Rodriguez v. Edison's Restaurant et al

Filing 33

ORDER granting 32 Letter Motion for Extension of Time to File. APPLICATION GRANTED. If Plaintiff fails to file for default judgment by February 17, 2023, I may dismiss this case for failure to prosecute pursuant to Federal Rule of Civil Procedure 41(b). SO ORDERED.. (Signed by Judge Vernon S. Broderick on 1/17/2023) (kv)

Case 1:22-cv-01909-VSB Document 33 Filed 01/17/23 Page 1 of 1

KATZMELINGER

370 LEXINGTON AVENUE, SUITE 1512
NEW YORK, NEW YORK 10017
www.katzmelinger.com
Eliseo Cabrera
Katz Melinger PLLC

t: 212. 460.0047
f: 212. 428.6811
[e-mail]

January 12, 2023
Via ECF
Honorable Vernon S. Broderick
United States District Court
Southern District of New York
40 Foley Square
New York, New York 10007
Re:

Rodriguez v. Edison Restaurant. et al.
Civil Action No. 22-cv-01909-VSB

01/17/2023
If Plaintiff fails to file for default
judgment by February 17, 2023, I
may dismiss this case for failure to
prosecute pursuant to Federal Rule
of Civil Procedure 41(b).

Dear Judge Broderick:
We represent the plaintiff, Leocadia Rodriguez, in the above-captioned matter, and write
to request an extension of the deadline to file a motion for default judgment, currently set for
January 18, 2023. This is the first such request.
On January 11, 2023 the Court ordered Plaintiff to submit her motion for default judgment
by January 18, 2023. Due to the need to first obtain certificates of default; the need to obtain an
affidavit from Plaintiff, which affidavit will need to be professionally translated; and the federal
holiday on January 16, 2023, we do not believe that we will be able to meet the one-week deadline.
Accordingly, we respectfully request an extension to February 17, 2022, in order to
adequately prepare and file the motion for default.
We thank the Court for its attention to this matter.
Respectfully submitted,
/s/ Eliseo Cabrera
Eliseo Cabrera