Calle Jara v. Manna 2nd Ave LLC et al

Filing 135

ORDER denying 134 Letter Motion for Extension of Time to File. Application DENIED. Plaintiff shall file his supplemental memorandum of law by May 28, 2021. Defendants' responsive brief is due June 18, 2021. The parties' three "bad dates" for trial and updated proposed JPTO with revised stipulated facts are due today, April 30, 2021 pursuant to ECF 133 and the instructions given at the April 21, 2021 conference.. (Signed by Magistrate Judge Ona T. Wang on 4/30/2021) (rro)

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

Telephone: [phone]
Facsimile: [phone]
April 28, 2021

VIA ECF
Judge Ona T. Wang
United States Magistrate Judge
United States District Court
500 Pearl Street
New York, NY 1007
Re:
CASE #:

MEMO ENDORSED

Calle Jara v. Manna 2nd Ave LLC et al
1:18-cv-02871-OTW

Your Honor:
This office represents Plaintiff in this matter. We submit this letter to respectfully request an
adjournment of the time to submit the supplemental pre-trial memorandum of law analyzing the
executive exemption as it applies to chefs in this case. Dkt. No. 123.
Plaintiff originally submitted a memorandum of law as to executive exemptions generally.
The Court directed Plaintiff’s counsel to supplement the analysis as to executive chefs. The Court
directed Plaintiff to submit the supplemental memorandum of law on April 30, 2021. Dkt. No.
123. There has been no previous request to adjourn this submission. The Defendant consents to
this request. The reason for the request is to spend additional time providing a comprehensive
analysis of the issues in the executive exemption for the Court.
Accordingly, Plaintiff respectfully requests until June 15, 2021 to submit the aforementioned
supplemental memorandum of law. We would also respectfully request that Defendant’s time to
respond would also be extended from May 21, 2021 to July 6, 2021.
We thank the Court for the time and attention devoted to this matter.
Application DENIED. Plaintiff shall file his
supplemental memorandum of law by May 28,
2021. Defendants' responsive brief is due June
18, 2021. The parties' three "bad dates" for trial
and updated proposed JPTO with revised
stipulated facts are due today, April 30, 2021
pursuant to ECF 133 and the instructions given
at the April 21, 2021 conference.
SO ORDERED.

____________________
Ona T. Wang 4/30/21
U.S.M.J.

Respectfully submitted,
By: ____/s/ Clifford R. Tucker _____________
Clifford R. Tucker, Esq.