Cuevas v. Our Children First, Inc.

BORRELLI & ASSOCIATES ———_——__ P.L.L.C. ———— www.employmentlawyernewyork.com Third Avenue 910 Franklin Avenue Suite 1821 Suite 200 New York, NY 10017 Garden City, NY 11530 Tel. No. 212.679.5000 Tel. No. 516.248.5550 Fax No. 212.679.5005 Fax No. 516.248.6027 December 2, 2019 Via ECF reece The Honorable Stuart D. Aaron USDC SDNY United States Magistrate Judge for the DOCUMENT Southern District of New York ELECTRONICALLY FILED Pearl Street DOC #: New York, New York 10007 ———— DATE FILED:_ 12/3/2019 __ Re: = Cuevas v. Our Children First, Inc. Docket No: 19-cv-7322 (SDA) Dear Judge Aaron: This office represents Plaintiff, Judith Cuevas, in the above-referenced matter involving wage violations against Defendant, Our Children First, Inc., under the Fair Labor Standards Act (“FLSA”) and the New York Labor Law. We write now to respectfully request a one-day extension from December 2, 2019 to December 3, 2019 to submit the parties’ joint motion for approval of the settlement of the Plaintiff's FLSA claims pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015). Defendant’s counsel has informed Plaintiffs counsel that he is still waiting for the signed agreement from his client, which should be received by tomorrow, and therefore Plaintiff is still waiting for the document to submit to the Court for its approval. Plaintiff will file the agreement, along with the accompanying motion, as soon as Plaintiff is in receipt. This is the parties’ third request for an extension of the deadline.

We thank the Court for its time and attention to the matter.

Respectfully submitted, ENDORSEMENT: Application GRANTED.

SO ORDERED. (| Dated: December 3, 2019 \ ul 4 pe al Jefftey R. Maguire, Esq. fart For the Firm