Garcia v. Sal 79 Associates, Inc. ( 2020 )

HELEN F. DALTON & ASSOCIATES, P.C. J J ATTORNEYS AT LAW 80-02 Kew Gardens Road, Suite 601, Kew Gardens, NY 11415 7 7 Tel. (718) 263-9591 Fax. (718) 263-9598 ep | => (718) (718) USDC SDNY DOCUMENT DOC #: DATE FILED: __ 12/4/2020 VIA ECF The Honorable District Judge John P. Cronan United States District Court Southern District of New York 500 Pearl Street New York, New York 10007 Re: Tellez Garcia, et al. v. Sal 79 Associates, Inc. et al. Civil Case No.: 1:19-cv-01301 (JPC)(KNF) Dear Judge Cronan: Our office represents the Plaintiffs in the above-referenced matter and we submit this letter motion to respectfully request an extension of time to submit the parties’ settlement agreement and motion for approval pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015). The aforementioned documents were due to the Court today, however, the parties are still working to finalize the necessary settlement documents. This is the first request for an extension of time to file and this request does not affect any other scheduled dates or deadlines. Defendants’ counsel consents to this request for an extension of time. If this is request is granted, the parties can submit the settlement agreement and motion for approval on or before December 17, 2020. We thank the Court for its consideration on this matter and remain available to provide any additional information. Respectfully submitted, _/s/ Roman Avshalumoy, Esq. Plaintiffs' request is GRANTED. The parties shall submit a joint motion for approval of the proposed settlement agreement, pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015), by December 17, 2020. The status conference scheduled for December 11, 2020 at 11:00 a.m. is adjourned sine die. SO ORDERED. 0 Vhof an