3 HELEN F. DALTON & ASSOCIATES, P.C. ATTORNEYS AT LAW

. 80-02 Kew Gardens Road, Suite 601, Kew Gardens, NY 11415 =p =) Tel. (718) 263-9591 Fax. (718) 263-9598

June 29, 2023 Via ECF: The Honorable Mary Kay Vyskocil, U.S.D.J. USDC SDNY United States District Court DOCUMENT Southern District of New York ELECTRONICALLY FILED Daniel Patrick Moynihan U.S. Courthouse DOC #: 500 Pearl St. DATE FILED: 6/29/2023 New York, NY 10007-1312 Re: | Cashabamba v. USA Interiors LLC, ef al. Civil Docket No.: 22-cv-03337 (MKV) Dear Judge Vyskocil: Our office represents Oscar P. Cashabamba (the “Plaintiff’), and we respectfully submit this letter motion, on consent of Defendants, to respectfully request a two (2) week extension of time for the parties to submit their Settkement Agreement, Motion for settlement approval and related settlement documents pursuant to Cheeks v. Freeport Pancake House, Inc.

(2d Cir. 2015). As apreliminary matter, this is the first such request in this case, and a granting of this request does not affect any other dates or deadlines in this matter. On May 26, 2023, the parties apprised the Court that they have reached a settlement in principle on all claims asserted herein. See Dkt. No. 35. In response thereto, on May 30, 2023, the Court directed the parties to file their above-referenced settlement submissions on or before June 30, 2023. See Dkt. No. 36. The reason the instant request 1s being made, however, is that our office 1s still in the process of finalizing the settlement documents and the parties require some additional time to finalize the documents, and procure our respective clients’ signatures. Accordingly, we respectfully request a two (2) week extension of the current deadline through July 14, 2023. We thank the Court for its kind consideration on this matter, and we remain available to provide any additional information.

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Respectfully submitted,

Leman Avahatumev- Roman Avshalumov, Esq.

CC: via ECF and Electronic Mail: Steven Kaplan, Esq. KAPLAN LEVENSON P.C. 910 Sylvan Ave, Ste 105 Englewood Cliffs, NJ 07632 Tel.: (212) 983-6900 Ext. 110 Email: [email protected] ATTORNEY FOR THE DEFENDANTS

Granted. SO ORDERED.

Date: 6/29/2023 K. {/ New York, New York Maw |Kay V¥skocil nited States District Judge

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