On April 25, 2025, a pre-motion conference was held before Judge Frederick Block, during

Summary

A letter dated May 22, 2025 and filed as Document 33 in Kolbert v. Benworth Capital Partners, LLC et al., Case 1:25-cv-00117-FB-CHK, in the U.S. District Court for the Eastern District of New York, addressed to Magistrate Judge Vera M. Scanlon. Counsel for Plaintiff William Kolbert asks, on consent of all parties, to adjourn the in-person initial conference set for June 5, 2025 and the proposed discovery plan due May 27, 2025. The letter states that at an April 25, 2025 pre-motion conference Judge Frederick Block gave the plaintiff three weeks to file a final amended complaint and stayed the case until then, and that the amended complaint was served May 16, 2025 (ECF Doc No. 32). It asks that all scheduled dates be extended until motions are fully briefed.

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Case 1:25-cv-00117-FB-CHK             Document 33 Filed 05/22/25               Page 1 of 1 PageID #:
                                             1012                                                       Serge F. Petroff
                                                                                                       *Steven Amshen
                                                                                                         James Tierney
                                                                                                           Jill Schaefer
                                                                                                          Maria Garber
                                                                                        (*admitted in New York & New Jersey)



                                            May 22, 2025

VIA ECF
Hon. Vera M. Scanlon
United States Magistrate Judge
Eastern District of New York
225 Cadman Plaza East
Brooklyn, New York, 11201

               Re:     Kolbert v. Benworth Capital Partners, LLC et al.,
                       Case No. 1:2025-cv-00117-FB-VMS

Dear Judge Scanlon:

        This office represents Plaintiff William Kolbert in this matter. Plaintiff, on consent of all
the parties, is respectfully requesting an adjournment of the in-person initial conference currently
scheduled for June 5, 2025 at 11:30 a.m., as well as the proposed discovery plan, which is currently
due on May 27, 2025.

         On April 25, 2025, a pre-motion conference was held before Judge Frederick Block, during
which the Plaintiff was granted three (3) weeks to serve and file a final amended complaint.
Contemporaneously and within the same order, the case was “stayed until the plaintiff serves and
files his final amended complaint.” Plaintiff served its amended complaint of May 16, 2025 (See
ECF Doc No. 32). The matter will now proceed to motion practice, as defendants indicated that
they will file their pre-motion conference letters in accordance with the aforementioned order.

        Accordingly, it is respectfully requested that all currently scheduled dates be extended until
all motions are fully briefed.

       I thank the Court for its courtesy in considering this request.


                                                Respectfully submitted,

                                                /s/ Serge F. Petroff
                                                Serge F. Petroff, Esq.


cc:    All counsel via ECF




                     1795 Coney Island Avenue, Third Floor, Brooklyn, New York 11230
                               Phone: (718) 336-4200 | Fax: (718) 336-4242


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