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)

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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: (212) 267-2101 • WEB: 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.

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