Michael Faillace & Associates, P.C. Employment and Litigation Attorneys 60 East 42" St. Telephone: (212) 317-1200 New York, New York 10165 Facsimile: (212) 317-1620

April 7, 2021 BY ECF & ELECTRONIC MAIL Honorable Katherine Polk Failla United States District Judge United States District Court Southern District of New York 40 Foley Square New York, NY 10007

Re: 20-cv-07214-KPF Martinez et al v. Ramen Meijin Inc. Your Honor: This firm represents Plaintiff in the above-referenced matter. The parties will be resolving this case through a Rule 68 Offer of Judgment (the “Offer”) pursuant to Mei Xing Yu v. Hasaki Rest., Inc.,

, 414 (2d Cir. 2019). However, Defendants need a bit more time to finalize the Offer and execute it. As such, the parties respectfully request that the deadline to submit settlement materials to the Court by April 9, 2021 be converted to a deadline to submit the Offer, and be extended by two weeks. This is the first request of its kind and is submitted on consent. The parties thank the Court for its time and attention to this matter. Respectfully Submitted, /s/ Jesse Barton, Esq. Michael Faillace & Associates, P.C. Attorneys for Plaintiff

Application GRANTED. The parties' submission shall be due on or by April 23, 2021. Dated: April 7, 2021 SO ORDERED. New York, New York Kiptherees Pall. Fuld HON. KATHERINE POLK FAILLA UNITED STATES DISTRICT JUDGE

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