EXHIBIT A

Case: 1:20-cv-03187 Document #: 212-1 Filed: 07/24/23 Page 1 of 24 PageID #:5929
UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

LISA PIAZZA, individually and on behalf of 

all others similarly situated, 

Plaintiff, 

v. 

NEW ALBERTSONS, LP; JEWEL FOOD 

STORES, INC.; and AMERICAN DRUG 

STORES, LLC d/b/a JEWEL-OSCO, 

Defendants. 

No. 1:20-cv-03187 

Judge Mary M. Rowland 

Magistrate Sheila M. Finnegan 

JOINT STIPULATION REGARDING DEFENDANTS’ EMERGENCY MOTION FOR 

STAY OF LITIGATION AND EMERGENCY HEARING REGARDING PLAINTIFF’S 

COUNSEL JASON CONWAY’S POTENTIAL WITNESS TAMPERING AND 

FRAUDULENT REPRESENTATIONS REGARDING INTERROGATORY 

VERIFICATIONS 

1. On June 2, 2023, Defendants filed an Emergency Motion for Stay of Litigation and 

Emergency Hearing Regarding Plaintiff’s Counsel Jason Conway’s Potential Witness Tampering 

and Fraudulent Representations Regarding Interrogatory Verifications (“Defendants’ Emergency 

Motion”). (Dkt. 176). 

2. The Parties have met and conferred and stipulate to the following proposed 

resolutions of Defendants’ Emergency Motion: 

a. Jason Conway of Conway Legal LLC will withdraw and recuse himself from 

the above-captioned matter, will file his voluntary motion to withdraw as 

counsel for Plaintiff and the Collective and putative Class, will have no contact 

with any Opt-In or putative Class member in or regarding this action, and will 

not assist or engage in the case in any capacity, other than to transition files. 

b. Jason Conway waives all rights to file a lien on the case for fees incurred at any 

time including as a prevailing party or in any settlement reached among the 

Parties. Additionally, Mr. Conway will not have any input, approval rights, or 

ability to preclude or interfere with any future settlement among the Parties. 

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The Parties, however, agree that in the event Plaintiff is a prevailing party in 

this litigation, Plaintiff’s fee petition, filed by other active counsel, may include 

reasonable time and reasonable fees incurred by Mr. Conway. 

c. Plaintiff will file a Motion to Withdraw her Cross Motion for Sanctions and 

Depositions of Eric Stevenson and Luigi De Matteo (Dkt.183). 

d. Plaintiff will file a Motion to Withdraw her Motion for Leave to Amend the 

Complaint (Dkt. 198) and stipulates that Plaintiff will take no action to refile a 

Motion to Amend the Complaint in this matter to expand the Collective or 

putative Class beyond the previously conditionally certified Collective and 

putative Class of current and former Jewel-Osco Assistant Store Directors 

employed in Defendants’ 188 Jewel-Osco Stores. 

e. The Parties will not seek any attorneys’ fees and/or costs against the other that 

are associated with filing and briefing of their respective motions relating to the 

present dispute. 

f. Defendants will file a Motion to Dismiss with Prejudice the following 6 NonResponsive Opt-ins, and Plaintiff agrees not to oppose the motion: 

i. Timothy Lindberg; 

ii. Ashley Moore; 

iii. Timothy Desch; 

iv. Terri Williams; 

v. Gary Miller; and 

vi. Eric Beauregard1

. 

Mr. Levin represents that he is finalizing the discovery answers and production 

for four Opt-Ins (Nicole Brock, Jessica Kuschel (Burke), Adam Mobley, and 

Lisa Garland), and will produce the discovery of those four Opt-Ins within 14 

days after the Court lifts the current stay on Opt-In discovery. Should Plaintiff 

fail to produce the four Opt-Ins’ discovery by that deadline, Plaintiff will not 

oppose Defendants’ Motion to Dismiss those four Opt-Ins with Prejudice. 

g. The Parties will submit for Court approval a Corrected Notice to the individuals 

who have previously opted-in and have not been dismissed advising that: 

i. Mr. Conway is no longer counsel of record, and that the law firm of 

Levin Sedran Berman, LLP will continue as counsel for Plaintiff and 

the Collective and putative Class; 

ii. Each Opt-In has the right to withdraw from the case or continue in the 

case without any retaliation, including that their employment status will 

not be affected; and 

1

 Although Opt-In Eric Beauregard has withdrawn his consent to join in this matter (Dkt. 166), 

Defendants seek to dismiss him with prejudice consistent with other withdrawn Opt-Ins. (Dkt 153). 

