KILLION v. PATEL

CourtDistrict Court, S.D. Indiana
DecidedApril 18, 2025
Docket1:24-cv-00337
StatusUnknown

This text of KILLION v. PATEL (KILLION v. PATEL) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
KILLION v. PATEL, (S.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

DYLAN KILLION, ) ) Plaintiff, ) ) v. ) No. 1:24-cv-00337-JPH-MJD ) CHINTU PATEL, et al., ) ) Defendants. )

ORDER ON MOTION FOR LEAVE TO AMEND COMPLAINT

This matter is before the Court on Plaintiff's Third Motion to File Amended Complaint, [Dkt. 117], and Defendants' objection thereto, [Dkt. 126]. For the reasons set forth below, the motion is GRANTED. I. Background Plaintiff in this case worked at three Subway restaurants that were owned by limited liability companies that were in turn owned by Chintu Patel. He asserts claims pursuant to the Fair Labor Standards Act ("FLSA") and the Indiana Wage Payment Statue, alleging that he was not paid in accordance with those statutes. He has sued Mr. Patel, Mr. Patel's wife, Jigna Patel, the three limited liability companies that owned the restaurants at which he worked—Subin 28, LLC, Subin 26, LLC, and Subin 34, LLC, (hereinafter collectively referred to as "the Killion LLCs")—and 35 other limited liability companies that own Subway restaurants and are owned by Mr. Patel (hereinafter collectively referred to as "the Other LLCs"). He "brings this case as a collective action pursuant to [the FLSA] on behalf of a class consisting of all similarly situated persons who are or were employed as non-exempt employees of the Subways owned and managed by Mr. Patel" and, as to the state law claim, "as a class action pursuant to Rule 23 on behalf of a class consisting of all similarly situated persons who are or were employed as employees of the Subways owned and managed by Mr. Patel." [Dkt. 42 at 7.] Defendants have filed a motion to dismiss the claims against all of the Defendants except

the Killion LLCs for lack of subject matter jurisdiction. [Dkt. 55.] Specifically, as relevant to the instant motion, Defendants argue the Plaintiff lacks standing to sue the Other LLCs because he was only employed by the Killion LLCs. Id. While Plaintiff has not yet filed a response to the motion to dismiss, it is anticipated that he will argue that he has standing to sue the Other LLCs based on the single employer doctrine. See [Dkt. 42 at 6] (allegation in Second Amended Complaint that all of "[t]he Subways owned and operated by Mr. Patel are an integrated employer under the Single Employer Doctrine."). II. Discussion Plaintiff seeks leave to file a Third Amended Complaint for two reasons. First, he wishes to add opt-in plaintiff and putative class member Angel Ray as an additional named plaintiff.

Second, he wishes to add two new defendants, JBMEnterprise, LLC and SubInky, LLC. 1. Applicable Law Leave to amend a complaint should be freely given "when justice so requires." Fed R. Civ. P. 15(a)(2). However, while Rule 15 creates a liberal standard for granting leave to amend, that standard must be reconciled with due respect for the Court's deadlines, as set in the case management plan that serves as the scheduling order required by Federal Rule of Civil Procedure 16(b). See Alioto v. Town of Lisbon, 651 F.3d 715, 719 (7th Cir. 2011). Here, the applicable deadline was June 20, 2024. Pursuant to Rule 16(b), after the expiration of the Court's scheduling order deadline to amend pleadings, a pleading may only be amended for good cause." Fed. R. Civ. P. 16(b)(4). Rule 16’s "good cause" standard "primarily considers the diligence of the party seeking amendment." Trustmark Ins. Co. v. General & Cologne Life Re of Am., 424 F.3d 542, 553 (7th Cir. 2005) (internal quotation marks and citations omitted). The movant bears the burden of showing "good cause." See Tschantz v. McCann, 160 F.R.D. 568, 571 (N.D. Ind.

1995) ("[A] party must show that despite their diligence the time table could not have reasonably been met."). The Seventh Circuit has held that the requisite diligence is not established if a delay is shown and the movant provides no good reason for the delay. See Alioto, 651 F.3d at 719. In reconciling Rule 15 and Rule 16, the Seventh Circuit has held it is proper for a court to consider first whether the moving party meets the heightened "good cause" standard under Rule 16(b)(4), before proceeding to examine whether the party meets the requirements of Rule 15. Alioto, 651 F.3d at 719. Ultimately, "the decision to grant or deny a motion to file an amended pleading is a matter purely within the sound discretion of the district court." Brunt v. Serv. Employees Int'l Union, 284 F.3d 715, 720 (7th Cir. 2002). 2. Analysis

Plaintiff recognizes that applicable standard and argues that there is good cause to permit the amendment because Plaintiff acted diligently to seek the amendment after he learned of the existence of the proposed new defendants, JBMEnterprise, LLC and SubInky, LLC. Plaintiff's counsel has shown that he asked Defendant Chintu Patel at his July 2024 deposition whether "there was a management company above the Subways," to which Mr. Patel responded in the negative. [Dkt. 117-1 at 3.] However, during a second deposition taken in February 2025, Mr. Patel revealed that JBMEnterprise, LLC, and SubInky, LLC, were, in fact, management companies that received "management fees" from the Subway restaurants. See [Dkt. 117-1 at 4] (describing JBMEnterprise, LLC, as "one of my management companies"); [Dkt. 117-1 at 5] (describing SubInky, LLC, as a management company owned by either Mr. Patel or his wife). In their response to the instant motion, Defendants take Plaintiff's counsel to task for failing to "define, explain, or suggest what he meant by the phrase 'management company.'"

[Dkt. 126 at 3.] But Mr. Patel did not ask for an explanation, so Plaintiff's counsel had no reason to believe that he was confused by the term "management company." And it was Mr. Patel who characterized JBMEnterprise, LLC, and SubInky, LLC, as "management companies" in his second deposition. So whatever Mr. Patel's understanding of the term "management company" was, he believed that JBMEnterprise, LLC, and SubInky, LLC, were management companies— although he did try to backtrack, testifying that JBMEnterprise was actually "not a management company. It's a company that collects management fee and distribution, profits, everything," [Dkt. 126-3 at 20], and then further backtracked, stating that its purpose was "basically not [to collect] management fee[s]. I would say like distribution, my profit," id. at 21. However, he later acknowledged that the financial records of Subin 28, one of the Killion LLCs, contained

payments denominated as "Management Fees" that were made to JBMEnterprise. [Dkt. 126-3 at 21, 24-25.] The reader can be excused for being confused and so, to an extent, can Plaintiff's counsel. While Plaintiff's counsel could have more artfully phrased his question at the first deposition— asking if there were any management companies that were related to the restaurants in any way, rather than asking if there were any management companies "above" them, the Court, in its discretion, finds that Plaintiff's counsel was sufficiently diligent in pursuing discovery in this case such that his failure to discover JBMEnterprise, LLC, and SubInky, LLC, as potential defendants in this case sooner was not due to a lack of diligence.

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Alioto v. Town of Lisbon
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Tschantz v. McCann
160 F.R.D. 568 (N.D. Indiana, 1995)

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Bluebook (online)
KILLION v. PATEL, Counsel Stack Legal Research, https://law.counselstack.com/opinion/killion-v-patel-insd-2025.