Michael Faillace & Associates, P.C. Employment and Litigation Attorneys

60 E 42nd Street, Suite 4510 Telephone: (212) 317-1200 New York, New York 10165 Facsimile: (212) 317-1620 May 29, 2025

VIA ECF Hon. Judge Jesse M. Furman United States District Judge Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 Re: Rodriguez et al v. Produce Experience Inc. et al Docket No.: 25-cv-01363-JMF Your Honor: We represent Plaintiffs in the above referenced matter and write, on behalf of the parties, to respectfully request a thirty-day extension of the deadline to submit settlement papers to the Court, currently scheduled for May 22, 2025. The new deadline would be June 21, 2025. This is the first request of its kind and is submitted on consent. We apologize for the tardiness of this request. The parties will not be submitting an agreement to the Court for review but will rather be submitting an offer of judgment (the “Offer”) and acceptance to the Court pursuant to Mei Xing Yu v. Hasaki Rest., Inc.,

, 398 (2d Cir. 2019). The parties anticipate needing an additional several weeks to finalize the Offer and acceptance and file them on the docket. Respectfully submitted, /si Jesse Barton Jesse Barton, Esq.

Application GRANTED. The Clerk of Court is directed to terminate ECF No. 38. MG |

ay 30, 2025 Certified as a minority-owned business in the State of New York