Soto v. Triumph Construction Corp. et al

Filing 43

ORDER granting 42 Letter Motion for Extension of Time to File. APPLICATION GRANTED. SO ORDERED.. (Signed by Judge Vernon S. Broderick on 11/21/2022) (kv)

Case 1:21-cv-02449-VSB Document 43 Filed 11/21/22 Page 1 of 1

ROBERT WISNIEWSKI P.C.
ATTORNEYS-AT-LAW

17 STATE STREET, SUITE 820 • NEW YORK, NY 10004

TEL: [phone] • WEB: www.rwapc.com

November 20, 2022
Hon. Vernon S. Broderick, USDJ
Thurgood Marshall
United States Courthouse
40 Foley Square
New York, NY 10007

11/21/2022

Re: Soto v. Triumph Construction Corp. et al.
Docket No.: 21-cv-02449-VSB
Dear Judge Broderick,
I represent Plaintiff in the above-entitled action. I write jointly with Defendants’ counsel
consent to request that, for the reasons that follow, Your Honor kindly extend the time for the
parties to submit their settlement agreement for a Cheeks review from November 21, 2022 to
December 9, 2022. This is the third request of its kind and two previous requests were granted
for good cause. There is no prejudice to any party.
Counsel for the parties are in the final stages of working out the text of the settlement
agreement with only several secondary issues remaining. It has taken us longer than anticipated
because of my trip overseas for the All Souls’ Day visit to my mother’s grave and the limited
access to the internet whilst I was abroad. Unfortunately, now Defendants and their counsel are
embarking on trips related to Thanksgiving and will be unable to fully devote their attention to
the document in the meantime. We are requesting only as much time as is necessary to ensure
that all parties can sign the final document. We also assure Your Honor that we are very much
confident that this will be the final request.
Wherefore, I respectfully request that Your Honor extend the time for the parties to file
the Cheeks motion by December 9, 2022
Respectfully submitted,
/s/ Robert Wisniewski
Robert Wisniewski
cc:

via ECF
Brian Gardner, Esq.
Jed Weiss, Esq.
Elizabeth Carbone, Esq.