Daryl Stephen v. Public Partnerships LLC

CourtDistrict Court, E.D. New York
DecidedJanuary 22, 2026
Docket1:25-cv-03895
StatusUnknown

This text of Daryl Stephen v. Public Partnerships LLC (Daryl Stephen v. Public Partnerships LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daryl Stephen v. Public Partnerships LLC, (E.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

DARYL STEPHEN,

Plaintiff, MEMORANDUM AND ORDER -against- 25-CV-3895 (NRM) (LKE) PUBLIC PARTNERSHIPS LLC,

Defendant.

NINA R. MORRISON, United States District Judge: Plaintiff Daryl Stephen, proceeding pro se, seeks a preliminary injunction in this action against his current employer, Public Partnership LLC. For the reasons discussed below, the motion for a preliminary injunction is DENIED. BACKGROUND Plaintiff Daryl Stephen brings this action against his employer, Public Partnerships LLC (“PPL”). PPL is a fiscal intermediary for the Consumer Directed Personal Assistance Program (“CDPAP”), a New York Medicaid program that allows family members to serve as in-home caregivers. Am. Compl. ¶¶ 9–10, ECF No. 13.1

1 The New York State Department of Health website explains that the Consumer Directed Personal Assistance Program “allows Medicaid members who are eligible for home care services to choose and hire their own personal caregiver, or ‘personal assistant.’” Consumer Directed Personal Assistance Program (CDPAP), N.Y. Dep’t of Health, available at https://www.health.ny.gov/health_care/medicaid/ program/longterm/cdpap/ (last visited Jan. 12, 2026). Stephen has been employed by PPL as a CDPAP caregiver for a diabetic family member since April 1, 2025. Id. ¶¶ 11–12. On July 14, 2025, Stephen commenced this action against PPL. Am. Compl.

Stephen alleges that PPL’s payroll system is inadequate in two main ways. First, Stephen alleges that PPL requires employees to record their hours through an electronic timesheet app (the “Electronic Visit Verification” or “EVV” system) that malfunctions regularly, leading to wage delays. Id. ¶¶ 13–16. Second, Stephen alleges that PPL enforces a “rigid weekly payroll cutoff at 11:59 p.m. Saturdays” that also leads to wages being delayed. Id. ¶ 16. As a result of the system malfunctions

and weekly payroll cutoff, Stephen alleges, he has experienced “late wages and combined paychecks.” Id. ¶ 17. Stephen alleges that these delays led to other harms, including delayed or reduced funding of medical and transportation benefits, missed or delayed prescriptions, approximately $500 in unspecified late fees, a missed rent payment in July 2025, and emotional damages. Id. ¶¶ 17–18a. Stephen claims that the wage delays violate the Fair Labor Standards Act (“FLSA”) and New York Labor Law (“NYLL”), and constitute breach of contract, negligence, and intentional

infliction of emotional distress. Id. ¶¶ 27–62. Finally, Stephen alleges that PPL retaliated against him in violation of the FLSA and NYLL by “cutting off technical support” and “[s]hifting all communications to Defendant’s legal counsel” after he brought this case. Id at ¶¶ 71–77. He seeks damages in an amount not less than $500,000, as well as declaratory and injunctive relief. Id. at 25–27.2 On September 24, 2025, Stephen moved for a preliminary injunction that would: 1) Requir[e] Defendant, within 30 days, to correct or provide a functional alternative to its defective EVV system; 2) Extend[] Defendant’s payroll submission cutoff by at least 24 hours beyond 11:59 p.m. Saturday; 3) Allow[] caregivers the option of separate paychecks for late-recorded hours rather than bundled pay; 4) Adjust[] the [benefits plan] to provide rolling or pro-rata funding of benefits . . . when hours are delayed; and 5) Order[] Defendant to file quarterly compliance reports for one year, with the first due within 90 days. Mot. for Prelim. Inj. (“PI Mot.”) at 1–2, ECF No. 14. In support of his motion, Stephen submitted a declaration in which he states that “on multiple dates in 2025,” he encountered an error message when he attempted to log in to the EVV system, that “[e]ach time the EVV system failed, [his] hours were not processed on time, which delayed [his] wages and sometimes forced multiple weeks of pay to be bundled together,” and that “[t]hese issues occur weekly.” Decl. of Sep. 24, 2025, PI Mot. Ex. A at 2, 5, ECF No. 14-1. Stephen also declared that because his wages were “delayed or bundled,” he suffered a denial of timely benefits funding, missed a student loan payment, missed or delayed filling prescriptions, lost approximately $50 in paid time off, and incurred an overdraft fee on his bank account. Id. at 4. In reply, Stephen submitted an additional declaration stating that an EVV

2 Page numbers are given to the numbers generated by the Electronic Case Filing System (“ECF”) unless otherwise stated. malfunction on September 27 and September 28 delayed his wages until October 1, 2025. Decl. of Oct. 31, 2025, at 6, ECF No. 27. PPL opposes the motion in full. Mem. in Opp’n to Mot. for Prelim. Inj. (“PI

Opp’n”), ECF No. 23. In opposition to the proposed preliminary injunction, PPL relies on a declaration from Escalation Manager Bennedette Mendez. Mendez Decl., ECF No. 23-5. Mendez affirmed that there is no requirement that caregivers submit their time by 11:59 p.m. Saturday. Id. ¶ 11. Instead, there is a weekly payroll cutoff, such that hours worked before 11:59 p.m. Saturday count towards the week’s pay, and hours worked after 12:00 am Sunday count towards the following week. Id. ¶¶ 14–

15. Mendez additionally alleges that Stephen’s delayed wages resulted not from system malfunctions but from his own failure to timely submit his timesheets. Id. ¶¶ 16–21. In any case, Mendez states, there are at least four mechanisms for caregivers to submit their hours. Id. ¶ 22. Finally, Mendez claims, there is “no outstanding payment amount owed to [Stephen].” Id. ¶ 27. Therefore, PPL argues, Stephen has neither shown that he faces irreparable, imminent harm, nor that he is likely to succeed on the merits. PI Opp’n at 7–17. PPL also argues that the requested

injunction would not be in the public interest; that the balance of equities weighs against the requested injunction; and that Stephen has failed to add a necessary party, namely the person receiving home health care (the “Consumer”). Id. at 17–24. STANDARD OF REVIEW Stephen seeks a preliminary injunction under Fed. R. Civ. P. 65(a). A preliminary injunction “is an extraordinary and drastic remedy, one that should not be granted unless the movant, by a clear showing, carries the burden of persuasion.” Moore v. Consol. Edison Co. of N.Y., 409 F.3d 506, 510 (2d Cir. 2005) (quoting Mazurek v. Armstrong, 520 U.S. 968, 972 (1997)). A plaintiff seeking a preliminary

injunction must establish the following elements: (1) [I]rreparable harm; (2) either (a) a likelihood of success on the merits, or (b) sufficiently serious questions going to the merits of its claims to make them fair ground for litigation, plus a balance of the hardships tipping decidedly in favor of the moving party; and (3) that a preliminary injunction is in the public interest.

New York ex rel. Schneiderman v. Actavis PLC, 787 F.3d 638, 650 (2d Cir. 2015) (citation modified). Additionally, when a movant seeks a mandatory injunction that “will alter, rather than maintain the status quo . . . the moving party must show a clear or substantial likelihood of success.” Beal v. Stern, 184 F.3d 117, 122–23 (2d Cir. 1999) (citation modified). Such a movant must also “make a strong showing of irreparable harm” and that “the preliminary injunction is in the public interest.” Actavis PLC, 787 F.3d at 650 (citations omitted).

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