Davis v. T&T Express Shipping, LLC

aNiae ‘iiaiaaaaa Bell Law Group, PLLC a USDC SDNY 116 Jackson Avenue | vocemenr Sete New You 173 ELECTRONICALLY FILED F (516) 706-4692 DOC #: BellLG.com DATE FILED:_ 01/23/2024 January 22, 2024 Via ECF Application GRANTED. No later than January 31, 2024, the parties Hon. Stewart D. Aaron shall file their Cheeks submission and proposed settlement United States District Court agreement.

Southern District of New York New York New York 19007 80, ORDERED Pou ey, Ciates OTK, NEW FOF Dated: January 23, 2024 RE: Davis, et. al. v. T&T Express Shipping, LLC, et. al., Case No.: 22-cv-01936 (VSB) Dear Judge Aaron: We represent all Plaintiffs in the above-referenced matter. The Parties reached a settlement agreement after a mediation session with the Court on November 2, 2023. The first deadline for the Parties to submit a proposed settlement and a motion for settlement approval, pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015), was January 3, 2024, which this court extended to January 17, 2024, in response to the parties’ joint request for a brief extension of same.

On Friday, January 19, 2023, this court ordered that by Monday, January 22, 2024, “the parties shall either file their Cheeks submission or a joint letter motion requesting an extension of time, which shall explain the reason(s) for the untimely filing and basis for an extension of time.”

The undersigned sincerely apologizes to the Court for not abiding by the January 17, 2024 deadline. The undersigned was having difficulty reaching one of the plaintiffs to confirm his acceptance of the drafted settlement agreement and was hopeful that contact would be made with the plaintiff before the end of last week. The undersigned should have notified the Court of this challenge rather than allowing the deadline to pass, without a submission. I regret any inconvenience this may have caused the Court, and I can assure the court that it will not happen again.

In further compliance with this Court’s recent order, the parties now respectfully a second and final two-week extension of time, to January 31, 2024, to file the Cheeks submission and proposed settlement agreement to this Court. Iam confident this will give the undersigned sufficient time to reach all the plaintiffs and address any other issues pertaining to the proposed settlement agreement. We thank the Court for its time and attention.

Respectfully submitted, BELL LAW GROUP, PLLC /s/: Chaya M. Gourarie Chaya M. Gourarie, Esq.

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