Ovalles Acosta v. Prudent Management, LLC

William Cafaro, Esq. F | C E S O F Louis M. Leon, Esq.

Partner Associate ADMITTED IN NY, CA, MD & TX | IAM CAFARO ADMITTED IN NY Email: [email protected] Email: leon @cafaroesq.com Amit Kumar, Esq. 108 West 39" Street, Suite 602 Matthew S. Blum, Esq.

Managing Attorney New York, New York 10018 Of Counsel ADMITTED IN NY & NJ Telephone: 212.583.7400 ADMITTED IN NY Email: [email protected] Facsimile: 212.583.7401 Email: mblum @cafaroesq.com www. cajaroesqg.com Andrew S. Buzin, Esq. Deena L. Buchanan, Esq.

Of Counsel Of Counsel ADMITTED IN NY, FL & DC ADMITTED IN NM & NJ October 28, 2020 Via ECF Hon Vernon S. Broderick, U.S.D.J. APPLICATION GRANTED United States Courthouse SO ORDERED A Jep.. PY A Southern District of New York VERNON 8S. BRODERICK Foley Square U.$.D.J, 10/29/2020 New York, NY 10007 Re: Ovalles Acosta v. Prudent Management et al Case No.: 17-cv-07590 Your Honor: This office represents Jose A. Ovalles Acosta (“Plaintiff”) in the above referenced action brought pursuant to the Fair Labor Standards Act (“FLSA”) and New York Labor Law (“NYLL”).

We write to request a thirty (30) day extension of time to file our request for settlement approval pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199, 206 (2d Cir. 2015).

The Parties are still in the process of re-drafting the Settlement Agreement in this action and will need the time to have the Agreement signed by our clients. Given this, we believe a short extension of time to file the fairness from today, November 2, 2020 until December 2, 2020 will allow the Parties to file their request for approval. This is the third request for an extension of time to file a request for settlement approval.

Prior to making this request we contacted Defendants’ counsel, but were unable to get a response prior to making the application.

TK We thank the Court for its courtesy in this regard.

Respectfully Submitted, LAW OFFICE OF WILLIAM CAFARO By: Amit Kumar, Esq (AK 0822) Attorneys for Plaintiffs West 39" Street, Suite 602 New York, NY 10018 212-583-7400 Akumar @ Cafaroesq.com CC: All Defense Counsel of record (via ECF)