Jane Doe v. OneTaste, Inc., et al.

• Court: District Court, S.D. New York
• Decided: October 2, 2025
• Docket: 1:23-cv-10184
• Status: Unknown

Opinion

DOCUMENT Bake ELECTRONICALLY FILED REITLER KAILAS & ROSENBLATT uy DOC #:__ DATE FILED:_ 10/2/2025 MEMORANDUM □□□□□□ October 2, 2025 VIA ECF Hon. Gregory H. Woods United States District Court Southern District of New York 500 Pearl Street Room 2260 New York, NY 10007 Re: Jane Doe v. OneTaste, Inc., et al. 23 cv 10184 (GHW) Dear Judge Woods: This firm represents the Defendants OneTaste, Inc. (“OneTaste”), OneTaste NYC LLC (“OneTaste NYC”), Nicole Daedone (“Daedone”), and Rachel Cherwitz (“Cherwitz”) (collectively, ‘““Defendants”’) in the above-referenced matter. I write to request an adjournment of the Initial Pre-Trial Conference in this matter, currently scheduled for October 23, 2025, and of the time for the parties to file a Proposed Civil Case Management Plan and joint status letter, both currently due on October 16, 2025, until after sentencing of Daedone and Cherwitz in the case U.S. v. Cherwitz and Daedone, 23-CR-146-DG (the "Criminal Action"). There are no other scheduled dates that will be affected by granting the relief requested herein. Plaintiffs have no objection to this request. By Order dated May 3, 2024, this Court stayed this action pursuant to Section 1595(b) of the Trafficking Victims Protection Reauthorization Act (the “TVPRA”) until final adjudication of the Criminal Action. See ECF Doc. No. 29. For purposes of the TVPRA, a criminal matter is deemed to have been finally adjudicated when, in the event of any conviction, the sentencing of every convicted criminal defendant has occurred. Lunkes v. Yannai, 882 F. Supp. 2d 545, 549 (S.D.N.Y. 2012)). By letter dated August 5, 2025, the parties informed the Court that Daedone and Cherwitz had been convicted of conspiracy to commit forced labor and that sentencing for Cherwitz was scheduled for September 25, 2025 and for Daedone for September 26, 2025. See ECF Doc. No. 36. On August 6, 2025, this Court issued an Order providing that “Assuming that the stay will be lifted by the end of September, the Court will issue a separate initial pretrial conference order, New York Princeton Los Angeles 885 Third Avenue, 20" Floor 4 Independence Way, Suite 120 530 Wilshire Blvd. Suite 301 New York, NY 10022 Princeton, NJ 08540 Santa Monica, CA 90401 Main: 212-209-3050 Main: 609-514-1500 Main: 310-337-2305 259105 www.reitlerlaw.com

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setting an initial conference for late October.” ECF Doc. No. 37. This Court also issued its Notice of Initial Pretrial Conference on August 6, 2025. ECF Doc. No. 38. Since the parties’ last status report to this Court, the Court in the Criminal Action has adjourned the dates for sentencing of Daedone and Cherwitz sine die. At present, the Defendants in the Criminal Action and the Government are required to file their sentencing memoranda on October 29, 2025, and November 5, 2025, respectively. Under the circumstances, the parties respectfully request that the dates for the Initial Pre-Trial Conference and for the filing of the Proposed Civil Case Management Plan and joint status report likewise be adjourned. The Initial Pre-Trial Conference was initially scheduled for February 29, 2024, and was adjourned twice, at the request of Plaintiff, initially to March 15, 2024, and then to April 26, 2024. The time for the parties to file a Proposed Civil Case Management Plan and joint status letter was also extended, at the request of Plaintiff, twice, from February 22, 2024 to March 8, 2024 and then to April 19, 2024. Such prior adjournments were necessitated by the fact that it was not until February 21, 2024 that Plaintiff served on Defendants a Waiver of the Service of Summons (the “Waiver’). An executed copy of the Waiver was electronically filed by Plaintiff on March 7, 2024. See ECF Doc. No. 18. The Initial Pretrial Conference and the date for filing a Proposed Case Management Plan and joint status letter were subsequently adjourned sine die, after Defendants requested a pre-motion conference in connection with their contemplated motion for a stay pursuant to the TVPRA. See ECF Doc. Nos. 23-24. There have been no further adjournment of these dates. Respectfully submitted,

/s/ Edward P. Grosz Edward P. Grosz cc: All Counsel of Record (via ECF) granted. ‘The parties’ October 2, 2025 request to adjourn the initial pretrial conference, Dkt. No. 39, is ‘The initial pretrial conference scheduled for October 23, 2025 is adjourned sie die. ‘Vhe parties’ deadline for of the joint status letter and proposed case management plan is also adjourned sine die. ‘The parties are directed the Court with a joint letter updating the Court on the status of the related criminal action by no later than the of (a) the final adjudication of the criminal action or (b) December 5, 2025. The Clerk of Court is directed to the motion pending at Dkt. No. 39. ORDERED. October 2, 2025 ew York, New York GR H. WOODS United States District Judge