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iii. If an Opt-In elects to continue in the litigation, they understand their 

duty to actively participate in the action and discovery (if requested by 

the parties or ordered by the Court) which may include responding to 

written requests for information, providing documents including emails 

and text messages, and appearing to provide sworn testimony in a 

deposition and at trial. 

3. Upon the Court’s Approval of the above terms and the Parties’ respective filings 

and compliance with the same, Defendants will withdraw their Motion Emergency Motion for Stay 

of Litigation and Emergency Hearing Regarding Plaintiff’s Counsel Jason Conway’s Potential 

Witness Tampering and Fraudulent Representations Regarding Interrogatory Verifications 

(“Defendants’ Emergency Motion”) and all other relief sought therein. 

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 

LISA PIAZZA, NEW ALBERTSONS, INC., JEWEL FOOD 

STORES, INC., and AMERICAN DRUG 

STORES, LLC d/b/a JEWEL-OSCO, 

s/ Daniel Levin (w/ permission) 

Daniel Levin, Esq. 

Nicholas J. Elia, Esq. 

LEVIN SEDRAN BERMAN, LLP 

510 Walnut Street, Suite 500 

Philadelphia, PA 19106-3697 

Telephone: (215) 592-1500 

dlevin@lfsblaw.com 

nelia@lfsblaw.com 

Jason Conway, Esq. (admitted pro hac vice) 

CONWAY LEGAL, LLC

1700 Market Street, Suite 1005 

Philadelphia, PA 19103 

Telephone: (215) 278-4782 

Fax: (215) 278-4807 

jconway@conwaylegalpa.com 

Counsel for Plaintiff and the ASD Collective 

and Putative Class 

s/ Jennifer Schilling 

Jennifer Schilling ARDC# 6256634 

Kerri Feczko ARDC #6320598 

LITTLER MENDELSON, P.C. 

321 North Clark Street, Suite 1100 

Chicago, IL 60654 

Telephone (312) 372-5520 

jschilling@littler.com 

kfeczko@littler.com 

Lee Schreter (admitted pro hac vice) 

LITTLER MENDELSON, P.C. 

3424 Peachtree Road, NE, Suite 1200 

Atlanta, GA 30326 

lschreter@littler.com 

Counsel for Defendants 

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CERTIFICATE OF SERVICE 

 I certify that, on July 24, 2023, I caused a true and correct copy of the aforementioned 

document to be served on the below counsel of record in this matter via the Court’s ECF/CM filing 

system. 

Daniel Levin, Esq. 

Nicholas J. Elia, Esq. 

LEVIN SEDRAN BERMAN, LLP 

510 Walnut Street, Suite 500 

Philadelphia, PA 19106-3697 

Telephone: (215) 592-1500 

dlevin@lfsblaw.com 

nelia@lfsblaw.com 

Jason Conway, Esq. 

CONWAY LEGAL, LLC

1700 Market Street, Suite 1005 

Philadelphia, PA 19103 

Telephone: (215) 278-4782 

Fax: (215) 278-4807 

jconway@conwaylegalpa.com 

 

 /s/ Jennifer Schilling 

 Jennifer Schilling 

Case: 1:20-cv-03187 Document #: 212-1 Filed: 07/24/23 Page 5 of 24 PageID #:5933
EXHIBIT B

Case: 1:20-cv-03187 Document #: 212-1 Filed: 07/24/23 Page 6 of 24 PageID #:5934
IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

LISA PIAZZA, individually and on 

behalf of all others similarly situated, 

Plaintiff, 

v. 

