Ruiz Rivera v. Polaris Cleaners 99, Inc. ( 2020 )

USDC SDNY DOCUMENT JUNG & ASSOCIATES ELECTRONICALLY FILED A PROFESSIONAL CORPORATION DOC #: ATTORNEYS AT LAW DATE FILED: 06/30/2020 470 PARK AVENUE SOUTH, SUITE 7 NORTH —————_ NEW YORK, N.Y. 10016 HENRY H. JUNG TEL: (212) 481-O800 EDWARD S. FELDMAN FAX: (212) 481-0820 JOHN J. CONNOLY HJUNG@CRYSTALLAW.COM June 26, 2020 Application GRANTED. SO ORDERED. VIA ECF Hon. Judge Barbara Moses Cawickeus United States District Court Barbara Moses, U.S.M.J. June 30, 2020 500 Pearl Street New York, NY 10007 Re: Ruiz Rivera et al v. Polaris Cleaners 99, Inc. et al (1:18-cv-08817-RA-BCM) Dear Hon. Judge Barbara Moses, This firm represents Defendants in the above-referenced case. I respectfully request the extension of due dates of the following three documents to June 30, 2020: (a) a joint letter demonstrating that the settlement agreement is fair and reasonable and should be approved in light of the factors enumerated in Wolinsky v. Scholastic Inc., 900 F. Supp. 2d 332, 335-36 (S.D.N.Y. 2012); (b) a copy of the parties’ fully executed settlement agreement, ; and (c) Plaintiffs’ counsel's time and expense records, together with any contingency fee agreement in this action. Defendants’ counsels are still in the process of obtaining Defendants’ signatures on the settlement agreement and confession of judgment, and this is the only reason why the parties are unable to submit the aforementioned three documents today. I would like to inform the Court that Plaintiffs’ counsel, Mr. Clifford Tucker, has consented to this extension request. Thank you for your attention to this matter. Respectfully submitted, By: /s/Henry Hong K. Jung Henry Hong K. Jung, Esq.