Markovic v. Milos HY, Inc.

Opinion

—————————————— Brown Kwon & Lam LLP BROWN Attorneys at Law 521 Fifth Avenue, 17th Floor KWON & New York, NY 10175 Tel.: (212) 295-5828 LAM LLP Fax: (718) 795-1642 es Email: info@bkllawyers.com

Writer’s Direct: Angela Kwon, Esq. akwon@bkllawyers.com May 17, 2022 Via ECF Hon. Lewis J. Liman, U.S.D.J. United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 RE: Markovic, et al. v. Milos HY, Inc. d/b/a Estiatorio Milos, et al. Case No. 22-cv-1412 (LJL) Dear Judge Liman: We are counsel for Plaintiffs in the above-referenced action. We write to respectfully request (i) an extension of time to serve the summons and complaint on the individual defendants and (ii) an adjournment of the Initial Conference currently scheduled for May 27, 2022. Since filing the complaint of this matter, we have been in communication with counsel at Jackson Lewis, P.C. who have informed us that they will be representing the two corporate defendants, Milos HY, Inc. and Milos, Inc., in this matter, but not the individual defendants who are currently residing outside of the country. Plaintiffs are in the process of locating the addresses of six individual defendants in order to effectuate service of process under the Hague Convention. Based on the foregoing, Plaintiffs respectfully request a sixty (60) day extension of the deadline to serve the summons and complaint on the individual defendants named in this matter. The current deadline is May 19, 2022, and if the extension is granted, the new deadline would be July 18, 2022. In addition, Plaintiffs respectfully request an adjournment of the Initial Conference currently scheduled for May 27, 2022 at 4:00 p.m. until a date after July 18, 2022. This is the first request for an extension/adjournment. Counsel for the corporate defendants consents to this request. We thank the Court for its time and consideration. Respectfully submitted The motion for the limited extension of time to serve the individual > defendants is granted. See Gerena v. Korb, 617 F.3d 197, 203-04 (2d Cir. /s/ Angela Kwon 2010) (explaining that court has discretion to extend time for service under Angela Kwon, Esq. Federal Rule of Civil Procedure 4(m)). The initial pretrial conference is adjourned to July 22, 2022 at 3:00 p.m. The parties are directed to dial in to the Court's teleconference line at 888-251-2909, Access Code 2123101#. ce: all parties via ECF So cnDeRRD. F Bat « LEWIS J. LIMAN United States District Judpe