Ubri v. Majestic Associates LLC ( 2024 )

Jeffrey R. Maguire, Esq., Partner =o: (212) 939-7229 f: (212) 531-6129 a: 445 Hamilton Avenue, Suite 1500, White Plains, NY 10601 €: jmaguire@stevensonmarino.com APPLICATION GRANTED Via ECF VERNON 8. BRODERICK The Honorable Vernon S. Broderick US.D.J. United States District Judge for the Dated: July 9, 2024 Southern District of New York 40 Foley Square New York, New York 10007 Re: — Ubriv. Majestic Associates LLC et al. Docket No: 23-cv-7954 (VSB) Dear Judge Broderick: We represent Plaintiff Eduardo Ubri in the above-referenced matter against Majestic Associates LLC, Majestic Property Associates LLC, 3871 Village Associates LLC, and Joshua Balsam (hereinafter, Majestic Property Associates LLC, 3871 Village Associates LLC, and Joshua Balsam are collectively referred to as “Defendants”). We write now, on behalf of Plaintiff and Defendants, to respectfully request a thirty-day extension of the parties’ deadline to file their motion for approval of Plaintiff's FLSA claims pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015), extending the deadline from July 5, 2024, to August 5, 2024. The basis for the request is to provide the parties with additional time to finalize the settlement agreement and corresponding motion papers. This is the first request for this extension and does not affect any other dates. We thank the Court for its time and attention to this matter. Respectfully submitted, f 4 iv’ \ | | < oe Jeffrey i ‘Maguire Stevenson Marino LLP To: Defendants’ Counsel via ECF