NEW ALBERTSONS, INC., JEWEL 

FOOD STORES, INC., and 

AMERICAN DRUG STORES, LLC 

d/b/a JEWEL-OSCO, 

Defendants. 

Case No. 20-cv-3187 

Honorable Mary M. Rowland 

Magistrate Judge Sheila M. Finnegan 

 

JOINT MOTION TO WITHDRAW (1) DEFENDANTS’ EMERGENCY MOTION FOR 

STAY OF LITIGATION AND EMERGENCY HEARING REGARDING PLAINTIFF’S 

COUNSEL JASON CONWAY’S POTENTIAL WITNESS TAMPERING AND 

FRAUDULENT REPRESENTATIONS REGARDING INTERROGATORY 

VERIFICATIONS AND (2) PLAINTIFF’S CROSS MOTION FOR SANCTIONS AND 

DEPOSITIONS OF ERIC STEVENSON AND LUIGI DE MATTEO 

Plaintiff Lisa Piazza (“Plaintiff”) and Defendants, New Albertsons, L.P., incorrectly named 

New Albertsons, Inc., Jewel Food Stores, Inc. d/b/a “Jewel” and American Drug Stores, LLC, 

d/b/a “Osco” (“Defendants”) (collectively, “the Parties”), by and through their undersigned 

counsel and pursuant to their Joint Motion for Court Approval and Entry of Stipulation (Dkt. 212), 

hereby submit the following Joint Motion to Withdraw: (1) Defendants’ Emergency Motion for 

Stay of Litigation and Emergency Hearing Regarding Plaintiff’s Counsel Jason Conway’s 

Potential Witness Tampering and Fraudulent Representations Regarding Interrogatory 

Verifications (Dkt. 176) and (2) Plaintiff’s Cross Motion for Sanctions and Depositions of Eric 

Stevenson and Luigi De Matteo (Dkt. 183). In support of their Motion, the Parties state as follows: 

1. On June 2, 2023, Defendants filed their Emergency Motion for Stay of Litigation 

and Emergency Hearing Regarding Plaintiffs’ Counsel Jason Conway’s Potential Witness 

Case: 1:20-cv-03187 Document #: 212-1 Filed: 07/24/23 Page 7 of 24 PageID #:5935
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Tampering and Fraudulent Representations Regarding Interrogatory Verifications (hereinafter 

“Emergency Motion”). (Dkt. 176). 

2. On June 12, 2023, Plaintiff filed her Response to Defendant’s Emergency Motion 

and a Cross Motion for Sanctions and Depositions of Eric Stevenson and Luigi De Matteo 

(hereinafter “Plaintiff’s Cross Motion for Sanctions”). (Dkt. 183). 

3. On June 22, 2023, Defendants filed their Reply in Support of their Emergency 

Motion. (Dkt. 194). 

4. On June 27, 2023, Plaintiff filed her Reply in support of her Cross Motion for 

Sanctions. (Dkt. 197). 

5. On July 5, 2023, the Parties appeared before Magistrate Judge Finnegan via 

videoconference for a motion hearing on Defendants’ Emergency Motion and Plaintiff’s Cross 

Motion for Sanctions. (Dkts. 195 and 203). 

6. After hearing argument from both Parties, the Court took Defendants’ Emergency 

Motion and Plaintiff’s Cross Motion for Sanctions under advisement and further ordered Plaintiff 

to file the following additional information by July 17, 2023: 

a. A document identifying each alleged statement of opposing counsel made in 

writing or during a court hearing that Plaintiff's counsel believed to be a threat to 

seek sanctions against Discovery Opt−Ins personally (copies of written documents 

containing the statements should be attached); 

b. A declaration from paralegal Cheryl Hesson of Levin Sedran & Berman to 

supplement the June 12, 2023 declaration of attorney Levin describing Ms. 

