Notice of Motion for Consolidation & Lead Plaintiff — Wilson v. Peloton (E.D.N.Y.)

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U.S. District Court, Eastern District of New York · No. 1:21-cv-02369-CBA-PK · Doc. 18 · 2021-06-28 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF NEW YORK 
ASHLEY WILSON, Individually and on 
behalf of all others similarly situated,  
 
Plaintiff,  
 
v.  
 
PELOTON INTERACTIVE, INC., JOHN 
FOLEY, AND JILL WOODWORTH, 
 
Defendants. 
 
Case No.: 1:21-cv-02369-CBA 
 
Hon. Carol Bagley Amon 
LEIGH DRORI, Individually and on behalf of 
all others similarly situated,  
 
Plaintiff,  
 
v.  
 
PELOTON INTERACTIVE, INC., JOHN 
FOLEY, and JILL WOODWORTH, 
 
Defendants. 
 
Case No.: 1:21-cv-02925-KAM 
 
Hon. Kiyo A. Matsumoto 
 
NOTICE OF MOTION OF DREW H. BROWN, SR., JENNIFER PHUNG, AND  
DAVID C. MILLHISLER FOR CONSOLIDATION OF THE ACTIONS, 
APPOINTMENT AS CO-LEAD PLAINTIFFS, AND APPROVAL 
OF SELECTION OF COUNSEL 
 
TO THE CLERK OF THE COURT, ALL PARTIES AND THEIR RESPECTIVE 
ATTORNEYS OF RECORD: 
PLEASE TAKE NOTICE that Drew H. Brown, Sr., Jennifer Phung, and David C. 
Millhisler (“Movants”) respectfully move this Court for an order: (1) consolidating the above-
captioned related actions (the “Actions”), (2) appointing Movants as Co-Lead Plaintiffs pursuant 
to §21D of the Securities Exchange Act of 1934 (“Exchange Act”), as amended by the Private 
Securities Litigation Reform Act of 1995 (the “PSLRA”), and (3) approving Movants’ selection 
of Levi & Korsinsky, LLP as Lead Counsel for the Class. 
Case 1:21-cv-02369-CBA-PK   Document 18   Filed 06/28/21   Page 1 of 2 PageID #: 104

2 
Movants seek consolidation of the Actions, appointment as co-lead plaintiffs, and approval 
of their choice of counsel pursuant to the Securities Exchange Act of 1934, the Federal Rules of 
Civil Procedure, and the PSLRA. This motion is based on this notice, the attached Memorandum 
of Law, the Declaration of Shannon L. Hopkins in support thereof, and the Court’s complete files 
and records in these actions, as well as such further argument as the Court may allow at a hearing 
on this motion. 
Dated: June 28, 2021  
 
 
 
Respectfully Submitted,  
 
 
 
 
 
 
 
LEVI & KORSINSKY, LLP 
 
 
 
 
 
 
By:  /s/ Shannon L. Hopkins 
Shannon L. Hopkins (SH-1887) 
55 Broadway, 10th Floor 
New York, NY 10006 
Tel: (212) 363-7500 
Fax: (212) 363-7171 
Email: shopkins@zlk.com 
Lead Counsel for Drew H. Brown, Sr., 
Jennifer Phung, and David C. Millhisler, 
and [Proposed] Lead Counsel for the Class 
 
 
 
Case 1:21-cv-02369-CBA-PK   Document 18   Filed 06/28/21   Page 2 of 2 PageID #: 105

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