Hoyos v. Milio

LEVIN-EPSTEIN & ASSOCIATES, P.C.

420 Lexington Avenue * Suite 2525 * New York, New York 10170 T: 212.792-0046 © F: 646.786-3170 * E: [email protected] October 25, 2022 Via Electronic Filing The Honorable Gabriel W. Gorenstein, U.S.M.J.

U.S. District Court Southern District of New York MEMORANDUM ENDORSED Pearl St. New York, NY 10007-1312 Re: — Hoyos v. Milio et al Case No.: 1:22-cv-01982-AT Dear Honorable Magistrate Judge Gorenstein: This law firm is counsel to Plaintiff Rodolfo Hoyos (the “Plaintiff’) in the above- referenced matter.

Pursuant to Your Honor’s Individual Motion Practice Rules I(A) and I(E), this letter respectfully serves to request an extension of time to submit a joint letter pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015) from October 25, 2022 to, through and including, October 28, 2022.

This is the second request of its nature. This request is made on consent of Defendants’ counsel. If granted, this request would not affect any other scheduled deadlines.

The basis for this request is that Defendants’ counsel is in the process of gathering his clients’ signatures on the parties’ settlement agreement. The parties anticipate being able to file the joint letter on or before October 28, 2022.

Thank you, in advance, for your time and consideration.

Respectfully submitted, LEVIN-EPSTEIN & ASSOCIATES, P.C.

By: /s/ Jason Mizrahi Jason Mizrahi East 42nd Street, Suite 4700 New York, NY 10165 Tel. No.: (212) 792-0048 Email: [email protected] VIA ECF: All Counsel Attorneys for Plaintiff Extension to November 22, 2022, granted. No further extension absent a formal motion with a sworn affidavit as to the reason for the delay.

So Ordered. 2