Barroso v. Table 87 Gowanus NYC LLC

FORCHELLI DEEGAN TERRANA ALEXANDER LEONG, ESQ.

PARTNER ALEONG @FORCHELLILAW.COM November 8, 2023 Via ECF & E-Mail <Failla NYSDChambers @nysd.uscourts.gov> The Honorable Katherine Polk Failla United States District Judge United States District Court, Southern District of New York MEM END R Fi Foley Square, Room 2103 New York, NY 10007 Re: Joint Letter Motion to Extend Time for Parties to File FLSA Settlement Documents for Court Review Case Name: Barroso v. Table 87 Gowanus NYC LLC, et al.

Case No.: 23-cv-04864 (KPF) Dear Judge Failla: This law firm represents all Defendants in the above referenced case. Pursuant to Rule 2(D) of Your Honor’s Individual Rules of Practice in Civil Cases, the parties jointly and respectfully write to request a 2-week extension for the parties to file the proposed settlement agreement and corresponding documents for court review pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015). The proposed settlement agreement and corresponding documents are currently due on November 10, 2023 pursuant to Your Honor’s Order dated October 19, 2023 [See ECF Doc. No. 26]. A draft of the settlement agreement and corresponding documents have been exchanged, and the parties are working together to finalize the settlement documents. However, due to scheduling conflicts in other pending matters, counsel for the parties do not expect to have the documents finalized by November 10th. Accordingly, the parties respectfully request that they be permitted to file the proposed settlkement agreement and corresponding documents on or before November 24, 2023. This is the first such request.

We thank the Court for its time and consideration and apologize for any inconvenience this may cause.

Respectfully submitted, FORCHELLI DEEGAN TERRANA LLP By: /s/ Alexander Leong Alexander Leong cc: Leonor Coyle, Esq., Plaintiffs attorney (via ECF) Tha fClenn. 222 Darla Cixcinatan Bheaq Cistta 11h a Timitnndalo NAV 114552 R1L YAR 1700 a farochallilacw onnm Application GRANTED. The parties shall file the proposed settlement agreement and corresponding documents on or before November 24, 2023.

The Clerk of Court is directed to terminate the pending motion at docket number 32.

Dated: November 9, 2023 SO ORDERED.

New York, New York Kathir Palle (flo HON. KATHERINE POLK FAILLA UNITED STATES DISTRICT JUDGE