Figueroa v. ZZ Lashes Inc.

Ny Employment Lawyers Representing bevstayers Exclusively November 16, 2021 | □ Via ECF \ □ \¥ □ Hon. Colleen McMahon \\ United States District Judge Southern District of New York lL) Xv 500 Pearl Street i New York, NY 10007 oh Lt 30 Re: Figueroa v. ZZ LASHES INC. et al. . A 4 | Case No: 1:20-cv-04382 7 i Dear Judge McMahon: y OY This firm represents Plaintiff in the above case. Plaintiff respectfully requests a stay of this action pending final execution of the settlement and dismissal with prejudice, or alternatively, leave to file a non-joint Proposed Pretrial Order. The parties have recently agreed to a settlement, and a final settlement agreement with terms that all parties have agreed to has been sent to Defendant Oberoi for his execution. We anticipate having the fully executed settlement agreement shortly and stipulating to dismiss with action with prejudice within the next few months. Moreover, we sent Defendant Oberoi a draft of the attached Proposed Joint Pre-Trial Order for his edits over forty (40) days ago, and we have been attempting to receive Defendant Oberoi’s edits regarding the attached Proposed Joint Pretrial Order since that time, repeatedly following up with him. We have not received his edits to date. In light of the above, Plaintiff respectfully requests a stay of this action pending final execution of the settlement and dismissal with prejudice, or alternatively, leave to file the nonjoint Proposed Pretrial Order as attached. I thank the Court for its time and attention to this matter. of Be deena RECIAA CRIA Respectfully submitted, feiduive J Lh it /s/ Ishan Dave USDC SDNY DEREK SMITH LAW GROUP, PLLC DOCUMENT ISHAN DAVE ELECTRONICALLY FILED Ishan@dereksmithlaw.com DOC #: —__ 1 Penn Plaza, Suite 4905 : ne 307 New York, New York 10119 DATE —— Phone: (212) 587-0760 CC: All Counsel of Record (Via ECF) NYC Office: One Pennsylvania Plaza, Suite 4905, New York, NY 10119 | (212) 587-0760 Philadelphia Office: 1845 Walnut Street, Suite 1600, Philadelphia, PA 19103 | (215) 391-4790 NJ Office: 73 Forest Lake Drive, West Milford, NJ 07421 | (973) 388-8625 Miami Office: 100 SE 2 " Street. Suite 2000, Miami, FL, 33131 | (305) 946-1884