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Martin v. Bottom Line Concepts — letter to request an extension of time, Document 40 (filed 04/16/24)

Summary

A letter from Nader Mobargha, co-counsel to Defendant Bottom Line Concepts, LLC, to Judge Paul A. Engelmayer in Case No. 23-cv-08510 (PAE), Qiana Martin v. Bottom Line Concepts, LLC, in the Southern District of New York, Doc. 40, filed 04/16/24. The letter, written jointly with counsel for Plaintiffs, requests an extension to May 14, 2024 of the deadline to respond to the second amended complaint and an adjournment of the initial pretrial conference. It states the Court had earlier rescheduled the pretrial conference to May 3, 2024 [ECF No. 38]. A Court endorsement reading "GRANTED" reschedules the pretrial conference to June 3, 2024 at 10 a.m. and states that no further extensions will be granted.

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“Martin v. Bottom Line Concepts — letter to request an extension of time, Document 40 (filed 04/16/24).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/case-1-23-cv-08510-doc-40-filed-04-16-24-5c5ae3110a/, SHA-256 08c511ff21df876f6899d6c244bec39c091190ec1923a0bf1dd2bead4cb18276.

Full text

              Case 1:23-cv-08510-PAE Document 40 Filed 04/16/24 Page 1 of 2




                                                                       BEYS LISTON & MOBARGHA LLP

                                                                                    Nader Mobargha
                                                                                        646.755.3603 (Direct)
                                                                                     nmobargha@blmllp.com



                                                     April 16, 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 jointly, with counsel for Plaintiffs, 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.

        The pmties previously requested an extension of the deadline for BLC to respond to Plaintiffs SAC
to April 18, 2024, and an adjournment of the initial pretrial conference. The Court granted the request and
rescheduled the pretrial conference to May 3, 2024. [ECF No. 38]

        We respectfully request that the Court extend the deadline for BLC to respond to Plaintiffs SAC to
May 14, 2024, and the initial pretrial conference be adjourned to May 28th, May 29th, May 30th, or May
31st, depending on the Court's availability.

        Good cause supports the requested extension. The undersigned and lead counsel counsel have had
several unexpected deadlines and need additional time to research and respond to the 28-page, 134-
paragraph Complaint. Moreover, the Parties request additional time to confer regarding a Rule 26 repo1t
and engage in further discussions.

       Plaintiffs counsel has consented to the request for an extension and adjournment.

       We appreciate the Court's attention to this matter.


                            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 40 Filed 04/16/24 Page 2 of 2




         Page 2 of 2




                                                 Respectfully,
                                                ,1)ad,u, 7th6
                                                 Nader Mobargha, Esq.
                                                 Co-counselfor Defendant Bottom Line Concepts, LLC

cc: All counsel via ECF

        GRANTED. The Court is unavailable due to a trial on the dates provided by counsel. The
        Comt thus reschedules the pretrial conference in this case to June 3, 2024 at 10 a.m.
        Preconference materials are due two days before. No further extensions will be
        granted.
        SO ORDERED.

        Dated: April 16, 2024                    PAUL A. ENGELMAlfER
               New York, New York                United States District Judge

File and source

File
gov-uscourts-nysd-607132-40-0-pdf_f266eab3817a9784.pdf
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269,230 bytes
SHA-256
08c511ff21df876f6899d6c244bec39c091190ec1923a0bf1dd2bead4cb18276
Our copy
gov-uscourts-nysd-607132-40-0-pdf_f266eab3817a9784.pdf
Original
archive.org
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