HELEN F. DALTON & ASSOCIATES, P.C. Ji. | i. ATTORNEYS AT LAW 80-02 Kew Gardens Road, Suite 601 ey | Sp Kew Gardens, New York 11415 ec-= Tel.: (718) 263-9591 June 28, 2022 Via ECF: The Honorable John P. Cronan, U.S.D.J. United States District Judge Southern District Of New York Daniel Patrick Moynihan U.S. Courthouse 500 Pearl Street, Courtroom 12D New York, New York 10007 CronanNySDChambers @nysd.uscourts.gov Re: Santos Guzman Garcia, et al. v. Moncon, Inc., et al. Docket No. 1:20-cv-5024 (JPC) Dear Judge Cronan: This office represents Plaintiffs in the above referenced matter (“Plaintiffs”) and we submit this letter motion jointly with Defendants to respectfully request that pre-trial submission date of July 1, 2022 and the jury trial start date of October 22, 2022 be adjourned sine die. The reason for this request is that the parties have reached a settlement-in-principle to resolve all remaining claims asserted in this action. Early today, the parties agreed on the terms of a settlement and will now begin drafting the necessary settlement documents. As this matter involves claims asserted under the Fair Labor Standards Act, the parties will be preparing the settlement agreement and motion for settlement approval for the Court’s review pursuant to Cheeks v. Freeport Pancake House,

(2d. Cir. 2015). As such, we ask that the above dates be adjourned so that the parties may focus their efforts on preparing these documents. If this request is granted, the parties respectfully request an August 1, 2022 deadline for submitting the settlement documents to the Court. This is the fifth request for an adjournment of the pre-trial submission date, however, this is the first such request due to the parties reaching a settlement-in-principle. This request will not affect any other deadlines than those stated above. We thank the Court for its patience and continued consideration.

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Respectfully submitted, Cass O'Denneke James O’Donnell, Esq.

The parties' request is granted. The parties shall submit any settlem requiring Court approval under Cheeks v. Freeport Pancake House, □ F.3d 199 (2d Cir. 2015), and any other necessary information, by Aug 1, 2022. All deadlines and conferences in this action, including the □□□ 2022 deadline for the parties to submit their proposed joint pretrial or CC: via ECF and any motions in limine, is adjourned sine die. Brian L. Gardner Cole Schotz P.C. SO ORDERED. 1325 Avenue of the Americas 19th Floor Date: June 29, 2022 Wha LE New York, NY 10019 New York, New York 212-752-8000 JOHN P. CRONAN Email: [email protected] United States District Judge ATTORNEY TO BE NOTICED Jason Robert Finkelstein Cole Schotz P.C. 1325 Avenue of the Americas New York, NY 10019 212-752-8000 Email: [email protected] ATTORNEY TO BE NOTICED

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