Hesson's written and verbal communications with Discovery Opt−Ins (between 

10/21/2022 and 5/26/2023) regarding discovery responses. That declaration should 

also state whether and when Ms. Hesson drafted any discovery responses, and to 

whom she provided the responses (e.g., Mr. Conway and Opt−Ins), and when and 

how this was done; 

c. Copies of all emails sent by Mr. Conway and Ms. Hesson to the Opt−Ins (or 

received from the Opt−Ins) between 10/1/2022 and 5/26/2023 relating to their 

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discovery responses; 

d. Copies of all emails exchanged between Mr. Conway and Ms. Hesson between 

10/1/2022 and 5/26/2023 relating to the Opt−In discovery responses. If a privilege 

is asserted as to any particular email, Plaintiff may provide it to the Court for in 

camera review on a provisional basis; 

e. Phone records (similar to those provided for Mr. Conway) that identify calls 

between Ms. Hesson and the Discovery Opt−Ins between 10/1/2022 and 5/26/2023; 

and 

f. Screenshots of the original pdf verifications saved in a folder on Mr. Conway's 

work computer (as described by him during the hearing) reflecting the date each 

was created and modified. (Dkt. 203). 

7. On July 12, 2023, Plaintiffs filed a Motion for Extension of Time to Submit 

Additional Materials Pursuant to Court Order dated July 5, 2023. (Dkt. 204). The Court granted 

the extension for Plaintiff to file the supplemental materials until July 24, 2023. (Dkt. 205). 

8. A video hearing on Defendants’ Emergency Motion and Plaintiff’s Cross Motion 

for Sanctions is currently scheduled for August 8, 2023. (Dkt. Nos. 203, 205). 

9. As set forth in the Parties’ Joint Stipulation Regarding Defendants’ Emergency 

Motion and corresponding Joint Motion for Court Approval and Entry (Dkts. 212), the Parties 

jointly and respectfully request the following: 

a. That Defendants be granted leave to withdraw their Emergency Motion (Dkt. 176); 

b. That Plaintiff be granted leave to withdraw her Cross Motion for Sanctions (Dkt. 

183); and 

c. The Parties agree that they shall each bear their own attorneys’ fees and costs as a 

result of bringing this motions. 

10. The Parties submit this joint motion in good faith and is not intended for purposes 

of delay or any improper purpose. 

WHEREFORE, the Parties jointly and respectfully request that the Court enter an order 

Case: 1:20-cv-03187 Document #: 212-1 Filed: 07/24/23 Page 9 of 24 PageID #:5937
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granting: (1) Defendants’ request to withdraw their Emergency Motion for Stay of Litigation and 

Emergency Hearing Regarding Plaintiffs’ Counsel Jason Conway’s Potential Witness Tampering 

and Fraudulent Representations Regarding Interrogatory Verifications (Dkt. 176); (2) Plaintiff’s 

request to withdraw her Cross Motion for Sanctions and Depositions of Eric Stevenson and Luigi 

De Matteo (Dkt. 183); and (3) any further relief that this Court deems just. 

Dated: July 24, 2023 Respectfully submitted: 

LISA PIAZZA, NEW ALBERTSONS, INC., JEWEL FOOD 

STORES, INC., and AMERICAN DRUG 

STORES, LLC d/b/a JEWEL-OSCO, 

s/ Daniel Levin (w/ permission) 

Daniel Levin, Esq. (admitted pro hac vice) 

Nicholas J. Elia, Esq. (admitted pro hac vice) 

LEVIN SEDRAN BERMAN, LLP 

510 Walnut Street, Suite 500 

Philadelphia, PA 19106-3697 

Telephone: (215) 592-1500 

dlevin@lfsblaw.com 

nelia@lfsblaw.com 

Jason Conway, Esq. (admitted pro hac vice) 

CONWAY LEGAL, LLC

1700 Market Street, Suite 1005 

Philadelphia, PA 19103 

Telephone: (215) 278-4782 

Fax: (215) 278-4807 

jconway@conwaylegalpa.com 

s/ Jennifer Schilling 

Jennifer Schilling ARDC# 6256634 

Kerri Feczko ARDC #6320598 

LITTLER MENDELSON, P.C. 

