Correa v. Gold Bull Vend, LLC

KAUFMAN DOLOWICH VOLUCK Kaufman Dolowich & Voluck, LLP EYSOATORAM 135 Crossways Park Drive, Suite 203 Woodbury, New York 11797 E H. Grimmett, Esq.

[email protected] " Telephone: 516.681.1100 Facsimile: □□□□□□□□□□□□ wwwkdvlaw.com October 14, 2022 VIA ECF SeUPAE pes nee Honorable John G. Koeltl APPLICATION GOANTED United States District Court ORDERED Southern District of New York ao ly .

40 Foley Square of, | of 2 Kot: pf New York, New York 10007 =e 1/5], 39- John G.Koelif, US.Du, Re: Correa v. Gold Bull Vend, LLC et al 21-cy-07781-JGK Dear Judge Koeltl: We represent defendants, Gold Bull Vend, LLC (d/b/a Sudsy Water Laundry & Dry Cleaners) and LaChena Clark! (collectively referred to hereinafter as “Defendants”), in the above- referenced matter.

This letter is submitted jointly by the parties to respectfully request an extension of time to file a motion for settlement approval, from the current deadline of October 14, 2022 to November 14,2022. This is the first request for an extension to file a motion for settlement approval pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2015). Counsel for the parties are continuing to negotiate the terms of the settlement agreement and are requesting additional time to finalize same.

We thank the Court for its consideration of this matter.

Respectfully submitted, Kaufman Dolowich & Voluck, LLP Edward Grimmett cc: All Counsel of Record (via ECF) ! Please note that “LaChena Clark” was incorrectly identified in the caption of the Amended Complaint as “LaChana Clark.”

NY | NI] CT [PAP CA