Castillo Rosario v. Lovely Twins Wines & Liquors Inc.

Michael Faillace & Associates, P.C.

Employment and Litigation Attorneys East 424 Street, Suite 4510 Telephone: (212) 317-1200 New York, New York 10165 Facsimile: (212) 317-1620 [email protected] USDC SDNY DOCUMENT ELECTRONICALLY FILED January 18, 2021 DOC #: DATE FILED:_01/18/2021 VIA ECF Valerie Caproni United States District Judge ‘Thurgood Marshall United States Courthouse Foley Square New York, NY 10007 Re: Castillo Rosario et al v. Lovely Twins Wines & Liquors Inc. et al CASE #: 1:20-cv-07941-VEC Your Honor: We represent Plaintiff in the above-named action. We respectfully request an extension of time to file a default judgment motion against the defendants in this action to assemble all necessary paperwork and continue attempting to contact defendants in this matter. The original time to file the motion is January 21, 2021. Dkt. No. 17. There have been no previous requests for adjournment. Defendants are in default. Consequently, there is no objection to an extension. We respectfully request that the trme to move for default be extended by 45 days to March 8, 2021.

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

Respectfully submitted, By: [s/ Chiford Tucker Clifford ‘Tucker intiff must move for an order to show cause why default judgment should not be entered against all four Defenda with this Court’s Individual Practices, by no later than Friday, March 5, 2021. Absent extraordinary the Court is unlikely to grant any further extensions.

Court reminds Plaintiff that if he enters into negotiations with any of Defendants, counsel must inform the Cour or if the parties have reached a settlement agreement, they must submit the agreement for approval in with Cheeks v. Pancake House, 796 F.3d 199 (2d Cir. 2017).

SO ORDERED.

Date: January 18, 2021