Morales v. Performance Master, Inc.

gains Bell Law Group, PLLC <P 116 Jackson Avenue a Syosset, New York 11791 T (516) 280-3008 F (516) 706-4692 BellLG.com oe wr January 19, 2024 Via ECF The Honorable Arun Subramanian United States District Court Southern District of New York Pearl Street New York, NY 10007 Re: Morales, et al. v. Performance Master, Inc. et al.

Civil Docket No.: 21-cv-00097-ER Dear Judge Subramanian: Our office represents Defendants J.D.M. Marmol & Granite and Marcos Zhiminaicela in the above-referenced matter. This letter is submitted to respectfully request an extension to January 26, 2024, for Defendants to submit a motion for summary judgment.

The basis for this request is that the undersigned was under medical illness during the first two weeks of January 2024. Moreover, Defendants were not Plaintiffs’ employer or joint employer, Plaintiffs have not provided any discovery responses with any evidence that Defendants were Plaintiffs’ employer and there is no issue of fact upon which to proceed to waste judicial resources.

We kindly thank Your Honor for your consideration of this request.

Very truly yours, /s/ Matthew Madzelan SO ORDERED. Matthew Madzelan, Esq.

Arun Subramanian, U.S.D.J.

Date: January 22, 2024 Penn Plaza, 23 Floor 1629 K Street, NW, Suite 300 10750 NW 6" Court New York, NY 10001 Washington, DC 20006 Miami, FL 33168