321 North Clark Street, Suite 1100 

Chicago, IL 60654 

Telephone (312) 372-5520 

jschilling@littler.com 

kfeczko@littler.com 

Lee Schreter (admitted pro hac vice) 

LITTLER MENDELSON, P.C. 

3424 Peachtree Road, NE, Suite 1200 

Atlanta, GA 30326 

lschreter@littler.com 

 

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CERTIFICATE OF SERVICE 

The undersigned, an attorney, certifies that on July 24, 2023 she caused a copy of the 

foregoing Joint Motion to Withdraw (1) Defendants’ Emergency Motion for Stay of Litigation 

and Emergency Hearing Regarding Plaintiffs’ Counsel Jason Conway’s Potential Witness 

Tampering and Fraudulent Representations Regarding Interrogatory Verifications and (2) 

Plaintiff’s Cross Motion for Sanctions and Depositions of Eric Stevenson and Luigi De Matteo 

to be filed electronically with the Clerk of the U.S. District Court, Northern District of Illinois, 

using the CM/ECF (electronic case filing) system, which will send notification of such filing to 

the following parties: 

Daniel Levin, Esq. 

Nicholas J. Elia, Esq. 

LEVIN SEDRAN BERMAN, LLP 

510 Walnut Street, Suite 500 

Philadelphia, PA 19106-3697 

Telephone: (215) 592-1500 

dlevin@lfsblaw.com 

nelia@lfsblaw.com 

Jason Conway, Esq. 

CONWAY LEGAL, LLC

1700 Market Street, Suite 1005 

Philadelphia, PA 19103 

Telephone: (215) 278-4782 

Fax: (215) 278-4807 

jconway@conwaylegalpa.com 

Attorneys for Plaintiff and the ASD Class 

and ASD Collective 

 /s/ Jennifer Schilling 

 Jennifer Schilling 

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EXHIBIT C

Case: 1:20-cv-03187 Document #: 212-1 Filed: 07/24/23 Page 12 of 24 PageID #:5940
IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

LISA PIAZZA, individually and on 

behalf of all others similarly situated, 

Plaintiff, 

v. 

NEW ALBERTSONS, INC., JEWEL 

FOOD STORES, INC., and 

AMERICAN DRUG STORES, LLC 

d/b/a JEWEL-OSCO, 

Defendants. 

Case No. 20-cv-3187 

Honorable Mary M. Rowland 

Magistrate Judge Sheila M. Finnegan 

PLAINTIFFS’ UNOPPOSED MOTION TO WITHDRAW HER MOTION 

FOR LEAVE TO AMEND COMPLAINT 

Plaintiff Lisa Piazza (“Plaintiff”), on behalf of herself and the putative class and collective, 

by and through the undersigned counsel, and for her Unopposed Motion to Withdraw her Motion 

for Leave to Amend Complaint (Dkt. 198), states as follows: 

1. This action was commenced on May 29, 2020, and seeks the recovery of unpaid 

overtime under the Fair Labor Standards Act, 29 U.S.C. § 201, et seq., and Illinois Minimum Wage 

Law (“IMWL”), 820 ILCS 105/1, et seq. on behalf of an FLSA collective and Rule 23 class 

comprising Jewel-Osco’s current and former Assistant Store Directors (“ASDs”). (See generally,

Dkt. 1 (Class and Collective Action Complaint)). 

2. On June 2, 2023, Defendants filed an Emergency Motion For Stay of Litigation and 

Emergency Hearing Regarding Plaintiff’s Counsel Jason Conway’s Potential Witness Tampering 

and Fraudulent Representations Regarding Interrogatory Verifications (“Defendants’ Emergency 

Motion”). (Dkt. 176). 

3. On June 28, 2023, Plaintiff filed a Motion for Leave to File Amended Class and 

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2 

Collective Action Complaint. (Dkt. 198). 

4. Pursuant to a joint request, the Parties’ briefing on Plaintiff’s Motion to Amend is 

stayed pending Judge Finnegan’s ruling on Defendants’ Emergency Motion and Plaintiff’s Cross 

Motion for Sanctions. (Dkt. 211). 

