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Request for Extension of Time and Adjournment — Martin v. Bottom Line Concepts (Doc. 38)

Summary

A letter dated March 22, 2024 to the Honorable Paul A. Engelmayer in Qiana Martin v. Bottom Line Concepts, LLC, Case No. 23-cv-08510 (PAE), in the United States District Court for the Southern District of New York, Document 38. Nader Mobargha of Beys Liston & Mobargha LLP, co-counsel to the defendant, requests that the deadline to respond to the second amended complaint be extended to April 18, 2024 and that the initial pretrial conference be adjourned. The letter states that the plaintiff's counsel has consented and that there was one previous request for an extension. An endorsement on the letter reads GRANTED and reschedules the initial pretrial conference to May 3, 2024 at 2:00 p.m.

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Archived web capture. Preserved source — captured from archive.org; archived 2026-09-26.

Cite this document

“Request for Extension of Time and Adjournment — Martin v. Bottom Line Concepts (Doc. 38).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/case-1-23-cv-08510-doc-38-filed-03-22-24-8f6eac2788/, SHA-256 965ce735d7fc15d25c4c2eb1be2301501e92453c258f719112d7c7d4710c2223.

Full text

               Case 1:23-cv-08510-PAE Document 38 Filed 03/22/24 Page 1 of 2




                                                                              BEYS LISTON & MOBARGHA LLP


                                                                                        Nader Mobargha
                                                                                          646.755.3603 (Direct)
                                                                                        nmobargha@blmllp.com



                                                      March 22, 2024

BYECF
The Honorable Paul A. Engelmayer
United States District Court for the Southern District of New York
40 Foley Square, Room 2201
New York, NY 10007

       Re:     Case No. 23-cv-08510 (PAE), Qiana Martin, on behalf of herself and all others similarly
               situated v. Bottom Line Concepts, LLC

Dear Judge Engelmayer:

       We are co-counsel to Defendant Bottom Line Concepts, LLC ("BLC") in the above-captioned
proceeding and write to request an extension of time to respond to Plaintiff Qiana Martin's ("Plaintiff")
second amended complaint (the "SAC") and an adjournment of the initial pretrial conference.

       Based on the Court's March 14, 2024 Opinion and Order regarding Defendant's motion to dismiss
Plaintiffs first amended complaint (the "FAC") [ECF No. 35], Defendant must respond to Plaintiffs SAC
by March 28, 2024.

       By Order of the same date [ECF No. 36], the Court scheduled an initial pretrial conference for April
2, 2024.

         In light of the fact that lead counsel for BLC is traveling the next two weeks, and the parties would
like the opportunity to try to resolve the case through informal, extrajudicial resolution, we respectfully
request that the deadline for BLC to respond to Plaintiffs SAC be extended to April 18, 2024, and the
initial pretrial conference be adjourned to May 3'd, May 6'\ May 7th or May 8th . The parties acknowledge
that in accordance with the Court's Individual Rules, they will prepare a Civil Case Management Plan and
Scheduling Order, as well as a joint letter setting forth a brief description of the case, any contemplated
motions, and the prospect for settlement, at least four (4) business days prior to the conference date.




                             641 Lexington Avenue, 14th Floor, New York, NY 10022
                                     Main: 646.755.3600 • Fax: 646.755.3599
                                               www.blmllp.com
              Case 1:23-cv-08510-PAE Document 38 Filed 03/22/24 Page 2 of 2




          Page 2 of 2

      There was one previous request for an extension of time with respect to the briefing schedule for
Defendant's motion to dismiss Plaintiff's FAC.

       Plaintiff's counsel has consented to the request for an extension and adjournment.

       We appreciate the Court's attention to this matter.

                                                     Respectfully,

                                                     Isl Nader Mobargha
                                                     Nader Mobargha, Esq.
                                                     Co-counsel for Defendant Bottom Line Concepts, LLC

cc: All counsel via ECF



  GRANTED. The initial pretrial conference is rescheduled to May 3, 2024 at 2:00 p.m. Dial-in
  information remains the same as stated in the Court's prior order.

  SO ORDERED.

  Dated: March 22, 2024                       PAULA.ENGELMAYE
         New York, New York                   United States District Judge

File and source

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gov-uscourts-nysd-607132-38-0-pdf_f839fe49b7d42074.pdf
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208,669 bytes
SHA-256
965ce735d7fc15d25c4c2eb1be2301501e92453c258f719112d7c7d4710c2223
Our copy
gov-uscourts-nysd-607132-38-0-pdf_f839fe49b7d42074.pdf
Original
archive.org
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