Moore v. Nelson Management Group LTD.

CLIFTON BUDD & DEMARIA, LLP ATTORNEYS AT LAW EMPIRE STATE BUILDING TEL 212.687.7410 FIFTH AVENUE, 61ST FLOOR FAX 212.687.3285 New York, NY 10118 WWW.CBDM.COM October 5, 2022 VIA ECE Honorable Edgardo Ramos, U.S.D,J. M E M O E N D O RS E D » page 2 United States District Court Southern District of New York Foley Square, Courtroom 619 New York, NY 10007 Re: Ernest Moore v. Nelson Management Group, Ltd., et al., Case No. 1:22-cv-03515 (ER) Dear Judge Ramos: This firm represents the Defendants in the above-referenced action.

Pursuant to Sections 1.A and 1.E of Your Honor’s Individual Rules and Practices, we respectfully seek a three-week extension of time for the parties to file their settlement agreement and joint submissions with the Court for fairness review pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015), from the current deadline of Wednesday, October 5, until Wednesday, October 26.

This is the first application for an extension of the submission deadline, directed by this Court in an Order entered September 14. See Dkt. No. 14. The parties have conferred and Plaintiff's counsel consents to the application. No other dates or deadlines would be affected by the request.

Defendants are currently reviewing draft settlement paperwork that would memorialize and give effect to the parties’ agreement. While Defendants expect that any negotiations concerning the settlement paperwork will be quickly completed, the undersigned is out of the office the remainder of this week and all of the following week, returning Monday, October 17.

We thank the Court for its consideration of this request.

Respectfully Submitted, CLIFTON BUDD & DEMARIA, LLP Shia Defendants By: Stephen P. Pischl | Counsel CLIFTON BUDD & DEMARIA, LLP Hon. Edgardo Ramos, U.S.D,J. The parties' request for an extension of time to submit October 5, 2022 settlement agreement for the Court’s approval pursuan Page 2 Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015) from October 5, 2022 to October 26, 20 is GRANTED. It is SO ORDERED. cc: □□□ □□□ ee ieee ABDUL HASSAN LAW GROUP, PLLC Edgardo Ramos, U.S.D.J Attorneys for the Plaintiffs Dated: October 5, 2022 New York, New York _2-