Zhang et al v. Hiro Sushi at Ollies Inc. et al

Filing 162

ORDER with respect to 161 Letter Motion for Extension of Time to File. Plaintiffs shall appear for a telephone conference on March 29, 2022 at 10:00 a.m. to discuss their request for extension of time to file Plaintiff Genxiang Zhang's supplemental party declaration. At the scheduled time, counsel should call [phone], access code 9176261. (Signed by Judge John P. Cronan on 3/28/2022) (tro)

TROY LAW, PLLC
ATTORNEYS / COUNSELORS AT LAW
Tel: [phone] [e-mail] Fax: [phone]
41-25 Kissena Boulevard, Suite 103, Flushing, NY 11355
March 28, 2022
Via ECF
Hon. John P. Cronan, U.S.D.J.
United States District Court
Southern District of New York
500 Pearl St.
New York, NY 10007-1312
Re: First Letter Motion for Extension of Time to File Supplemental Party Declaration until
April 11, 2022, from March 28, 2022
1:17-cv-07066-JGK Zhang et al v. Hiro Sushi at Ollies Inc. et al
Dear Judge Cronan:
This office represents Plaintiffs in the above referenced matter. Plaintiffs write
respectfully to request a two-week extension of time to file Plaintiff Genxiang Zhang’s
Supplemental Party Declaration in further support of his damages for the period from September
01, 2015, through December 25, 2015. This is our first request for an extension of time to file the
supplemental declaration in further support of his damages and granting this request will not
prejudice any party since the Defendants are currently in default.
On March, 24, 2022, Your Honor, ordered Plaintiffs’ counsel to file a supplemental
party declaration from Plaintiff Genxiang Zhang by March 28, 2022. See Dkt. No. 159.
However, the undersigned will not be able to timely file the supplemental party declaration by
March 28, 2022. The reason for the delay is that Plaintiff Genxiang Zhang is currently living
outside of New York State. As Plaintiff Genxiang Zhang is a full-time immigrant worker, he
does not have the luxury of being able to request time off and travel between States in a short
time frame. With such short notice, the Plaintiffs’ counsel was also not able to schedule an
appointment with Plaintiff Genxiang Zhang to supplement the affidavit in further support of
Plaintiff Zhang’s employment with the Defnedants’ for the period September 01, 2015, through
December 25, 2015.
Additionally, Plaintiff’s Counsel respectfully requests a two weeks’ extension of time
to submit the supplemental paperwork, since Plaintiff’s counsel has upcoming Trials in other
matters which has already taken up a significant amount of resources within the firm.
For the foregoing reason, the undersigned respectfully requests Your Honor to allow a
two-week extension of time to file Plaintiff Genxiang Zhang’s declaration in further support of
his damages for the period from September 1, 2015, to December 25, 2015.

Hon. John P. Cronan, U.S.D.J.
Southern District of New York
1:17-cv-07066- -JPC-DCF Zhang et al v. Hiro Sushi at Ollies Inc. et al
Page 2 of 2
We sincerely apologize for the delay and thank the Court for its time and kind
consideration of this matter.
Respectfully Submitted,
TROY LAW PLLC
Attorneys for Plaintiffs
/s/ John Troy
John Troy, Esq.
Cc: All Counsel of Record Via ECF
tcspk/JT

Plaintiffs shall appear for a telephone conference on March 29, 2022 at
10:00 a.m. to discuss their request for extension of time to file Plaintiff
Genxiang Zhang's supplemental party declaration. At the scheduled
time, counsel should call [phone], access code 9176261.
SO ORDERED.
Date: March 28, 2022
New York, New York

_________________________
JOHN P. CRONAN
United States District Judge