, 26, 27, 30. More pertinently, the remaining

claims were brought pursuant to New York state law, alleging:

1. Minimum wage, overtime, spread of hours, and wage notice and wage statement

violations under the NYLL and/or the Wage Theft Prevention Act ("WTPA");
2. Unpaid off-the-clock work;
3. Failure to provide proper tip credit;
4. Failure to accurately track daily tips earned or maintain records thereof; and

5. Improper tip credit on the basis of causing tipped employees to engage in non-tipped

duties for hours exceeding 20% of the total hours worked each workweek ("80/20

claim").

See id. at ¶¶ 18, 26, 27, 30.

As of the time of this submission, the parties in the Federal Action are currently engaged

in discovery for members of the putative class of all non-exempt tipped employees from August

28, 2012 to present, including the exchange of approximately one thousand pages of

documentation thus far. See Nguyen Decl., ¶ 9. On March 18, 2019, prior to moving to certify a

class pursuant to FRCP 23 or CPLR § 901, plaintiff moved to compel class discovery, including

payroll and time records for all non-exempt tipped employees at all five entity defendants for the

62.5
entire NYLL period. Nguyen Decl., Exhibit D, ECF No. On April 8, 2019, the court denied

plaintiff's motion and instead, directed Defendants to produce records for all non-exempt tipped

employees for just the Midtown East location for the entire NYLL period, including, inter alia,

payroll records, employee handbooks, tip and pay policies, Wage Theft Protection Act notices,

signed tip allowance and tip notice forms, and documents to identify managers and owners.

6.6
Nguyen Decl., Exhibit E, ECF No. 64, p.

5
A copy of the Federal Action Docket is attachedhereto as Exhibit D to the Nguyen Decl. Entries therein are noted
__"
as "ECF No. toreference theirdocket entrynumber.

6
A copy of theApril 8, 2019 Order isattached hereto as Exhibit E to theNguyen Decl.

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On November 27, 2018, the Delijanin plaintiff moved for conditional certification in the

Federal Action. Nguyen Decl., Exhibit E, ECF No. 35. On April 22, 2019, the court issued its

decision, wherein it granted conditional certification of the Midtown East location only and

denied certification of all five entity defendants, without prejudice, on the basis "the other

entities."
Wolfgang locations all appear to be separate corporate Delijanin, 2019 WL 1760154 at

*7.7
As stated above, as of the time of this submission, the Federal Action defendants are

currently in the process of exchanging the above enumerated documents for the entire putative

class at the Midtown East location. See Nguyen Decl., ¶ 9. Moreover, plaintiff's counsel (same

counsel as in the State Action) has repeatedly represented they plan to again move to

conditionally certify all five entity defendants in addition to moving to certify the class, and have

in fact, produced at least two declarations in alleged support of same. To that end, the federal

court has directed the parties to engage in settlement discussions on a class basis.

B. The State Action

Notwithstanding the foregoing, on or about February 22, 2019, Plaintiffs, Ljubanovic and

Dodic, through their counsel, Lee Litigation Group, PLLC (same counsel as the Federal Action),

commenced this putative-class-action in the Supreme Court of the State of New York, County of

New York on behalf of themselves and all other current and former non-exempt tipped

employees, including servers, waiters, runners, and bussers. See Nguyen Decl., Exhibit A

("State Complaint").

As in the Federal Complaint, Plaintiffs again alleged the same individual defendants,

"owner"
Peter Zweiner, Wolfgang Zweiner, Zizo Doe, and Aramo Doe, were each an of the

Plaintiffs' "employer"
entity Defendants and could be considered sufficient to hold them liable

Defendants'
for purported wage-and-hour violation. State Complaint, ¶ 8. Additionally,

See Exhibit C to Nguyen Decl.

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Plaintiffs filed the putative class action against the same five entity defendants on behalf of the

same putative class as in the Federal Action. In doing so, the state complaint even included

support"
identical exhibits "in of the complaint, including plaintiff Delijanin's paystub. S_ee State

Complaint, p. 22-37.

