Charles v. Pinnacle Too, LLC et al

Filing 158

ORDER granting 157 Letter Motion for Extension of Time to File. The extension request is GRANTED. Motions for summary judgment are now due by December 9, 2024, responses are due by December 27, 2024, and replies are due by January 13, 2025. SO ORDERED. (Signed by Magistrate Judge Jennifer E. Willis on 10/24/2024) (tg)

LEE LITIGATION GROUP, PLLC
148 WEST 24TH STREET, EIGHTH FLOOR
NEW YORK, NY 10011
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WRITER’S DIRECT:

212-465-1188
[e-mail]

VIA ECF
The Honorable Jennifer E. Willis, U.S.M.J.
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re:

October 23, 2024

Charles v. Pinnacle Too, LLC., et al.
No. 22-CV-4232 (DEH)(JW)

Dear Judge Willis,
We are counsel to Plaintiff in the above-captioned matter and write jointly with counsel to
Defendants to request an extension of the deadline to move for summary judgment and to propose
a briefing schedule. This letter is submitted pursuant to section 1(C) of Your Honor’s Individual
Rules.
Pursuant to Your Honor’s Order, dated June 4, 2024 (Dkt. 146), motions for summary
judgment are due 30 days following rulings on Plaintiff’s Motion for Final Collective Certification
(Dkt. 84) and Defendants’ Motion to Decertify Plaintiff’s Conditionally Certified Collective
Action (Dkt. 116).
On September 30, 2024, the Court granted Plaintiff’s motion for Class Certification of the
New York Labor Law ("NYLL") claims, pursuant to Rule 23 of the Federal Rules of Civil
Procedure, and in doing so denied as moot Plaintiff’s motion for Final Collective Certification.
(Dkt. 155). By that Order, Defendants’ class list is due by October 30, 2024. On October 15, 2024,
the Court entered an Order denying as moot Defendants’ Motion to Decertify the Conditionally
Certified Class. (Dkt. No. 156).
Motions for summary judgment are currently due on November 14, 2024. The parties
request to extend the deadline to move for summary judgment and propose the following briefing
schedule:
The extension request is GRANTED.
Motions for summary judgment are now
due by December 9, 2024, responses
are due by December 27, 2024, and
We thank the Court for considering this request. replies are due by January 13, 2025.
SO ORDERED.
Respectfully submitted,
Motions by December 9, 2024
Oppositions by December 27, 2024
Replies by January 13, 2025

/s/ C.K. Lee
C.K. Lee, Esq.
cc: all parties via ECF

__________________________________
JENNIFER E. WILLIS
UNITED STATES MAGISTRATE
JUDGE
October 24, 2024