Quizet Rivera et al v. Grill on 2nd LLC et al

Filing 109

ORDER LETTER MOTION for Extension of Time to File addressed to Judge John P. Cronan from Jordan Gottheim dated January 26, 2021. LETTER MOTION for Extension of Time to File Response/Reply as to 106 Proposed Default Judgment. 104 MOTION for Defaul t Judgment as to All Defendants. 105 Declaration in Support of Motion, addressed to Judge John P. Cronan from Jordan Gottheim dated January 26, 2021. Document filed by Angel Castillo (individually), Angel Castillo (on behalf of others similarly sit uated), et al. Plaintiffs' request is GRANTED. Any oppositions to Plaintiffs' motion for default judgment shall be filed by February 9, 2021. Any replies shall be filed by February 16, 2021. SO ORDERED. (Responses due by 2/9/2021. Replies due by 2/16/2021). (Signed by Judge John P. Cronan on 1/26/2021) (rjm)

Case 1:15-cv-06293-JPC-KNF Document 109 Filed 01/27/21 Page 1 of 1

Michael Faillace & Associates, P.C.
Employment and Litigation Attorneys
60 E. 42nd Street, Suite 4510
New York, New York 10165
_________

Telephone: [phone]
Facsimile: [phone]

January 26, 2021

VIA ECF
Honorable John P. Cronan, U.S.D.J.
United States District Court for the Southern District of New York
500 Pearl Street
New York, NY 10007
Re: Quizet Rivera et al v. Grill on 2nd LLC et al 1:15-cv-06293-JPC-KNF
Your Honor:
This office represents Plaintiffs in the above referenced matter. Today, Plaintiffs field a
motion for Default Judgment against all defendants (ECF Dos. Nos. 104-106). In light of the fact
that the motion was filed a day later than permitted under the Court’s Order of January 22, 2021,
and to avoid undue prejudice to the parties, Plaintiffs request that the deadlines for filing opposition
to the motion and for filing reply thereto, set in said January 22 Order for February 8 and 15
respectively, be each extended by one day, to February 9 and 16 respectively. This is the second
such request for an extension, the first having been filed and granted on January 22, 2021.
On behalf of Plaintiffs, I apologize for the delay in the filing of the motion and thank the
Court for its attention to this matter.

Respectfully submitted,
/s/ Jordan Gottheim
Jordan Gottheim
MICHAEL FAILLACE & ASSOCIATES, P.C.
Attorneys for the Plaintiff
Plaintiffs' request is GRANTED. Any oppositions to Plaintiffs' motion for default
judgment shall be filed by February 9, 2021. Any replies shall be filed by February
16, 2021.
SO ORDERED.
Date: January 26, 2021
New York, New York

___________________________

JOHN P. CRONAN
United States District Judge

Certified as a minority-owned business in the State of New York