5. As set forth in the Parties’ Joint Stipulation Regarding Defendants’ Emergency 

Motion and corresponding Joint Motion for Court Approval and Entry (Dkt. 212), Plaintiff 

respectfully requests leave to withdraw her Motion for Leave to File Amended Class and 

Collective Action Complaint. (Dkt. 198). 

6. Plaintiff further stipulates that she will take no action to refile a motion for leave to 

amend the Complaint in this matter to expand the class, the collective, or class members beyond 

the previously conditionally certified and putative class of current and former Jewel-Osco 

Assistant Store Directors employed in Defendants’ 188 Jewel-Osco Stores. Plaintiff’s decision 

was made in consultation with new lead counsel, Daniel Levin. 

7. As set forth in the Parties’ Joint Stipulation Regarding Defendants’ Emergency 

Motion and corresponding Joint Motion for Court Approval and Entry (Dkt. 212), Defendants do 

not oppose the granting of this motion. 

WHEREFORE, Plaintiff respectfully requests that the Court grant her Motion to Withdraw 

her Motion for Leave to Amend Complaint. (Dkt. 198). 

Dated: July 24, 2023 

Respectfully Submitted, 

s/ Daniel Levin 

Daniel Levin, Esq. 

Nicholas J. Elia, Esq. 

LEVIN SEDRAN & BERMAN LLP 

510 Walnut Street, Suite 500 

Philadelphia, PA 19106-3697 

Case: 1:20-cv-03187 Document #: 212-1 Filed: 07/24/23 Page 14 of 24 PageID #:5942
3 

Telephone: (215) 592-1500 

dlevin@lfsblaw.com 

nelia@lfsblaw.com

Jason Conway, Esq. 

CONWAY LEGAL, LLC 

1700 Market Street, Suite 1005 

Philadelphia, PA 19103 

Telephone: (215) 278-4782 

Fax: (215) 278-4807 

jconway@conwaylegalpa.com 

Attorneys for Plaintiff and the ASD Class 

and ASD Collective

 

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CERTIFICATE OF SERVICE 

I certify that, on July 24, 2023, I caused a true and correct copy of the aforementioned 

document to be served on all counsel of record in this matter through operation of the Court’s 

CM/ECF system. 

 /s/ Daniel Levin 

 Daniel Levin 

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EXHIBIT D

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FOR QUESTIONS CONTACT DANIEL LEVIN AT (215) 592-1500 or dlevin@lfsblaw.com

 

 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

LISA PIAZZA, individually and on behalf of 

all others similarly situated, 

Plaintiff, 

v. 

NEW ALBERTSONS, INC.; JEWEL FOOD 

STORES, INC.; and AMERICAN DRUG 

STORES, LLC d/b/a JEWEL-OSCO, 

Defendants. 

No. 1:20-cv-03187 

Judge Mary M. Rowland 

CORRECTIVE NOTICE OF LAWSUIT 

PLEASE READ THIS NOTICE 

1. What is this notice about? 

You previously submitted your consent to join the lawsuit entitled Piazza v. New Albertsons, Inc., 

Jewel Food Stores, Inc., and American Drug Stores, LLC d/b/a Jewel-Osco, regarding your 

employment as an Assistant Store Director by Jewel-Osco between August 26, 2017 and February 

3, 2021. 

You are receiving this CORRECTIVE NOTICE because there have been some recent 

developments in the lawsuit that may impact your rights. 

2. Why did I get this notice? 

You are receiving this corrective notice because you have previously elected to join this lawsuit. 

The Court for the Northern District of Illinois has authorized this corrective notice to inform you 

of some recent case developments. 

3. Plaintiff’s Counsel 

You have previously been represented by Jason Conway of Conway Legal LLC, Daniel Levin and 

Nicholas J. Elia of Levin Sedran Berman LLP, and Douglas M. Werman, Maureen A. Salas and 

Sarah J. Arendt of Werman Salas P.C. 

