Ametepe et al v. Peak Time Parking, Corp. et al

Filing 76

ORDER granting 75 LETTER MOTION for Extension of Time to File cross-motions for summary judgment. Request GRANTED. SO ORDERED. (Signed by Magistrate Judge Stewart D. Aaron on 2/25/2020) (jca)

February 25, 2020
Via ECF
The Honorable Stewart D. Aaron
United States Magistrate Judge for the
Southern District of New York
500 Pearl Street
New York, New York 10007
Re:

2/25/2020

Ametepe et al. v. Peak Time Parking, Corp. et al.
Docket No: 18-cv-5384 (PAE)(SDA)

Dear Judge Aaron:
This office represents the named-Plaintiff, James Ametepe, and the two opt-in Plaintiffs,
Pedro Sabala and Emmanuel Boadi (all three as “Plaintiffs”), in the above-referenced matter
involving alleged wage violations against Defendants, Peak Time Parking, Corp., and FIH
Enterprise Inc., and Sam Dar Enterprises Inc., and AD Parking Inc., and Zafar Majeed, and Fayyaz
Khan, and Naveed Anjum, and Mustafa Ali Khandwalla (collectively as “Defendants”) under the
Fair Labor Standards Act and the New York Labor Law. We write now, on behalf of all parties,
to respectfully request a seven-day extension of the parties’ joint deadline to submit cross-motions
for summary judgment, extending the deadline from February 28, 2020 to March 6, 2020.
Following the settlement conference, the parties have made substantial progress in
settlement discussions and are optimistic that the requested extension herein prior to filing the
parties’ respective cross-motions will aide the parties’ efforts to fully resolve the case.
Accordingly, the parties respectfully request a seven-day extension of the parties’ joint deadline
to file their cross-motions only, which if granted, will not affect the parties’ joint deadline to
oppose the respective cross-motions or joint deadline to submit replies. Therefore, should the
parties not reach a settlement, the matter will not be subject to any additional delay. The parties’
proposed briefing schedule is as follows: cross-motions due March 6, 2020, opposition papers due
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March 30, 2020, reply papers due April 14, 2020. This is the first request for an extension of the
parties’ joint motion deadline following the parties’ settlement conference with the Court.
We thank the Court for its time and attention to this matter.
Respectfully submitted,

_________________________
Jeffrey R. Maguire, Esq.
For the Firm
To: Defendants’ Counsel via ECF

Request GRANTED. SO ORDERED.
Dated: February 25, 2020

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