N l ( USDC SDNY NISAR LAW GROUP, P.C. Employment Attorneys fu DOCUMENT wmneninnsen ELECTRONICALLY FILED Susan Ghim, Of Counsel DOC #: sghim@nisarlaw.com “Ven. 12/7/2023. Main: (212) 600-9534 DATE FILED: A" Direct: (646) 889-1011 Request GRANTED. The parties shall submit December 6, 2023 |the settlement agreement for the Court's review within five (5) business days of VIA ECF Defendant's receipt of the lien search —— results. The parties shall submit a joint Hon. Katharine H. Parker, MJ status letter to provide an update on the United States District Court, SDNY . P status of the lien search by January 2, 2024 500 Pearl Street New York, NY 10007 SO ORDERED: 2 RE: 23cv 437 Rambert v. Silvercup Scaffolding I LLC = ON. KATHARINE H. PARKER Fourth Request for Extension of Cheeks motion diyyrrep STATES MAGISTRATE JUDGE 12/7/2023 Dear Judge Parker: As the Court is aware, I represent Plaintiff Carlton Rambert in the above referenced matter where Plaintiff has made both wage and hour and discrimination allegations. The parties’ Cheeks motion is due on December 8, 2023. Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015) I write with Defendants’ consent to respectfully request an additional extension of time to submit the wage and hour settlement agreement for the Court’s review. The Defendants require additional time to complete a lien search. While the parties are hopeful that the lien search will be completed and receive the results within a reasonable time, the government agency’s time frame is uncertain. Instead of requesting any further extensions to an interim deadline and in the interest of judicial economy and efficiency, the parties request an extension to submit their Cheeks motion within five (5) business days of Defendants’ receipt of the requested lien search information. This is the parties’ fourth request for an extension of the Cheeks motion deadline. Thank you. Respectfully submitted, /s/ Susan Ghim Susan Ghim, Of Counsel 132746164.1 One Grand Central Place, 60 East 42°4 Street, Suite 4600, New York, New York 10165 Main: 212 600 9534 | Fax: 516 604 0157 | www.Nisarlaw.com