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FOR QUESTIONS CONTACT DANIEL LEVIN AT (215) 592-1500 or dlevin@lfsblaw.com

 

 

Mr. Conway has withdrawn from this case and will no longer represent you or any other 

individual who has joined this case. As Mr. Conway has withdrawn from this case he should 

not be contacted regarding this case. 

Mr. Werman, Ms. Salas, and Ms. Arendt of Werman Salas P.C. have also withdrawn from 

this case and they will no longer represent you or any other individual who has joined this 

case. 

You and other ASDs who joined this lawsuit, will continue to be represented by: 

LEVIN SEDRAN & BERMAN LLP 

Daniel Levin, Esq. 

510 Walnut Street, Suite 500 

Philadelphia, PA 19106-3697 

Telephone: (215) 592-1500 

dlevin@lfsblaw.com 

Please contact Mr. Levin if you have any questions about this Action. 

4. Notice of Rights to Stay in Litigation Or Right to Withdraw 

You previously joined this lawsuit. Your rights are protected and your claim for unpaid overtime 

under Illinois and federal law is being litigated. However, if you no longer wish to pursue your 

claim, please contact attorney Daniel Levin and you will be withdrawn from this lawsuit without 

fear of retaliation. If you withdraw, Defendants may ask the Court to bar you from asserting your 

claims again in the future; however, you will not be required to pay any costs or fees associated 

with this litigation as Plaintiff’s counsel will bear the costs and fees of litigation regardless of 

whether you withdraw from this lawsuit. 

Federal law prohibits an employer from firing or in any way retaliating against you because you 

have joined this lawsuit. Likewise, it is entirely your decision whether to remain in the lawsuit or 

elect to withdraw, and you will not be penalized for either decision. 

If you believe that you have been penalized, discriminated against, or disciplined in any way as a 

result of requesting to withdraw or electing to stay in this lawsuit, please contact Mr. Levin as 

listed above. 

5. Legal Effect Of Remaining in The Lawsuit 

It is entirely up to you to decide whether you remain in the lawsuit. If you choose to remain in this 

lawsuit, you will be bound by any ruling, judgment, or settlement, whether favorable or 

unfavorable. You may also be required to: 

(i) respond to written discovery and provide documents, including emails and text 

messages; 

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FOR QUESTIONS CONTACT DANIEL LEVIN AT (215) 592-1500 or dlevin@lfsblaw.com

 

 

(ii) travel to give your deposition and provide sworn testimony; and 

(iii) travel to and participate in trial. 

You will be separately contacted by Mr. Levin if you are required to do any of the above. 

Remaining in this lawsuit does not mean you are entitled to unpaid wages or damages, only that 

the Plaintiff’s attorneys will try to obtain a recovery for you. If you do not prevail, Plaintiff’s 

counsel will bear responsibility for the costs and expenses associated with this lawsuit. 

6. What happens if I do nothing after receiving this Corrective Notice? 

If you do nothing, you will remain part of the collective and be subject to the requirements 

described in Paragraph 5. 

By remaining in this lawsuit, you agree to have the Plaintiff and her counsel, Mr. Levin, act as 

your representatives and make decisions on your behalf concerning the case. Decisions made and 

agreements entered into by the Plaintiff will be binding on you, including approving any 

settlement, entering into an agreement with counsel regarding payment of attorneys’ fees and costs, 

and deciding all other matters pertaining to this lawsuit. 

7. What happens if I request to withdraw from the lawsuit? 

If you choose to request to withdraw from the lawsuit, you will not be entitled to share in any 

amounts recovered by the Plaintiff in this case and will not be affected by any decision regarding 

those claims, whether favorable or unfavorable, and you will not be responsible for costs and 

expenses. You will also be free to hire your own lawyer and file your own claims subject to the 

applicable time periods for asserting such claims. You should be aware that your time to bring 

FLSA claims is limited by a two- or three-year statute of limitations, and withdrawing from this 

action, or proceeding separately, may result in some or all of your claims expiring. 

