MevRam Servs., LLC v. Quadrum Hospitality Group, LLC

2024 NY Slip Op 31163(U)
CourtNew York Supreme Court, New York County
DecidedApril 4, 2024
StatusUnpublished

This text of 2024 NY Slip Op 31163(U) (MevRam Servs., LLC v. Quadrum Hospitality Group, LLC) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MevRam Servs., LLC v. Quadrum Hospitality Group, LLC, 2024 NY Slip Op 31163(U) (N.Y. Super. Ct. 2024).

Opinion

MevRam Servs., LLC v Quadrum Hospitality Group, LLC 2024 NY Slip Op 31163(U) April 4, 2024 Supreme Court, New York County Docket Number: Index No. 652871/2023 Judge: James d'Auguste Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 652871/2023 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 04/04/2024

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: Hon. James E. d' Auguste PART 55 Justice ----------------------------------------------------X INDEX NO. 652871/2023 MEVRAM SERVICES, LLC, MOTION DATE 08/21/2023 Plaintiff, MOTION SEQ. NO. ------=--00-=---1.:___ _ -v- QUADRUM HOSPITALITY GROUP, LLC, ARLO SOHO, DECISION + ORDER ON LLC, ARLO NOMAD, LLC, ARLO MIDTOWN, LLC, MOTION Defendants. ---------------------- ------X

The following e-filed documents, listed by NYSCEF document number (Motion 001) 9, 10, 11, 13, 14, 15, 16, 17, 19, 21 were read on this motion to/for DISMISS

In Motion Sequence 001, defendants Quadrum Hospitality Group, LLC ("Quadrum"),

Arla Soho, LLC, Arla Nomad, LLC, and Arla Midtown, LLC ("Arla defendants") (collectively

"defendants"), move for dismissal of claims in plaintiffMevRam Services, LLC's ("MevRam")

complaint. Defendants oppose the motion. For the reasons set forth below, the motion is denied.

MevRam is a full-service hospitality and commercial cleaning company that staffs

employees, including housekeepers and front-desk employees for hotels; MevRam provides

services based on agreements with commercial companies, such as hotels. Quadrum is the

parent company of the Arla defendants, who each operate a hotel in New York City. MevRam

and Quadrum entered into three service agreements for MevRam to provide engineering and

housekeeping services to Quadrum's hotels (NYSCEF Doc. Nos. 10, 13).

The action arises from MevRam's complaint asserting that defendants allegedly

wrongfully breached the terms of three service agreements between the parties. Each agreement

contains essentially the same terms and conditions, except for the particular employees and

652871/2023 MEVRAM SERVICES, LLC, vs. QUADRUM HOSPITALITY GROUP, LLC ET AL Page 1 of 5 Motion No. 001

[* 1] 1 of 5 INDEX NO. 652871/2023 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 04/04/2024

services MevRam would provide. Each agreement also contains a no-poaching provision-

which prohibited either party engaging any staff employee of the other party for a period of 90

days after termination of the agreements. The contracts additionally provide that if the no-

poaching agreements were violated, the poaching party was required to continue the employee's

assignment for 520 consecutive work hours or pay MevRam a fee equivalent to 520 work hours

of such employee (NYSCEF Doc. Nos. 10, 17).

Defendants move for dismissal of MevRam's claims related to the no-poaching provision

asserting it is void, unenforceable and violates public policy. Defendants argue the no-poaching

provision violates the New York City Displaced Building Service Workers Protection Act

("DBSWPA"), and the New York City Displaced Hotel Service Workers Act (DHSWA").

Defendants assert that MevRam's claims that the "employees at issue were not displaced and

remained employed by MevRam" is unsupported by any exception written into either law, and

MevRam is simply "attempting an end-run around both of these laws" via enforcement of the no-

poaching provision in the parties' contracts (NYSCEF Doc. No. 21 ).

MevRam asserts that defendants breached the agreements by terminating them early

without providing the requisite notice, and by poaching MevRam's employees immediately

following termination of the contracts. MevRam contends that immediately after breaching the

parties' agreements, defendants hired Proper Hospitality Services ("PHS") to replace MevRam,

and PHS promptly hired 32 of MevRam's active employees to continue performing the same

services they did under the agreements between MevRam and defendants. However, despite the

breach, Mevram claims defendants refused to compensate MevRam fees owed, as required under

the no-poaching provision of the parties' agreements (NYSCEF Doc. Nos. 10, 17).

652871/2023 MEVRAM SERVICES, LLC, vs. QUADRUM HOSPITALITY GROUP, LLC ET AL Page 2 of 5 Motion No. 001

[* 2] 2 of 5 INDEX NO. 652871/2023 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 04/04/2024

Further, MevRam maintains that there is no support for defendants' arguments under the

DBSWPA and the DHSW A claiming neither applies to the instant matter. Mevram notes that

the employees at issue were not displaced and remained employed by MevRam with numerous

other available assignments following defendants' breach of the parties' contracts. Additionally,

MevRam notes that it is willing to provide alternative employment to its employees once a

service agreement is terminated (NYSCEF Doc. Nos. 17, 21).

Moreover, MevRam contends that contrary to defendants' assertions the liquidated

damages clause within the parties' agreements is enforceable. MevRam claims the provision for

liquidated damages within the parties' agreements is reasonably calculated based on a formula

that was intended, at the time the parties entered into the agreements, to estimate the actual

damages, and the amount of the liquidated damages is not grossly disproportionate to the actual

damages suffered (NYSCEF Doc. No. 17) (see Truck Rent-A-Center, Inc. v. Puritan Farms 2nd,

Inc., 41 NY2d 420 [1977]).

Defendants' claims that the no-poaching provision violates the DBSWPA and DHSW A

are meritless given that the employees were never displaced, and the two laws are not implicated

herein. It is clear DHSW A does not apply as it deals with a change in control of a hotel. As

there was no such change in control or identity of the hotels or hotels' employer herein as

defendants still own and control the hotels, the DHSW A is inapplicable, and the no-poaching

provision did not require defendants to violate that law. Hence, the no-poaching provision is

enforceable against defendants (NYSCEF Doc. Nos. 10, 17).

Similarly, while the DBSWPA on its face appears to be relevant to the instant matter, the

cases analyzing claims under the DBS WP A concern circumstances where employees were

actually displaced-when a new employer took over the management of a building, unlike here.

652871/2023 MEVRAM SERVICES, LLC, vs. QUADRUM HOSPITALITY GROUP, LLC ET AL Page 3 of 5 Motion No. 001

[* 3] 3 of 5 INDEX NO. 652871/2023 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 04/04/2024

Guerrero v. Club Quarters Mgmt. Co., LLC, 74 Misc. 3d 224 [Sup Ct, NY County. 2021]

(applying the DBSWPA where purchaser of hotel terminated plaintiff employees). Unlike in

Guerrero, there was no change in defendants' hotels' management, instead defendants breached

their contracts with MevRam to circumvent their obligations and poached MevRam's employees.

Thus, even had PHS failed to retain the subject employees as the successor contractor for

defendants, the employees would have remained employed by MevRam and continued to receive

their normal pay and benefits (NYSCEF Doc. No. 17). In any event, even if defendants were

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Related

Truck Rent-A-Center, Inc. v. Puritan Farms 2nd, Inc.
361 N.E.2d 1015 (New York Court of Appeals, 1977)

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Bluebook (online)
2024 NY Slip Op 31163(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/mevram-servs-llc-v-quadrum-hospitality-group-llc-nysupctnewyork-2024.