Morales v. Performance Master, Inc.
Opinion
gains Bell Law Group, PLLC Ly a 116 Jackson Avenue a Syosset, New York 11791 T (516) 280-3008 F (516) 706-4692 BellLG.com February 16, 2024 Via ECF The Honorable Arun Subramanian United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Morales, et al. v. Performance Master, Inc. et al. Civil Docket No.: 21-cv-00097-ER Dear Judge Subramanian: Our office represents Defendants J.D.M. Marmol & Granite and Marcos Zhiminaicela in the above-referenced matter. This letter is submitted to respectfully request a one-week extension to February 23, 2024, to submit Defendants’ Reply. The basis for this request is that the undersigned is leaving the firm and new counsel is being assigned to the matter. Further, Plaintiffs did not provide the exhibits for their opposition at any time prior in discovery but only upon submitting their opposition to summary judgment to which we require additional time to review and discuss the same with Defendants. We kindly thank Your Honor for your consideration of this request. Very truly yours, /s/ Matthew Madzelan Matthew Madzelan, Esq. SO ORDERED. Arun Subramanian, U.S.D.J. Date: February 16, 2024 5 Penn Plaza, 23 Floor 1629 K Street, NW, Suite 300 10750 NW 6" Court New York, NY 10001 Washington, DC 20006 Miami, FL 33168
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