Enrique Africa, individually and on behalf of all others similarly situated v. Jianpu Technology Inc.

Opinion

Ex Kano S. San G | an cy esams@glancylaw.c Pp ron g ay 1925 Century Park East, Suite 2 Los Angeles, CA 90 & Mu rray ue 810.201 9

October 13, 2022 VIA ECF The Honorable Jesse M. Furman Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 Re: = Enrique Africa v. Jianpu Technology Inc. et al., Case No. 1:21-cv-01419-JMF Dear Judge Furman: We represent Lead Plaintiff Enrique Africa (“Plaintiff”) in the above-referenced action. We write regarding the Court’s September 28, 2022 Opinion and Order (“Order”), in which the Court granted Defendants’ motion to dismiss Plaintiff’s operative complaint with leave to amend. I. INTRODUCTION Within the Court’s Order, the Court stated that Plaintiff shall file any amended complaint within thirty days of the date of the Order, which would be on or before October 28, 2022. In accordance with Paragraphs 2(E) and 4(A) of the Court’s Individual Rules and Practices in Civil Cases, Plaintiff submits this letter-motion to respectfully request an extension of 30 days to file an amended complaint pursuant to the Court’s Order. Il. ARGUMENT Plaintiff respectfully requests an extension because Counsel for Plaintiff currently have several matters with intervening obligations that would conflict with the current deadline in this matter. Such matters include, but are not limited to, drafting a reply brief for a motion for class certification due October 18, 2022, preparation for a hearing on October 20, 2022, drafting an appellate brief due on November 10, 2022, drafting an amended complaint in one matter due October 28, 2022, and drafting an amended complaint in another matter with a deadline of December 13, 2022. One attorney of record also recently had a death in the family which required his travel to services on October 10th and 11th. Plaintiff has not previously requested an extension

The Honorable Jesse M. Furman October 13, 2022 Page 2 with respect to this amended complaint, there is no current scheduled appearance before the Court, and there are no other existing deadlines. Courts, moreover, have commonly granted such requests. See, e.g., DeJesus-Vasquez v. Bethencourt, No. 19-CV-967 (KMK), 2021 WL 3540553, at *1 (S.D.N.Y. Aug. 10, 2021) (noting that “the Court granted Plaintiffs request for an extension of time” to file an amended complaint and that the Court subsequently “provided Plaintiff a further extension of time”); Muhammad v. Annucci, No. 19CIV3258GBDOTW, 2020 WL 1303571, at *4 (S.D.N.Y. Mar. 19, 2020) (‘Plaintiff filed a letter requesting an extension of time to file his amended complaint .. . . his request for an extension of time to file an amended complaint . . . is GRANTED.”). Counsel for Plaintiff has conferred with counsel for Defendants regarding this request, and counsel for Defendants stated that Defendants take no position on this request. Ill. CONCLUSION Accordingly, Plaintiff respectfully requests a deadline of Monday, November 28, 2022 to file an amended complaint (a 30-day extension deadline would fall on Sunday, November 27, 2022). We thank the Court very much for considering this request.

Application GRANTED. The Clerk of Court is Very truly yours, directed to terminate ECF No. 62. s/Ex Kano S. Sams IT ORDERED G Ex Kano S. Sams II

ctober 14, 2022