Santiago v. Umbrella Management LLC ( 2024 )

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 ee Email: info@bkllawyers.com Writer’s Direct: clam@bkllawyers.com (212) 295-5827 Via ECF March 27, 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 until April 5, 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 previous Order, the parties’ application for judicial approval is due on March 27, 2024. While the parties have worked to meet that deadline and the agreement has been finalized, we are still waiting for Defendants’ execution of the settlement agreement before we file the settlement agreement for Cheeks review. This is the second request for an extension of time to file the settlement agreement for fairness. Thank you for your time and consideration. The status conference scheduled for April 2, 2024 is CANCELLED, Respectfully Submitted, given the parties’ settlement. □□□ hat Cara wan (CL6399) The parties shall file their materials for judicial approval under Che ara Lam, v. Freeport Pancake House, Inc., 796 F.3d 19 (2d Cir. 2015), by Apri 2024. cc: All Parties via ECF The Clerk of Court is respectfully requested to close ECF No. 41. SO ORDERED. Dale E. Ho United States District Judge Dated: March 28, 2024