Juscinska v. 60 Up, LLC ( 2022 )

LAW OFFICES OF NOLAN KLEIN, P.A. ATTORNEYS & COUNSELORS 112 W. 347 STREET, SUITE 1800 NEW YORK, NY 10120 PH: (646) 560-3230 633 S. ANDREWS AVE., SUITE 500 Nolan Klein, Esq FORT LAUDERDALE, FL 33301 klein@nklegal.com PH: (954) 745-0588 www.nklegal.com April 20, 2022 The application is GRANTED. The initial pretrial conference scheduled for April 27, 2022, at 4:30 p.m., is adjourned to Ma 25, 2022, at 4:30 p.m., on the following conference line: VIA CM/ECF □□ emai th access one oy wey 18, 2022, the Honorable Jude Judge Lorna G. Schofield parties shall file a joint etter and proposed case management Southern District of New York plan. The Clerk of Court is respectfully directed to close the 500 Pearl Street motion at Docket No. 10. New York, NY 10007 Dated: April 21, 2022 Re: — Juscinska v. 60 Up, LLC, etal. New York, New York hath □□□ Ae SDNY Case No.: 1:22-cv-01549 UNITED STATES DISTRICT JUDGE Dear Judge Schofield: This office represents the Plaintiff, Natalia Juscinska, in the above-captioned case. An initial pre-trial conference is scheduled for April 27, 2022 at 4:30 p.m. The parties’ case management plan is due April 20, 2022. To date, Defendants 60 UP, LLC and 301 W. 45 Realty, LLC, have not made an appearance or returned the waivers of service forms that were delivered to them. Accordingly, Plaintiff has proceeded to serve both defendants directly. As such, Plaintiff respectfully requests that this Court adjourn the conference to an alternate date and time to allow time for Defendants to make an appearance. This is the second request for an adjournment of this conference, and the request will not prejudice any parties or affect any other scheduled dates. We thank the Court for your time and consideration in this matter. Respectfully Submitted, Law Offices of Nolan Klein, P.A. By: __/s/Nolan Klein NOLAN KLEIN (NK4223) NKK/amd