Kirton v. Concepts of Independence, Inc.

Peter A. RoMERO □□□□□ D □□□□□□ [email protected]!

June 26. 2023 Vi RCE APPLICATION GRANTED SO ORDERED A}... □□ □□ Hon. Vernon S. Broderick ee □□□ United States District Court VERNON S. BRODE RICK Southern District of New York Foley Square U S.D.J, 6/27/23 New York, New York 10007 Re: Judy Kirton v. Concepts of Independence, Inc., Case No.: 1:22-cv-08552 (VSB) Dear Judge Broderick: This firm represents the Plaintiff Judy Kirton (“Plaintiff”) in the above-referenced putative collective and class action against Defendant Concepts of Independence, Inc. (“Defendant”), for alleged violations of the Fair Labor Standards Act and the New York Labor Law. Having reached a settlement in principle, the Court set a deadline of June 28, 2023, for Plaintiff to submit her motion for approval, pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015), with respect to Plaintiff's FLSA claims. However, the parties are continuing to finalize their settlement documentation. As such, the parties require a brief two-week extension of time to allow the parties to finalize the settlement documentation prior to the submission of their motion for approval. Accordingly, Plaintiff requests, with Defendants’ consent, an extension of time to submit the parties’ motion for approval from June 28, 2023, until July 12, 2023. No other deadlines would be affected by this extension. This is the parties’ second request for an extension of time to file their motion for approval, with the prior request having been granted.

We thank the Court for its consideration of this request.

Respectfully submitted, /S/ Matthew J. Farnworth, Esq.

MATTHEW J. FARNWORTH, ESQ.

C: All Counsel of Record via ECF OEFEICE OF PETER A RPOMERBO DIIC - I|LARBOPRP AND EMDIOVMENTIITIGATION