Wang v. Hainan Hnat-Management (US) LLC

. New York Financial District Headquart JIA LAW GROUP 88 Pine Svaat Tah Fl Now York NY 10006 ATTORNEYS AT LAW +1 347.897.6199 November 26, 2025 Via ECF Judge Edgardo Ramos, U.S.D.J.

United States District Court Southern District of New York 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 additional time from today, November 26, 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 December 31, 2025. Defendant is in the process of obtaining the funds to make the Settlement Payment and the Parties are 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 Respectfully submitted, submit the settlement agreement is JIA LAW GROUP, P.C. to December 31, 2025.

ORDERED. By: /s/Thomas Hsien Chih Kung ~ Thomas Hsien Chih Kung A GT 88 Pine Street, 18" Floor Ramos. \U.S.D.J. New York, NY 10005 December 1, 2025 (347) 897-6199 York, New York thomas. [email protected] Ce: — All parties of record (via ECF) Page 1 of 1