Law Office of Mohammed Gangat 675 31d Ave, Su 1810, NY, NY 10017 Application granted. The parties shall file, by May 23, 2025, either: (i) a joint Cheeks VIA ECF submission and fully executed proposed settlement agreement, or (i tes “1: Proposed Judgment pursuant to Federal Rule of Civil Procedure 68. Honorable District Judge Philip M. Halpe United States District Court See Mei Xing Yu v. Hasaki Rest., Inc.,

(2d Cir. 2( 300 Quarropas Street, Room 520 White Plains, NY 10601 so Youth ,

Philip M. Halpern RE: Raul Herrera, et al. v. Ca United States District Judge Docket No. 1:24-cv-09483]|Dated: White Plains, New York May 8, 2025 Dear Judge Halpern, We represent the Plaintiffs in the above-referenced action and the related matter, Ruiz et al. v Capri IT Pizza, Inc., et al case number 7:24-cv-01536, and respectfully submit this joint letter requesting a two-week extension to file our Cheeks motion, which is currently due on May 9, 2025 pursuant to the Court's Order (Dkt. No. 23). The parties have made substantial progress in finalizing the settlement agreement and accompanying Cheeks’ motion. However, additional time is required to complete the review of all settlement documents with our respective clients, obtain the necessary signatures from all parties, and finalize the jot Cheeks submission. Additionally, Plaintiffs' counsel was incapacitated due to illness for more than a week in late April, which has delayed the completion of these tasks. If granted, the parties anticipate filing the completed Cheeks motion no later than May 23, 2025. This is the parties' first request for an extension of this deadline, and the requested extension will not affect any other scheduled dates in this matter. We appreciate the Court's consideration of this request.

Respectfully Submitted, (s Eliseo Cabrera Eliseo Cabrera, Esq.