MorrisonConenur John B. Fulfree (212) 735-8850 [email protected]

May 27, 2021

Via ECE APPLICATION GRANTED Hon. John G. Koeltl, U.S.D.J. __. SOORDERED United States District Court Sc) of TY i oy Digg Southern District Of New York □□□ ——_ of SEMKP 500 Pearl St. A? , John G. Koeltl, U.S.D.J. New York, NY 10007-1312 □□□ Re: Shinji Ujiie v. New Life Sushi, Inc., et al., (S.D.N.Y. Docket No. 19-cvy-16996 (JGK)(DCF)) Dear Judge Koeltl:

We represent defendants New Life Sushi, Inc. d/b/a Sushi Seki Upper East Side, 365 Seki, Inc., d/b/a Sushi Seki Times Square, Bi Hang Cheng, and Zhong Shen Shi a/k/a Seki (collectively hereinafter, “Defendants”), in the above-referenced matter. We write on behalf of all parties to jomtly request an extension of time, from May 28, 2021 to June 4, 2021, to file a joint motion and proposed agreement settling Plaintiff's Fair Labor Standards Act claims, pursuant to Cheeks □□ Freeport Pancake House, Inc.,

(2d Cir. 2015) and this Court’s May 17, 2021, Order (ECF No. 38). This is the parties’ first request for an extension of time to file their settlement proposal. Several events presenting logistical challenges make this extension request necessary. Counsel for Plaintiff was out of the office last week on a planned vacation. Counsel for both parties have also been managing crowded litigation and counseling schedules that have temporarily delayed finalization of the parties’ jot motion pursuant to Cheeks. Further, as the Court is aware, Defendants Sushi Seki Times Square and Sushi Seki Upper East Side are sushi restaurants in Manhattan. Defendants are re-opening their businesses to full capacity amidst the upcoming holiday weekend, and this brief extension of time will allow counsel to obtain the required signatures for the proposed agreement during this busy time. Accordingly, the parties respectfully request that the Court permit them to file their motion and proposed settlement agreement by June 4, 2021.

Hon. John G, Koeltl United States District Judge May 27, 2021 Page 2

The parties thank Your Honor for his consideration of this joint request.

Respectfully submitted, /s/ John B. Fulfree John B. Fulfree cc: All Counsel of Record (Via ECF)