Ruiz Rivera v. Polaris Cleaners 99, Inc.

USDC SDNY J A DOCUMENT UNG & ASSOCIATES ELECTRONICALLY FILED A PROFESSIONAL CORPORATION DOC 4: ATTORNEYS AT LAW Se PARK AVENUE SOUTH, SUITE 7 NORTH DATE FILED: _ □□□□□□□□□□ NEW YORK, N.Y. 10016 HENRY H. JUNG TEL: (212) 481-O800 EDWARD S. FELDMAN FAX: (212) 481-0820 JOHN J. CONNOLY EM 0) FN DORSED [email protected] June 30, 2020 i VIA ECF Application GRANTED. SO ORDERED.

Hon. Judge Barbara Moses United States District Court alc Pearl Street Barbara Moses, U.S.M.J.

New York, NY 10007 July 2, 2020 Re: Ruiz Rivera et al v. Polaris Cleaners 99, Inc. et al (1:18-cv-08817-RA-BCM) Dear Hon. Judge Barbara Moses, This firm represents Defendants in the above-referenced case. I respectfully request the extension of due dates of the following three documents to July 6, 2020: (a) a joint letter demonstrating that the settlement agreement is fair and reasonable and should be approved in light of the factors enumerated in Wolinsky v. Scholastic Inc., 900 F. Supp. 2d 332, 335-36 (S.D.N.Y. 2012); (b) a copy of the parties’ fully executed settlement agreement, ; and (c) Plaintiffs’ counsel's time and expense records, together with any contingency fee agreement in this action.

Defendants’ counsels are still in the process of obtaining Defendants’ signatures on the settlement agreement and confession of judgment, and this is the only reason why the parties are unable to submit the aforementioned three documents today. More specifically, even though Defendants’ counsel fully explained Defendants the terms of the Settlement Agreement and Confession of Judgment in Korean, Defendants still want to have another person to fully translate and explain the terms of the Settlement Agreement and Confession of Judgment, and Defendants will meet the translator this Friday, July 3, 2020. Defendants represented to Defendants’ counsel that they would provide a signed Settlement Agreement and Confession of Judgment next Monday, July 6, 2020. I would like to inform the Court that Plaintiffs’ counsel, Mr. Clifford Tucker, has consented to this extension request.

Thank you for your attention to this matter.

Respectfully submitted, By: /s/Henry Hong K. Jung Henrv Hone K June Fea.