Cortes v. DS Brooklyn Portfolio Owner LLC

KATZMELINGER LEXINGTON AVENUE, SUITE 1512 NEw YorK, NEw York 10017 www.katzmelinger.com Adam Sackowitz t: 212.460.0047 Katz Melinger PLLC f : 212.428.6811 ajsackowitz @katzmelinger.com June 17, 2022 Via ECF Honorable Vernon S. Broderick United States District Court Foley Square, Room 518 New York, New York 10007 Re: Cortes et al. v. DS Brooklyn Portfolio Owner LLC et al.

Civil Action No. 20-cv-09619 Your Honor: We represent the plaintiffs, Joaquin Cortes and Raul Mera (“Plaintiffs”), in the above- captioned matter, and submit this letter jointly with counsel for all defendants to respectfully request a brief extension of the parties’ deadline to submit a settlement agreement and letter motion seeking approval of the settlement agreement until June 22, 2022. This is the parties’ second request for an extension of the aforementioned deadline.

Counsel have continued to work in good faith to finalize the terms of the parties’ agreement. As part of those efforts, within the last twenty-four hours, certain terms were proposed to be added to or modified within the proposed settlement agreement. Following additional discussions today, counsel now believe that they have an agreement on all terms and respectfully request a brief extension of time, until June 22, 2022, to submit a formal written settlement agreement and accompanying letter motion seeking approval of the agreement to the Court.

We apologize again for the untimeliness of this request. Counsel genuinely believed that the parties would be able to submit an agreement to the Court by today’s deadline, but unanticipated issues arose which necessitated this request for additional time.

We thank the Court for its consideration.

APPLICATION GRANTED Respectfully submitted, VERNON S. BRODERICK Fe USDJ. 06/21/22 Adamackowitz The parties shall have until June 24, 2022, to file their settlement agreement and letter motion. Prior to submitting, the parties should review recent case law in this District regarding the propriety of settlement approvals in similar actions, including my own recent orders. See, e.g., Adams v. By Design LLC, 21-CV-6157 (VSB), 2022 WL 1910135 VY Thine 2 9099): Miranda v Grace Farme Tne 16-CV-_1269 (VSR) 9099 WT.