The identical nature of the wages claims in the Federal and State Actions are readily

apparent when directly compared in the below chart:

Claims The Federal Action The State Action

Overtime

Minimum Wage

Spread of Hours

Wage Notice

Wage Statement

Failure to provide proper tip
credit

Failure to maintain tip records

80/20 claim

27.8
Compare Federal Complaint, ¶¶ 18, 26, 27, 30 with State Complaint, ¶¶ 11, 24, 26,

8
The State Complaiñt includes allegations of discrimination and hostile work environment on behalf of Plaintiff
Ljübâñ0vic only under the New York State Human Rights Law and New York City Human Rights Law. See State
Complaiñt, ¶¶ 30-38, 47-60.

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C. The Federal and State Actions Allege Similar Facts and Wage-and-
Substantively
Hour Violation Predicates

In addition to concerning the same parties, same causes of actions, and substantively

similar claims for relief noted above, both the Federal and State Complaints alleged substantively

identical facts and asserted substantively identical predicates for certification of a class action.

For instance, the pertinent Complaints both alleged that Delijanin and Plaintiffs: (i) were

employed by Defendants as non-exempt tipped employees9; (ii) did not receive at least the

minimum wage for all hours worked 0; (iii) did not receive proper wage notices and wage

notice;¹2
statements ; (iv) were not provided proper tip (v) spent more than 20% of the total

hours worked performing "non-tipped duties"13; and (vi) failed to accurately record daily tips

eamed.14

Additionally, the Complaints also asserted substantively identical "questions of law and

Class"
fact common to the in seeking certification of a class-action, namely whether Defendants:

(i) employed the putative class members under the NYLL; (ii) employed the same "policies,

plan"
practices, programs, procedures, protocols and regarding the putative class members; (iii)

correctly utilized the proper hourly rate to compensate the putative class members; (iv) paid the

putative class members the proper NYLL minimum wage for all hours worked; (v) provided

proper notice to the putative class regarding use of a tip credit; (vi) provided proper wage

9
Compare Federal Complaint, ¶ 15; with State Complaint, ¶¶ 8, 18, 22.

Compare Federal Complaint, ¶¶ 18, 28; with State Complaint, ¶¶ 11, 27. .

Compare Federal Complaint, ¶¶ 35, 36; w_ithStateComplaint, ¶¶ 11, 26,29.

2
Compare Federal Complaint, ¶¶ 18, 30; with State Complaint, ¶¶ 11, 24.

Compare Federal Complaint, ¶¶ 18, 26; witl1StateComplaint, ¶¶ 11, 19,23.

Compare Federal Complaint, ¶¶ 18, 30; with State Complaint, ¶ 11.

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credit.is
statements; and (vii) took the proper amount of tip In sum, the State Action is brought

by essentially the same plaintiff(s), uses the exact same counsel, is alleged against the same

defendants, pursues the same causes of action, seeks certification of the same class action, and

attempts to recover the same relief (i.a, the same wages allegedly due under the same regulations

for the same work performed).

HL ARGUMENT

A. The Court Should Dismiss the Present Action Pursuant to CPLR §3211(a)(4)

The CPLR provides a party may move for judgment dismissing one or more causes of

action asserted against them on the ground that "there is another action pending between the

States."
same parties for the same cause of action in a court of any state or the United C.P.L.R. §

3211(a)(4).16
This provision "codifies the procedure by which the court considers whether, in

the interest of comity and judicial economy, it should dismiss a later-filed suit in favor of an

earlier action pending in another forum, to avoid vexatious litigation and duplication of effort,

issues."
and the attendant risk of divergent rulings on similar ACE Fire Underwriters Ins. Co. v.

ITT Indus., 2006 WL 3849060 (Sup. Ct. N.Y. Cnty. 2006), aff'd, 44 A.D.3d 404 (1st Dept.

2007) (citing White Light Prods., Inc. v. On the Scene Prods., Inc., 231 A.D.2d 90, 96 (1st Dept.

