Luna Martinez v. K&P Facilities Maintenance Inc.

__. eee ee NII NIE ISDS OIE DEIN INA NDNA EE □□□ sine die. Pursuant to Cheeks v. Freeport Pancake KAUFMAN DOLOWICH VOLUCK House, Inc., 796 F.3d 199 (2d Cir. 2015), the parties shall ATTORNEYS AT LAW prepare a joint statement explaining the basis for the Aaron N. Solomon, Esq. proposed settlement, including any provision for attorney Email: fees, and why it should be approved as fair and 1C mail: [email protected] reasonable. The settlement agreement and joint □□ Saranicole A. Duaban, Esq. statement shall be filed via ECF by May 3, 2022. oO Email: SDuaban @kdvlaw.com The Clerk of Court is respectfully directed to terminate the April 1 motion sequence at ECF 26.

SO ORDERED.

VIA ECF Honorable Philip M. Halpern United States District Judge Southern District of New York Hip M. Halpern United States Courthouse United States District Judge Pearl Street, Room 1950 Dated: White Plains, New York New York, New York 10007 April 19, 2022 Re: Fredy Luna Martinez et. al. v. K&P Facilities Maintenance, Inc. Your Honor: This office represents K&P Facilities Maintenance, Inc. and Carlos Espinoza (“Defendants”) in the above referenced matter.

In accordance with Your Honor’s rules, the Parties request an adjournment of the initial conference currently scheduled for April 21, 2022 at 2:30 P.M. Plaintiffs’ Counsel consented to this adjournment. The Parties are requesting this adjournment because they have settled in principle the instant case and are currently working on finalizing a settlement agreement. This is the Parties’ first adjournment request of the initial conference. Thank you for your consideration of our request.

Respectfully submitted, Kaufman Dolowich & Voluck, LLP /s/ Saranicole A. Duaban Saranicole A. Duaban cc: All counsel of record via ECF