The Law Offices of Jacob Aronauer i TA 250 Broadway, Suite 600 , ‘y 7 /;*e New York, New York 10007 (212) 323-6980 [email protected]

January 13, 2025 Via ECF Hon. Ronnie Abrams Southern District of New York Re: = 1:24-cv-08473 (RA) Dear Judge Abrams: This office represents Plaintiff. The parties jointly request to adjourn the Court ordered conference scheduled for January 16, 2025. The basis for the request is that the parties have agreed to provide the Court with a settlement agreement consistent with Cheeks. This afternoon I provided Defendants a draft of a settlement agreement that I believe is consistent with Cheeks. We request to have three weeks to finalize the settlement agreement. I want to thank Defendants’ counsel for their professionalism. I also want to thank the Court for its patience and understanding. R tfull Via ECF “spree All attorneys on record /s Jacob Aronauer Jacob Aronauer granted. The January 16 conference is adjourned sine die. No later than February 14, 2025, the parties submit a joint letter setting forth their views as to why their settlement is fair and reasonable and should be accompanied by all necessary supporting materials. In light of the presumption of public access attaching documents,” see Lugosch v. Pyramid Co. of Onondaga,

(2d Cir. 2006), the parties are that materials on which the Court relies in making its fairness determination will be placed on the public et, see Wolinsky v. Scholastic Inc., No. 11-CV-5917 (JMF),

, at *3—7 (S.D.N.Y. July 5, 2012). are advised, however, that the Court will not approve of settlement agreements in which: (a) Plaintiffs practically any possible claim against the defendants, including unknown claims and claims that have no whatsoever to wage-and-hour issues,” Gurung v. White Way Threading LLC,

, 228 .N.Y. 2016) (internal quotation marks omitted); or (b) Plaintiffs are “bar[red] from making any negative stateme: the defendants,” unless the settlement agreement “include[s] a carve-out for truthful statements about [P]laintif litigating their case,” Lazaro-Garcia v. Sengupta Food Servs., No. 15 Civ. 4259 (RA),

(S.D.N.Y. Dec. 15, 2015) (internal quotation marks omitted).