Carnevale v. SellX, Inc. ( 2024 )

BANTLE & LEvy LLP ATTORNEYS AT LAW 99 PARK AVENUE, SUITE 1510 NEW YORK, NEW YORK 10016 ROBERT L. LEVY TEL 212.228.9666 LEE F. BANTLE FAX 212.228.7654 SHERIE N. BUELL DAVID KRAUSS The deadline to seek a certificate of default is hereby adjourned to Augus 2024. If the parties have not submitte their Cheeks materials by then, plain July 9, 2024 — should must seek a certificate. The C Via ECF Filing of Court is directed to terminate the Honorable Arun Subramanian motion at Dkt. 14. SO ORDERED. United States District Court Southern District of New York / 500 Pearl Street, Courtroom 15A New York, New York 10007 Arun Subramanian, U.S.D.J. Date: July 10, 2024 Re: Carnevale, et al. v. SellX Inc., et. al., 24-cv-02365 (AS) Dear Judge Subramanian: This firm represents Plaintiffs Casey Carnevale, Michael Huffer, Stephanie Majors, and Craig McCarthy in the above-referenced case. Together with counsel for Defendants SellX Inc. and Dean Glas, we write to advise that the parties have reached a settlement in principle in this matter that we are currently working to memorialize in a formal agreement to be submitted to the Court for review pursuant to Cheeks v. Freeport Pancake House Inc., 796 F.3d 199 (2d Cir. 2015). Accordingly, per Rule 3(E) of Your Honor’s Individual Practice Rules, we write to request a stay of Plaintiffs’ July 12, 2024 deadline to seek a certificate of default (ECF Doc. No. 12) in order to enable the parties to finalize and submit to the Court materials requesting approval of the settlement pursuant to Cheeks by August 9, 2024. This 1s the parties’ first request to stay or extend deadlines in this case. We appreciate the Court’s time and consideration of this joint request. Respectfully submitted, BANTLE & LEVY LLP BOOK LAW LLP Attorneys for Plaintiffs Attorneys for Defendants By: /s/Sherie N. Buell By: /s/Nadav Zamir Sherie N. Buell Nadav Zamir 99 Park Avenue, Suite 1510 7 Times Square, 19 Floor New York, New York 10016 New York, New York 10036 buell@civilrightsfirm.com NZamir@BookLawLLP.com