Figueroa v. ZZ Lashes Inc. et al

Filing 48

ORDER granting 46 Letter Motion to Stay re: 46 FIRST LETTER MOTION to Stay Pending Settlement and Dismissal addressed to Magistrate Judge Sarah Netburn from Ishan Dave dated 11/15/2021., 47 FIRST LETTER MOTION to Stay Pending Settlement and Dismissal addressed to Judge Colleen McMahon from Ishan Dave dated 11/16/2021. ; granting 47 Letter Motion to Stay re: 46 FIRST LETTER MOTION to Stay Pending Settlement and Dismissal addressed to Magist rate Judge Sarah Netburn from Ishan Dave dated 11/15/2021., 47 FIRST LETTER MOTION to Stay Pending Settlement and Dismissal addressed to Judge Colleen McMahon from Ishan Dave dated 11/16/2021. 60 day order. Submit settlement agreement or JOINT pretrial order by January 14, 2022.. (Signed by Judge Colleen McMahon on 11/16/2021) (kv)

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Case 1:20-cv-04382-CM-SN Document 48 Filed 11/17/21 Page 1 of 1 Case 1:20-cv-04382-CM-SN Document 47 Filed 11/16/21 Page 1 of 1 DJrs:DEREK SMITH ~ LAW GROUP, PLLC Emp loyment Lawyers Representing Employees Exclu si vely November 16, 2021 Via ECF Hon. Colleen McMahon United States District Judge Southern District of New York 500 Pearl Street New York, NY 10007 Re : Figueroa v. ZZ LASHES INC et al. Case No: 1:20-cv-04382 Dear Judge McMahon: This firm represents Plaintiff in the above case. Plaintiff respectfully requests a stay of this action pending final execution of the settlement and dismissal with prejudice, or alternatively, leave to file a non-joint Proposed Pretrial Order. The parties have recently agreed to a settlement, and a final settlement agreement with terms that all parties have agreed to has been sent to Defendant Oberoi for his execution. We anticipate having the fully executed settlement agreement shortly and stipulating to dismiss with action with prejudice within the next few months . Moreover, we sent Defendant Oberoi a draft of the attached Proposed Joint Pre-Trial Order for his edits over forty (40) days ago, and we have been attempting to receive Defendant Oberoi's edits regarding the attached Proposed Joint Pretrial Order since that time, repeatedly following up with him . We have not received his edits to date. In light of the above, Plaintiff respectfully requests a stay of this action pending final execution of the settlement and dismissal with prejudice, or alternatively, leave to file the nonjoint Proposed Pretrial Order as attached. I thank the Court for its time and attention to this matter. USDCSDNY DOCUMENT ELECTRONICALLY FILED DOC #:-----""7'-+-::-t"----;DATE FILED: . Respectfully submitted, Isl Ishan Dave DEREK SMITH LAW GROUP, PLLC ISHAN DAVE Ishan @dereksmithlaw.com 1 Penn Plaza, Suite 4905 New York, New York 10119 Phone: (212) 587-0760 .. M - ' CC : All Counsel of Record (Via ECF) NYC Office: One Pennsy lvan ia Pl aza, Suite 4905, New York, NY 10 11 9 I (212) 587-0 760 Phil adelp hi a Office: 1845 Walnut Street, Suite 1600. Philadelphia , PA 19 103 I (215) 391-4790 NJ Office: 73 Forest Lake Drive, West Milford, NJ 07-t2 I I (973 ) 388-8625 Miami Office: I 00 SE 2 nd Street. Suite 2000, Miami, FL, 33131 I (3 05) 946-1884 """'-" .. .,_

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