Miranda et al v. Grace Farms, Inc. et al

Filing 118

ORDER granting 117 Letter Motion for Extension of Time to File. APPLICATION GRANTED. SO ORDERED.. (Signed by Judge Vernon S. Broderick on 10/27/2022) (kv)

Case 1:16-cv-01369-VSB Document 118 Filed 10/27/22 Page 1 of 2

HELEN F. DALTON & ASSOCIATES, P.C.
ATTORNEYS AT LAW

80-02 Kew Gardens Road, Suite 601, Kew Gardens, NY 11415
Tel. [phone] Fax. [phone]

October 25, 2022
Via ECF:
The Honorable Vernon S. Broderick United
States District Court
Southern District of New York
Thurgood Marshall United States
Courthouse 40 Foley Square
New York, NY 10007

10/27/2022

Re: Miranda, et al. v. Grace Farms, Inc. d/b/a City Café, et al.
Civil Docket No.: 16-cv-1369 (VSB)
Dear Judge Broderick:
Our office represents the Miranda Plaintiffs in this FLSA action, and we respectfully submit
this letter motion to respectfully request a two-week extension of time for the parties to file their
Motion for settlement approval and related settlement documents for Court review (the “Motion”).
As a preliminary matter, we apologize to the Court for our violation of prior Courts Order,
and not sooner notifying the Court that the parties would be unable to satisfy the prior October
deadlines. Dkt. Nos. 115-116. This result was due to our office’s closure on various days earlier this
month due to our office’s observance of religious holidays as week as our office’s temporary loss of
contact with our clients and our inability to reach them earlier in the month. This resulted in the delay
in preparing the settlement documents to send to defense counsel and our office overlooking the
deadline for filing.
Since then, however, we have drafted the settlement documents, which we are sending to
defense counsel for his review. Our office anticipates that we will be able to finalize the documents
within the next two weeks.
We attempted to contact Defendants’ counsel today prior to the filing of this motion, but were
unable to reach him; however, we have no reason to believe that Defendants’ counsel would not join
in this request, and would consent to the relief sought herein.
Accordingly, we respectfully request a two (2) week extension of time to submit
the parties’ motion for settlement approval and settlement documents. If this request is granted,
the parties will be able to do so, and have the documents submitted for the Court’s review by or before
November 8, 2022.

Case 1:16-cv-01369-VSB Document 118 Filed 10/27/22 Page 2 of 2

We thank Your Honor for his kind consideration in this matter, and we remain available
to provide any additional information.
Respectfully submitted,
_______________________
Roman Avshalumov, Esq.
CC:
Philip K Davidoff, Esq.
FordHarrison LLP
366 Madison Avenue, 7th Fl
New York, NY 10017
914-316-1308
[e-mail]
ATTORNEY TO BE NOTICED FOR THE DEFENDANTS