Gomez v. Shine Services LLC

MARK A. BECKMAN ] USDC SDNY [email protected] | DOCUMENT DIRECT DIAL: (212) 453-0724 ecmmtc | ELECTRONICALLY FILED GORDONsREES EATHER E. GRIFFIN [email protected] ae SOULE PANS UKTI DIRECT DIAL: (212) 453-0715 DATE FILED: 1/13/21 YOUR 50 STATE PARTNER™ SS ATTORNEYS AT LAW BATTERY PARK PLAZA, 28™ FLOOR New York, NY 10004 WWW.GRSM.COM January 12, 2020 VIA ECF Magistrate Barbara Moses Daniel Patrick Moynihan United States Courthouse Pearl St. New York, NY 10007-1312 Re: Luis Gomez v. Shine Services LLC, et al.

Case No.: 1:20-cv-04190-AJN Dear Magistrate Moses: We represent defendants Shine Services LLC, FirstService Residential New York, Inc., West 178" Corp., and Ramesh Sarva (“Defendants”) in the above-referenced matter, and submit this letter, with the consent of plaintiffs counsel, to request an extension of time to file papers in this FLSA case for review and approval of the parties’ settlement pursuant to Cheeks v. Freeport Pancake House, 796 F.3d 199 (2nd Cir. 2015). The papers are currently due tomorrow, January 13, 2021; however, the undersigned recently experienced a death in the family and, as a result, the parties are still working on finalizing the Agreement.

Accordingly, the parties respectfully request the Court extend the deadline to submit the papers through and including 15 days from the Court’s order granting the request. As noted above, plaintiff consents to the request, and this represents the parties’ second request to extend the time to submit the papers. There are no current deadlines impacted by this request.

We appreciate the Court’s attention to this matter.

Respectfully submitted, What 1. $tz2-— Mark A. Beckman Heather E. Griffin Application GRANTED. The parties shall submit their settlement papers pursuant to Cheeks no later than January 28, 2021. SO ORDERED. ewok Barbara Moses, U.S.M.J.

Januarv 13. 2021