Xitumul Soto v. The Village in Times Square LLC

Fox Rothschild ue ATTORNEYS AT LAW Park Avenue, Suite 1700 New York, NY 10178 Tel 212.878.7900 Fax 212.692.0940 www.foxrothschild.com ALEXANDER BOGDAN Direct Dial: 212-878-7941 Email Address: ABogdan@ FoxRothschild.com February 1, 2021 This request is GRANTED. The conference schedule VIA ECF AND EMAIL February 8, 2021 at 10:30 a.m. is adjourned sine die. The partie: request Court approval of any settlement resolving any claim The Honorable John P. Cronan require Court approval under Cheeks v. Freeport Pancake Hous United States District Judge 796 F.3d 199 (2d Cir. 2015) by March 3, 2021.

United States District Court —YVba A □□□ SO ORDERED.

Southern District of New York Pearl Street, Room 1320 Date: February 1, 2021 JOHN P. CRONAN New York, NY 10007 New York, New York United States District Judge Re: Soto v. The Village in Times Square LLC et al. (1:20-cv- 05463-JPC) Joint Status Letter and Request for Adjournment of Pre-Trial Conference Dear Judge Cronan: We represent defendants The Village in Times Square LLC, Giovanni Carollo, and Artemio Cielo (collectively, “Defendants”’) in the above-referenced matter. On behalf of Defendants and jointly with Plaintiff Jose Manuel Xitumul Soto, we submit this joint status letter and request for an adjournment of the Initial Pretrial Conference (the ““Conference’”’) scheduled for February 8, 2021.

On January 20, 2021, the parties participated in mediation through the Southern District of New York’s Mediation Program and reached a settlement in principle. The parties anticipate that they will submit a proposed settlement agreement to the Court for approval within the next thirty (30) days. The parties request that the Conference be adjourned pending the parties’ submission to the Court of the proposed settlement agreement.

This application is the third request for an adjournment of the Conference. No other dates will be affected by this request. Plaintiff consents to this request for an adjournment.

Respectfully submitted, /s/ Alexander Bogdan Alexander Bogdan cc: All Counsel of Record. (via ECF) A Pennsylvania Limited Liability Partnership