Klein v. Jafri

Opinion

(OK Attorneys at Law L’ Abbate, Balkan, Colavita & Contini, L.L.P. 3 Huntington Quadrangle, Suite 1025S, Melville, New York 11747 7.516.294.8844 F.516.294.8202 www.lbcclaw.com T. McCaffery Partner winccaffery @ lbcclaw.com Direct Dial (516) 837-7369 June 20, 2025 Application granted. | do not anticipate granting further Via ECF extensions absent good cause shown. Honorable Robyn F. Tarnofsky . . United States Magistrate Iudge The Clerk of Court is respectfully requested to terminate ECF 8 United States District Court Date: June 23, 2025 50 ORDERED Southern District of New York New York, NY (ls gull we 500 Pearl Street , aN a □ New York, New York 10007 ROBYN F. TARNOFSKY UNITED STATES MAGISTRATE JUDGE Re: David Klein v. Farva Jafri, Jafri Law Firm, Mykola Ishchuk, Esmeralda Famutimi Docket Nos. : 1:24-cv-01649 1:25-cv-03135 Our File No. : 169L-108515 Dear Judge Tarnofsky: The undersigned represents the defendants, Farva Jafri, individually and incorrectly sued herein as Jafri Law Firm, Mykola Ishchuk, and Esmeralda Famutimi, in the above referenced actions. Pursuant to this Court’s Order of May 29, 2025, defendants’ answer in the transferred California action (Docket No. 1:25-cv-03135) is due to be served on Monday, June 23, 2025 and the pre-answer motion to dismiss the original New York action (Docket No. 1:24-cv-01649) is due to be served on Thursday, June 26, 2025. This letter is written to request an extension of time to answer in the transferred California action and to move in the original New York action. Magistrate Judge Ona T. Wang has been assigned to this case for settlement purposes and has scheduled a preliminary settlement conference call for Thursday, June 26, 2025 at 4:00 p.m. It is anticipated that a settlement conference of the case will be scheduled during that conference call. As a settlement conference of this case is likely to be held shortly, it is respectfully requested that defendants’ time to answer in the transferred California action (Docket No. 1:25- cv-03135) and to move in the original New York action (Docket No. 1:24-cv-01649) be extended until seven days after the settlement conference of this case. The extension of time is also requested and required because defendant, Farva Jafri, has been ill and was recently in the hospital. 100 Eagle Rock Avenue, Suite 220, East Hanover, NJ 07936 T. 973.428.4824 F. 973.428.1036

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The undersigned emailed plaintiff’s counsel to seek his consent to this request, but as of the filing of this letter, I have not heard back from plaintiff’s counsel. Thank you for your consideration. Respectfully s itted,

William T. McCaffery cc: Via ECF Carlos Jato, Esq. LAW OFFICE OF CARLOS JATO Attorney for Plaintiff

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