If you wish to withdraw, please contact Plaintiff’s Counsel, Daniel Levin at (215) 592-1500 or 

dlevin@lfsblaw.com. 

8. How can I get more information? 

If you have any questions, you may write, e-mail or call counsel for the Plaintiff: 

LEVIN SEDRAN & BERMAN LLP 

Daniel Levin, Esq. 

510 Walnut Street, Suite 500 

Philadelphia, PA 19106-3697 

Telephone: (215) 592-1500 

dlevin@lfsblaw.com 

PLEASE DO NOT CONTACT THE COURT WITH QUESTIONS ABOUT THIS NOTICE. 

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EXHIBIT E

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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

LISA PIAZZA, individually and on 

behalf of all others similarly situated, 

Plaintiff, 

v. 

NEW ALBERTSONS, INC., JEWEL 

FOOD STORES, INC., and 

AMERICAN DRUG STORES, LLC 

d/b/a JEWEL-OSCO, 

Defendants. 

Case No. 20-cv-3187 

Honorable Mary M. Rowland 

Magistrate Judge Sheila M. Finnegan 

PLAINTIFFS’ UNOPPOSED MOTION FOR LEAVE TO WITHDRAW JASON 

CONWAY AS COUNSEL FOR PLAINTIFFS 

Plaintiff Lisa Piazza (“Plaintiff”), on behalf of herself and the putative class and collective, 

by and through the undersigned counsel and pursuant to Local Rule 83.17, and for her Unopposed 

Motion for Leave to Withdraw Jason Conway (“Mr. Conway”) as Counsel for Plaintiffs, states as 

follows: 

1. On June 4, 2020, the Court granted Mr. Conway’s Motion for Leave to Appear Pro 

Hac Vice on behalf of Plaintiff and the putative class and collective. (Dkt. 9). 

2. As set forth in the Parties’ Joint Stipulation Regarding Defendants’ Emergency 

Motion and corresponding Joint Motion for Court Approval and Entry (Dkt. 212), Plaintiff 

respectfully requests leave to withdraw Mr. Conway of Conway Legal, LLC as counsel of record 

for Plaintiff and the putative class and collective in this matter. 

3. Plaintiff and the putative class and collective will continue to be represented in this 

matter by Levin, Sedran & Berman LLP. 

4. Plaintiffs’ counsel conferred with defense counsel who stated that Defendants do 

Case: 1:20-cv-03187 Document #: 212-1 Filed: 07/24/23 Page 22 of 24 PageID #:5950
2 

not oppose this motion. 

WHEREFORE, Plaintiff respectfully requests that the Court grant her unopposed motion 

and permit Jason Conway of Conway Legal, LLC to withdraw his appearance as attorney of record 

for Plaintiff and the putative class and collective in this matter. 

Dated: July 24, 2023 

Respectfully Submitted, 

s/ Jason Conway 

Jason Conway, Esq. 

CONWAY LEGAL, LLC 

1700 Market Street, Suite 1005 

Philadelphia, PA 19103 

Telephone: (215) 278-4782 

Fax: (215) 278-4807 

jconway@conwaylegalpa.com 

Daniel Levin, Esq. 

Nicholas J. Elia, Esq. 

LEVIN SEDRAN & BERMAN LLP 

510 Walnut Street, Suite 500 

Philadelphia, PA 19106-3697 

Telephone: (215) 592-1500 

dlevin@lfsblaw.com 

nelia@lfsblaw.com 

Attorneys for Plaintiff and the ASD Class 

and ASD Collective

 

Case: 1:20-cv-03187 Document #: 212-1 Filed: 07/24/23 Page 23 of 24 PageID #:5951
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CERTIFICATE OF SERVICE 

I certify that, on July 24, 2023, I caused a true and correct copy of the aforementioned 

document to be served on all counsel of record in this matter through operation of the Court’s 

CM/ECF system. 

 /s/ Jason Conway 

 Jason Conway 

Case: 1:20-cv-03187 Document #: 212-1 Filed: 07/24/23 Page 24 of 24 PageID #:5952