Meyer v. The Literal Co.

Opinion

ROMANO A d LAW Davidf@ RomanoLaw.com One Battery Park Plaza, 7th Floor (212) 865-9848 New York, NY 10004

April 24, 2024 VIA ECF MEMO ENDORSED Hon. Jessica G. L. Clarke, U.S.D.J. United States District Court Southern District of New York 500 Pearl Street, Room 1040 New York, NY 10007 Re: Meyer, et al. v. The Literal Co., et al., Case No. 23-cv-06539 (JGLC) Dear Judge Clarke: This firm represents Defendants in the above-referenced matter. Pursuant to Rule 2.e. of this Court’s Individual Rules and Practices, the parties respectfully and jointly request a seven day extension of the deadline to submit to the Court the terms of the parties’ settlement agreement and joint letter explaining the settlement’s fair and reasonable compromise of the disputed issues at hand pursuant to Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199, 200 (2d Cir. 2015). While the parties request a seven-day extension, we anticipate submitting the agreement for approval by Friday, April 26, 2024. The deadline for submission of the parties’ settlement agreement and explanation letter for approval is April 24, 2024. The parties extend their sincere apologies for again requesting an extension within the 48 hour deadline set by the Court’s Individual Rules, and respectfully request that the Court extend the deadline by seven additional days, to May 1, 2024. This is the parties’ third and final request for an extension of time. This Court granted the parties’ previous joint requests. The reason for this extension request is that, while the parties have substantially reached agreement, slightly more time is needed to coordinate signatures between the parties and complete the joint letter motion for approval. The parties are available should the Court have any further questions. Respectfully submitted,

THE SIEGEL LAW FIRM, P.C. ROMANO LAW PLLC By: ___/s/ Bradley R. Siegel By: _/s/ David M. Fish Bradley R. Siegel, Esq. David M. Fish Bradley R. Siegel, Esq. David M. Fish

591 Stewart Avenue, Suite 550 Andrew C. Ramstad Garden City, New York 11530 One Battery Park Plaza, 7th Floor (516) 558-7559 New York, NY 10004 bradley @ thesiegellawfirm.com (212) 865-9848 davidf @romanolaw.com Attorneys for Plaintiffs andrew @romanolaw.com Attorneys for Defendants

Application GRANTED. The parties shall file their submission by April 26, 2024. No further extension: shall be granted. The Clerk of Court is directed to terminate ECF No. 55. SO ORDERED. □□ p C Ye aica Larke ( JESSICA G. L. CLARKE United States District Judge

Dated: April 25, 2024 New York, New York