Ponce v. Safi-G, Inc.

HELEN F. DALTON & ASSOCIATES, P.C. a, ATTORNEYS AT LAW The Court congratulates the parties on their settlement. / letter-motion at ECF No. 55 is GRANTED. All deadlines □ =p ey appearances, including the scheduled trial, are CANCELL == By December 4, 2023, the parties shall file a joint motio settlement approval pursuant to Cheeks v. Freeport Par Via ECF: House, Inc., 796 F.3d 199, 206 (2d Cir. 2015). Plaintiff's The Honorable Sarah L Cave, U.S.M.J. motion in limine at ECF No. 49 is DENIED as moot.

United States District Court Southern District of New York The Clerk of Court is respectfully directed to close ECF N Daniel Patrick Moynihan U.S. Courthouse [49 and 55, and to terminate the December 1, 2023 Pearl St. conference and the December 11, 2023 jury trial. □□ New York, NY 10007-1312 Adal Hy SO ORDERED. 11/13/2023 □□□ ye Re: Ponce, et al v. Saft-G, Inc., et al.

Civil Docket No.: 22-cv-04341 (SLC) Dear Judge Cave: Our office represents Plaintiffs Maria Paz Ponce, Wilson Lozano Rey, and Sergio Alonso Cabrera Montoya (“Plaintiffs”) in this FLSA Action, and we respectfully submit this letter motion, jointly and together with Counsel for the Defendants: (1) to apprise the Court that the parties have reached a settlement in principle on all claims asserted by all Plaintiffs herein; (2) to respectfully request that the Court stay all current deadlines in this matter in light of the parties’ settlement; and (3) to respectfully request three (3) weeks for the parties to submit their agreement and anticipated motion for settlement approval pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015).

As stated above, the parties reasonably anticipate three (3) weeks to be sufficient for the parties to submit their settlement agreement, and a motion for Court approval; moreover, the parties respectfully request that the Court issue an Order staying the deadlines for all submissions and appearances in this matter so that the parties may focus their efforts on preparing and finalizing the above-referenced documents. If this request is granted, the parties can file their above-referenced settlement submissions by December 1, 2023.

We thank The Court for its kind consideration on this matter, and we remain available to provide any additional information.

Respectfully submitted, Avraham cher Avraham Y. Seer, Esq.

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