Wang v. Hainan Hnat-Management (US) LLC
Wang v. Hainan Hnat-Management (US) LLC
Trial Court Opinion
> New York Financial District Headquart JIA LAW GROUP 88 Pine Svaat Tah Fl Now York NY 10006 : ATTORNEYS AT LAW +1 347.897.6199
October 22, 2025 MEMO ENDORSED Via ECF Judge Edgardo Ramos, U.S.D.J. United States District Court Southern District of New York 500 Pearl Street, Room 1320 New York, NY 10007
Re: Wang v. Hainan Hnat-Management (US) LLC; 24-cv-04251; Joint Letter Motion for Additional Time to Submit Settlement Agreement for Cheeks Review.
Dear Judge Ramos: We represent the Defendant Hainan Hnat-Management (US) LLC (“Hainan”) in the above- referenced matter. We write jointly and with the consent of Plaintiff's counsel to respectfully request that the Court grant the Parties fourteen (14) days’ additional time from today, October 22, 2025, to submit the settlement agreement for review by the Court pursuant to Cheeks v. Freeport Pancake House, Inc.,
796 F.3d 199, 200(2d Cir. 2015) until November 5, 2025. The Parties are in the process of finalizing the terms of the settlement agreement before submission for review and request this additional time to do so. Thank you for Your Honor’s attention and consideration to this matter.
request is granted. The deadline to submit Respectfully submitted, settlement agreement for review is 5, 2025. JIA LAW GROUP, P.C.
ORDERED. By: /s/Thomas Hsien Chih Kung A \D Thomas Hsien Chih Kung Edaardo os USDI 88 Pine Street, 18" Floor ON WL 347) 897-6199 New York, New York ( “weet [email protected] Ce: — All parties of record (via ECF)
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