Santiago v. Umbrella Management LLC ( 2024 )

ee ae ee □□ ee a Nae ee yay □□ □□□ □□□ □□□□ □□ □□ □□ —_—_—_—_—_ Brown Kwon & Lam, LLP B ROWN Attorneys at Law 521 Fifth Avenue, 17th Floor KWO N & New York, NY 10175 Tel.: (212) 295-5828 LAM LLP Fax: (718) 795-1642 hs Email: info@bkllawyers.com Writer’s Direct: clam@bkllawyers.com (212) 295-5827 Via ECF March 20, 2024 Hon. Dale E. Ho, U.S.D.J. United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Santiago v. Umbrella Management LLC, et al. Case No.: 1:23-cv-2673 (DEH)(SLC) Dear Judge Ho, We represent Plaintiff in the above-referenced matter and write jointly with counsel for Defendants to request a one-week extension of time, until March 27, 2024, to file the parties’ settlement agreement for court approval. See Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199, 206 (2d Cir. Aug. 7, 2015). Pursuant to the Court’s Order, the parties’ application for judicial approval is due on March 20, 2024. While the parties have worked to meet that deadline, we require additional time to finalize the language of the settlement agreement and to allow for execution prior to filing of the Cheeks motion. There have been no prior requests for an extension of this date. Thank you for your time and consideration. Respectfully Submitted, Application GRANTED. Is! Clara Lam The parties shall file their materials for judicial approval under Cheeks Clara Lam, Esq. (CL6399) Freeport Pancake House, Inc., 796 F.3d 19 (2d Cir. 2015), by March 27, 2024. ec: All Parties via ECF The Clerk of Court is respectfully requested to close ECF No. 39. SO ORDERED. Dale E. Ho United States District Judge Dated: March 21, 2024 New York, New York