Fernandez v. Catholic Guardian Services

BoORRELLI & ASSOCIATES PLLC. www.employmentlawyernewyork.com M [= M O E N DO RS □□ Third Avenue 910 Franklin Avenue Suite 1821 Suite 200 New York, NY 10017 Garden City, NY 11550 Tel. No. 212.679.5000 Tel. No, 516.248.5550 Fax No. 212.679.5005 Fax No. 516.248.6027 Via 0 0 Plaintiff's request for an extension of time to file the parties’ . settlement agreement for approval is granted. The parties’ Via ECE ttlement t is due March 26, 2021 The Honorable Edgardo Ramos Settlement agreement 1s cue MAES 2: United States District Judge for the It is SO ORDERED. ek ( ) (2 Southern District of New York Edgardo Rath os, U.S.D.J Foley Square Dated: March 4, 2021 New York, New York 10007 New York, New York Re: — Fernandez v. Catholic Guardian Services, et al., Docket No. 1:17-cv-03161 (ER)(SN) Dear Judge Ramos: We represent named-Plaintiff Thania Fernandez and the forty opt-in Plaintiffs (all forty- one, collectively, as “Plaintiffs”) in this conditionally-certified collective action arising under the Fair Labor Standards Act and the New York Labor Law against Catholic Guardian Services, and individuals Craig Longley, Grace Poppe, and Dolores Ortiz (collectively as “Defendants’”). On November 9, 2020, Defendants’ counsel advised the Court that the parties had reached an agreement on the framework for a settlement in principle.

Since our last correspondence, the parties have made substantial progress towards finalizing the settlement agreement. However, given the number of Plaintiffs involved, signatures for all of whom are required, the parties need additional time to finalize the settlement and submit it for approval. Accordingly, we write now, on behalf of all parties, to request an additional twenty-one days, until March 26, 2021, to finalize the terms of the settlement, have it executed by all parties, and submit it to the Court for review in accordance with Cheeks □□□ Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015). This is the parties’ third request for an extension of this deadline.

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

Respectfully submitted, Caitlin Duffy, Esq.

For the Firm To: All parties via ECF