De Jesus v. Fordham Fulton Realty, Corp.

STEP H E N S DCU VIEIN 1 LAW FIRM ELECTRONICALLY FILED P LLC DOC #: DATE FILED: 8/29/2022 □□ July 22, 2022 Hon. Analisa Torres United States District Court Southern District of New York Pearl St. New York, NY 10007-1312 Re: Juan Elias de Jesus v. Fordham Fulton Realty Corp. ef al.

Case No. 1:20-cv-10951-AT Request for Extension of Time to Serve Dear Judge Torres: Iam counsel for the Plaintiff in the above-caption matter.

I write this letter to request a further extension of time to file a motion for approval of the settlement agreement pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015).

Since the Court last granted an extension of time to file a Cheeks motion, I have made contact with defense counsel, who confirmed that his office still represents both defendants in this matter, and that he is awaiting the return of the executed proposed settlement agreement. As the deadline to file a Cheeks motion in the matter has approached, I again attempted to contact counsel to inquire as to the status of the proposed settlement agreement, and to obtain counsel’s consent to request an extension of time to file a Cheeks motion, given the proximity of the deadline for filing. I have received no response from counsel. For the foregoing reason, I am therefore constrained to make this ex-parte request that the Court grant a further extension of time to file a Cheeks motion of at least three weeks so that I may make further inquiries of defense counsel regarding the execution of the proposed settlement agreement.

Thank you for your consideration of this request.

Yours truly, /S/ Glendoval J. Stephens GRANTED.

SO ORDERED. □□□ Dated: August 29, 2022 ANALISA TORRES New York, New York United States District Judge