Alicea v. The Woodner Company LTD

Rapaport Law Firm, PLLC | Attorneys at Law | 80 Eighth Avenue | Suite 206 | New ‘Yor Pursuant to Cheeks v. Freeport Pancake House, Inc., 79 F.3d 199 (2d Cir. 2015), the parties shall prepare a joint Rapaport statement explaining the basis for the proposed . settlement, including any provision for attorney fees, and Law =| rm Why it should be approved as fair and reasonable. The settlement agreement and joint statement shall be filed Marc A. Rapaport* via ECF by April 26, 2023..

Tel (212) 382-1600 Sain The Clerk of Court is respectfully directed to terminate th eee motion sequence pending at Doc. 22.

March 21, JSO ORDERED. via cwnce (Ory Philip M. Halpern Hon. Philip M. Halpem, U.S.D.J United States District Judge Federal Building and United States Courthouse Dated: White Plains, New York Quarropas Street, Room 530 March 22, 2023 White Plains, New York 10601-4150 Re: Irene Alicea v. The Woodner Company Ltd, Case No. 7:22-cv-09569-PMH Dear Judge Halpern: We represent plaintiff Irene Alicea (“Plaintiff”) in the above-referenced matter, which involves claims under the Fair Labor Standards Act, 29 U.S.C. §§ 201 ef seg. (“FLSA”) and New York Labor Law (“NYLL”) for wage and hour violations. We respectfully submit this letter, jointly with counsel for Defendant, to request that tomorrow’s scheduled initial conference be adjourned sine die because this afternoon, the parties reached a settlement in principle.

This is the second request to adjourn the foregoing conference. The parties believe that the requested extension will not affect any other deadline in this case. Although this extension request is made at the last minute, there is good cause for this request because, as stated above, the foregoing agreement in principle was only reached this afternoon.

The parties also jointly request sufficient time to prepare and submit a signed settlement agreement, together with an application for the Court’s approval of same pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F. 3d 199 (2d Cir. 2015).

The parties appreciate the Court’s attention to this request.

Respectfully submitted, Ware Kapaport Marc Rapaport ce: All Counsel of Record via ECF