Morales v. Fross, Zelnick, Lehrman & Zissu, P.C. et al

Filing 23

ORDER granting 22 Letter Motion for Extension of Time to File. Application granted. The parties are directed to file settlement documents, including a Cheeks fairness letter, by December 3, 2021. The Clerk of the Court is respectfully directed to terminate the motion sequence pending at Doc. 22. SO ORDERED. (Signed by Judge Philip M. Halpern on 11/18/2021) (jca)

Case 7:21-cv-04509-PMH Document 23 Filed 11/18/21 Page
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Case 7-21-cv-04509-PMH Document 22 Filed in NYSD on 11/17/20211 ofPage 1 of 2

Application granted. The parties are directed to file
settlement documents, including a Cheeks fairness letter,
by December 3, 2021.

225 Broadway, Suite Court is respectfully directed to terminate
The Clerk of the 1405
New York, Newsequence pending at Doc. 22.
the motion York 10007
T: [phone] F: [phone]
dsblawny.com
SO ORDERED.
William J. Dealy (1946-2012)
Milo Silberstein
Marc D. Braverman
Laurence J. Lebowitz

_______________________
Philip M. Halpern
United States District Judge
Dated: White Plains, New York
November 18, 2021

VIA ECF

Amanda E. Maguire
Maria Louisa Bianco
Erica J. Weser
Albert J. Soler
Of Counsel

November 17, 2021

The Hon. Philip M. Halpern
United States District Judge
Southern District of New York
Federal Building and Courthouse
300 Quarropas Street, Room 530
White Plains, NY 10601
Re:

Morales v. Fross, Zelnick, Lehrman & Zissu, P.C., et al.
Case No. 7:21-cv-04509-PMH

Dear Judge Halpern:
This firm represents Defendants Fross Zelnick Lehrman & Zissu, P.C., Leo Kittay, James
D. Weinberger and Terry Raphael (collectively, “Defendants”) in connection with the abovereferenced matter. This letter is written jointly with Plaintiff’s counsel.
Pursuant to Your Honor’s Order dated November 1, 2021, the parties were directed to file
the settlement documents resolving Plaintiff’s claims under the Fair Labor Standard Act and
New York Labor Law, including a Cheeks fairness letter, by November 19, 2021. The parties
have been working diligently to negotiate and draft the settlement documents. However, in order
to permit the parties to finalize and execute the settlement documents, and to provide Plaintiff
with the consideration and revocation periods to which she is entitled under the Age
Discrimination in Employment Act, the parties are respectfully requesting a brief two (2) week
extension of the Court’s deadline to December 3, 2021.
This is the parties’ first request for an extension of time to submit the settlement
documents.

Long Island Location: 24 Summit Boulevard, Westhampton, New York 11977 - T: [phone]

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We thank the Court for its consideration of this request.
Respectfully submitted,
/s/
Marc D. Braverman
MDB/am
cc:
Trevor Brice, Esq. (via ECF)

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