THE LAW OFFICE OF JUSTIN A. ZELLER, P.C . 

251 WEST 14 T H STREET 

NEW YORK, NY 10011 

PHONE (212) 860-9169 

FAX (917) 421-9387 

JAZELLER@ZELLERLEGAL.COM 

 

 August 23, 2007 

VIA ECF

Hon. William H. Pauley III 

United States District Court 

Southern District of New York 

500 Pearl Street, 

New York, NY 11201 

 Re: SANCHEZ V. BELLCLAIRE

 Docket No.: 06 cv 1781 

Dear Judge Pauley, 

 The undersigned is counsel to plaintiff in the abovereferenced matter. I write to request an extension of time to 

file plaintiff’s motion for collective action certification. 

 The original dates for the motion are as follows: 

8/24/07: Plaintiff shall file its motion; 

9/5/07: Defendant shall file its opposition; 

9/10/07: Plaintiff shall file its reply. 

 The reason for my request is two-fold: (1) I have had 

difficulty obtaining affidavits from my client’s due to 

scheduling conflicts, and (2) the date set by the Court to hear 

oral arguments fall on a Jewish Holiday (the second day of 

Sukkot). 

 This is the first request for such relief and my adversary 

has consented to the adjournment. Attached, please find 

plaintiff’s proposed revised Scheduling Order. The date on which 

the Court will hear oral argument has been left blank. Due to 

the Sukkot holiday, I respectfully request that the Court set a 

hearing date any time after October 5, 2007. I apologize for the 

late request and I thank the Court very much for Its 

consideration. 

Case 1:07-cv-03429-DCF Document 10 Filed 08/23/2007 Page 1 of 4
 Respectfully submitted, 

 Justin A. Zeller 

 Counsel to Plaintiffs 

Case 1:07-cv-03429-DCF Document 10 Filed 08/23/2007 Page 2 of 4
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

---------------------------------------------------------------X 

LAURO SANCHEZ, et. al. : 

 : 

 Plaintiffs, : 

 : 

 -against- : 07 Civ. 3429 (WHP) 

 : 

BELLCLAIRE, INC., a New York Corporation, : Proposed Revised 

and KYUNG LEE, individually, : Scheduling Order

 : 

 Defendants. : 

---------------------------------------------------------------X 

WILLIAM H. PAULEY III, District Judge: 

 1. Plaintiffs shall filed and serve their motion for collective action 

 certification by September 4, 2007; 

 

 2. Defendants shall file and serve their opposition by September 17, 2007; 

 3. Plaintiffs shall file and serve any reply by September 25, 2007; 

 4. This Court will hear oral argument on ________________, 2007 at 

 11:30 a.m.; 

 5. All discovery shall be completed by October 31, 2007. 

 6. The parties shall submit a joint pre-trial order in accordance with this 

 ourt’s individual practices by November 30, 2007; and 

 7. This Court will hold a final pre-trial conference on December 14, 2007 

 at 10:00 a.m. 

 SO ORDERED: 

 ________________________ 

 WILLIAM H. PAULEY III 

 U.S.D.J. 

Counsel of record: 

Justin Alexander Zeller, Esq. 

Case 1:07-cv-03429-DCF Document 10 Filed 08/23/2007 Page 3 of 4
Law Office of Justin A. Zeller, P.C. 

251 West 14th Street, 5th Floor 

New York, NY 10011 

Counsel for Plaintiffs 

Jonathan Y. Sue, Esq. 

Law Office of Jonathan Y. Sue 

1220 Broadway 

Suite 502 

New York, NY 10001 

Counsel for Defendants 

 

Case 1:07-cv-03429-DCF Document 10 Filed 08/23/2007 Page 4 of 4