Collado Gonzalez v. Chestnut Holdings of New York, Inc.

one NISAR LAW GROUP, P.C.

N | | G One Grand Central Place fu 60 East 42nd Street, Suite 4600 teaeaumh tos aes eal mete New York, NY 10165 Susan Ghim, Of Counsel [email protected] Main: (212) 600-9534 Direct: (646) 889-1011 “es MEMO ENDORSED at page 2 VIA ECF TO: Hon. Edgardo Ramos, U.S.D.J.

United States District Court, SDNY Foley Square New York, NY 10007 Re: Case No. 25cv753 Gonzalez v. Chestnut Holdings of New York, Inc., et al Request for Conference and Extension of Cheeks Motion Deadline Dear Judge Ramos: As the Court is aware, undersigned counsel represents the Plaintiff Angel Collado Gonzalez (‘Plaintiff’) in the above referenced matter. On or about July 16, 2025, Plaintiff and the Defendants Chestnut Holdings of New York, Inc., 1231 LLC, Kerem Holdings 7 LLC and 1504 Sheridan LLC (“Defendants”) (Plaintiff and Defendants collectively, “the Parties”) settled their wage and hour disputes in principle. [ECF doc. 25] On or about July 17, 2025, the Court ordered a deadline of August 15, 2025 for the parties to submit their settlement agreement for the Court’s approval pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015) [ECF doc. 27] On consent of Defendants’ Counsel, Plaintiff respectfully requests: (1) a short phone conference before the court to resolve a legal impasse under Cheeks, and (2) thereafter a two week extension to finalize a draft, execute and file their settlement agreement for approval. /d. This is the Parties’ first request for a court conference concerning their settlement in principle and for an adjournment of the Cheeks motion deadline. All other court dates and/or deadlines were adjourned sine die. [ECF doc. 27] Undersigned Counsel was at an all day mediation today on another matter and filed the instant requests as soon as possible. The Parties were diligently working towards finalizing their settlement agreement. However, counsel for Defendants sent a redlined draft agreement with further changes, earlier today which left inadequate time to finalize an agreement for execution.

Importantly, without disclosing the contents of settlement discussions, the Parties are at an impasse on two legal contentions under Cheeks. The Parties mutually wish to proceed to execution on a final agreement in this case and believe that the Court would be able to assist in the swift resolution of this impasse. As to the extension of the deadline to submit an executed document for approval, Plaintiff requires approximately two weeks after resolution of the legal impasse. Undersigned counsel requires additional time for scheduling purposes as I need to meet with the client with a language translator to review the final agreement for execution.

Respectfully submitted, /s/ Susan Ghim SusanGhim The request is granted. A conference is scheduled for August 26, 2025 at 11:30am. The deadline to file the executed settlement agreement for approval Via ECF to: all attorneys of record under Cheeks is September 9, 2025. The parties are instructed to call (855) 244-8681; enter access code 2301 087 7354#; and enter # again when asked to enter the attendee ID number. The parties are furthe instructed to join the call five (5) minutes prior to the conferences start time.

— \—_— Edgardo Ramos,‘U.S.D.J.

Dated: August 14, 2025 New York, New York