Law Office of Mohammed Gangat 675 3rd Ave, Su 1810, NY, NY 10017 18) 669-0714 [email protected] Application granted. VIA ECF The parties shall file, by May 23, 2025, either: (i) a joint Cheeks —_—_—eewe . submission and fully executed proposed settlement agreement, o1 Honorable District Judge Philip M. Halpern|proposed Judgment pursuant to Federal Rule of Civil Procedure € United States District Court See Mei Xing Yu v. Hasaki Rest., Inc.,

(2d Cir. 300 Quarropas Street, Room 520 White Plains, NY 10601 “hw ,

Philip M. Halpern RE: Raul Herrera, et al. vy. Capri\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. 57). 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 joint 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.