PETER A. RoMERO Ded □□□□□□□ □□□□□□□□□□□□□□□□□□□□□□□□□ January 18, 2023 VIA ECF Honorable Vernon S. Broderick APPLICATION GRAN 1 | D United States District Judge SO ORDERED AJep. PTA United States District Court VERNON S. BRODERICK Southern District of New York 0 1 19/2023 40 Foley Square USDJ New York, New York 10007 Re: |= Ronald Cerrato Galan v. Style Management Co., Inc., et al. Docket No.: 22-cv-01137 (VSB) Dear Judge Broderick: This firm represents the Plaintiff Ronald Cerrato Galan, in the above-referenced matter, against Defendants I Rosenberg Auto Repairs Inc., Andrew Rosenberg and Stefanie Rosenberg for alleged violations of the Fair Labor Standards Act (“FLSA”) and New York Labor Law. Having reached a settlement in principle, the Court directed Plaintiff to submit his motion for approval of the parties’ settlement, pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015), with respect to Plaintiff's FLSA claims, by January 20, 2023. The parties have recently completed negotiations relating to the terms of their formal settlement agreement. However, the parties must still confer regarding their joint motion for approval of the FLSA settlement. Unfortunately, Defendants’ counsel is out of town due to a family emergency and will be unable to confer regarding the motion for approval until after January 20, 2023. Accordingly, Plaintiff, with Defendants’ consent, requests a one-week extension of time to serve his motion for approval from January 20, 2023 until January 27, 2023. Plaintiff sought two prior extensions of this deadline, which was granted. Respectfully submitted, FA L al a ht llr DAVID D. BARNHORN, ESQ. C: All Counsel of Record via ECF OEFEICE OF PETER A RPOMERBO DIIC - I|LARBOPRP AND EMDIOVMENTIITIGATION