1997)).

"first-in-time"
The other-action-pending doctrine follows the rule. Nat'l Union Fire Ins.

Co. of Pittsburgh, PA v. Jordache Enters., Inc., 205 A.D.2d 342, 343 (1st Dept. 1994). Such rule

provides that "the court which has firsttaken jurisdiction is the one in which the matter should be

interfere."
determined and it is a violation of the rules of comity to H.M. Hamilton & Co. v.

15
Compare Federal Complaint, ¶ 23; with State Complaint, ¶ 14.

Defendants respectfully note the standardon determining a Motion to Dismiss pursuant toCPLR § 3211(a)(4) "is
conveniens,"
similarto that undertaken in applying the doctrine of forum non and thus this Court is not limitedto
matters and/or factual allegations presented solely within the operative coniplaint. Bridas Intern S.A. v. Repsol
S.A.,975 N.Y.S.2d 708, *3 (Sup. Ct.N.Y. Cnty. 2013) (emphasis in (citations
original) omitted).

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American Home Assur. Co., 21 A.D.2d 500, 506 (1st Dept. 1964). For the rule to apply, there

identity"
must be "substantial between the parties and the "relief sought must be 'the same or

same.'"
substantially the White Light Prods., 231 A.D.2d at 93-94. Here, both factors are

indisputably present.

i. There is Substantial Identity Between the Parties

Dismissal of the later-filed suit under CPLR § 3211(a)(4) requires only that there be

substantial - not complete - of the parties. Id. "The presence of additional parties . ..
identity

will not necessarily defeat a motion pursuant to CPLR § 3211(a)(4) where, as here, 'both suits

wrongs.'"
arise out of the same subject matter or series of alleged Id. Moreover, substantial

identity can be present even when there is no common defendant present. See Syncora Guar. Inc.

v. J.P. Morgan Sec.. LLC, 110 A.D.3d 87, 96 (1st Dept. 2013) (emphasis supplied). Here, there

are at least seven common defendants. See eenerally Federal and State Complaints.

As noted above, Plaintiffs in the State Action, similar to plaintiff in the Federal Action,

worked as non-exempt tipped employees and purport to bring this matter on behalf of themselves

and the putative class, as defined "all non-exempt, tipped employees, including servers, waiters,

Defendants"
runners, and bussers, who were employed by during the six years preceding the

Complaint. State Complaint, ¶ 8; Federal Complaint, ¶ 15. Plaintiffs filed the state Complaint on

February 22, 2019, see eenerally State Complaint, and thus, the NYLL period would date back to

February 22, 2013. In the Federal Action, plaintiff filed the co

Case Info

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Shlomo Hagler Track Judge’s New Case

Case No.

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Document Filed Date

June 17, 2019

Case Filing Date

February 22, 2019

County

Parties

Aramo Doe Defendant
BROWN, WILLIAM MICHAEL Attorney for the Plaintiff
FARRELL, JONATHAN DANIEL Attorney for the Defendants
GREEN, SCOTT RICHARD Attorney for the Defendants
Jairo Dodic Plaintiff
John Does 1-10 Defendant
LEE, C K. Attorney for the Plaintiff
MARTINEZ, LARRY RAFAEL Attorney for the Defendants
Nefail Ljubanovic Plaintiff
Peter Zweiner Defendant
WATERS, GERALD CHARLES Attorney for the Defendants
Wolf At Tribeca Inc. d/b/a Wolfgang's Steakhouse Tribeca Defendant
Wolf Eastside LLC d/b/a Wolfgang's Steakhouse Defendant
Wolfgang's Steakhouse Inc. Defendant
Wolfgang Zweiner Defendant
Wolf Gotham LLC d/b/a Wolfgang's Steakhouse - Gotham Hotel Defendant
Wolf On Broadway LLC d/b/a Wolfgang's Steakhouse Defendant
Zizo Doe Defendant
ZMF Restaurants LLC d/b/a Wolfgang's Steakhouse At Park Avenue Defendant
K. LEE Attorney

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