Michael Faillace & Associates, P.C. Employment and Litigation Attorneys 60 E. 42™ Street, Suite 4510 Telephone: (212) 317-1200 New York, New York 10165 Facsimile: (212) 317-1620 [email protected] September 3, 2021

VIA ECF Honorable Ronnie Abrams United States District Judge Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 Re: — Cerezo v. 53 West 72nd Street Café, LLC (d/b/a The Dakota Bar), et al.; 20-cv-05492 (RA) Dear Judge Abrams: 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 September 3, 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. SO ORDERED.

ip Lid J“ —__ Hon. Ronnie Abrams 09/13/21 Certified as a minority-owned business in the State of New York