Ovalles Acosta v. Prudent Management, LLC ( 2020 )

William Cafaro, Esq. F | C E S O F Louis M. Leon, Esq. Part Associat ADMITTED IN NY, CA, MD & TX | IAM CAFARO ADMITTED IN NY Email: bcafaro@cafaroesg.com Email: leon @cafaroesq.com Amit Kumar, Esq. 108 West 39" Street, Suite 602 Matthew S. Blum, Esq. Managing Attorney New York, New York 10018 Of Counsel ADMITTED IN NY & NJ Telephone: 212.583.7400 ADMITTED IN NY Email: akumar@cafaroesg.com Facsimile: 212.583.7401 Email: mblum @cafaroesq.com www. cajaroesqg.com Andrew S. Buzin, Esq. Deena L. Buchanan, Esq. Of Counsel Of Counsel ADMITTED IN NY, FL & DC ADMITTED IN NM & NJ December 1, 2020 pate Her S. Broderick. US.D.J APPLICATIONGRANTED United States Courthouse SO ORDERED A Jen, PIAA Southern District of New York VERNON 5. BRODERICK 40 Foley Square US.DJ. New York, NY 10007 Re: Ovalles Acosta v. Prudent Management et al Case No.: 17-cv-07590 Your Honor: This office represents Jose A. Ovalles Acosta (“Plaintiff”) in the above referenced action brought pursuant to the Fair Labor Standards Act (“FLSA”) and New York Labor Law (“NYLL”). We write, jointly with the defendants, to request a short two-week extension of time to file our request for settlement approval pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199, 206 (2d Cir. 2015). The Parties are still in the process of re-drafting the Settlement Agreement in this action and will need the time to have the Agreement signed by our clients. Given this, we believe a short extension of time to file the fairness from December 2, 2020 up to and including December 16, 2020 will allow the Parties to file their request for approval. This is the fourth request for an extension of time to file a request for settlement approval. We thank the Court for its courtesy in this regard. Respectfully Submitted, LAW OFFICE OF WILLIAM CAFARO / By: Amit Kumar, Esq (AK 0822) Attorneys for Plaintiffs 108 West 39th Street, Suite 602 New York, NY 10018 212-583-7400 Akumar@Cafaroesq.com CC: All Defense Counsel of record (via ECF)