Ferrando-Guerra v. Zestful Management Corp. ( 2024 )

alas pee Bell Law Group, PLLC ee NY 116 Jackson Avenue LN; ie) SDC DNY | U Syosset, New York 11791 i | DOCUMENT T (516) 280-3008 | ELECTRONICALLY FILED F (516) ee 462 Rae DOC #: BelllLG.com = DATE FILED:_2/27/2024 Granted. March 27, 2024 SO ORDERED: je-—~ 3/27/2024 Hon. Robert W. Lehrburger, U.S.M_J. UNITED STATES MAGISTRATE JUDGE United States District Court South District of New York 40 Foley Square, Room 2201 New York, New York 10007 RE: Ferrando-Guerra, et al vs. Zestful Management Corp., Docket No.: 1:23-cv-8123 Dear Judge Lehrburger : We represent Plaintiffs in the above docketed employment matter. In compliance with Rule Rule I(F) of this Court’s individual practice rules, we write now to respectfully request a two-week extension of time to submit the parties’ settlement agreement and motion for settlement approval, pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015), from March 29, 2024 to April 12, 2024. Counsel for Defendant consents to this request. The reason for this request is that the undersigned has had numerous pressing legal deadlines since the date of the settlement conference due to staff turnover. Accordingly, the undersigned respectfully requests a two-week extension of time to submit the parties’ settlement agreement and Cheeks submission, from March 29, 2024 to April 12, 2024. We thank the court for its attention to this matter. Respectfully Submitted, BELL LAW GROUP, PLLC Chews Ut. Gomaris CG/ce ChayaM. Gourarie Esq. 5 Penn Plaza, 23 Floor 100 Quentin Roosevelt Blvd. Ste. 208 1629 K Street, NW, Suite 300 10750 NW 6 Court