earner aaa Andrew R. Spector, Partner = Gre □□ a iN Admitted in Florida, New York and Texas RANS Eee Direct phone: 305.537.2002 Direct fax: 305.537.2001 andrew.spector @spectorrubin.com

July 24, 2020 VIA ECF The Honorable Edgardo Ramos United States District Judge Thurgood Marshall U.S. Courthouse M E M O F N D O RS E D 40 Foley Square, Courtroom 619 New York, New York 10007 at page 2. Re: JAS Forwarding (USA), Inc. v. Mediterranean Shipping Company (USA) Inc. and MSC Mediterranean Shipping Company S.A. Case No. 1:19-cv-9741-ER Dear Judge Ramos, The undersigned represents Plaintiff, JAS Forwarding (USA), Inc. (hereinafter “Plaintiff” and/or “JAS”), in the above-referenced case. Pursuant to Your Honor’s Individual Practices 4 1(E), this shall serve as a joint letter-motion requesting a stay of the instant matter, including all deadlines, pending the Parties finalizing a settlement of all claims and counterclaims. The instant letter-motion is submitted jointly along with counsel for Defendants, Mediterranean Shipping Company (USA), Inc. and MSC Mediterranean Shipping Company S.A. (hereinafter “Defendants” and/or “MSC’’), who consent to the relief requested herein. The instant matter arises from the international movement of goods, which were misdelivered to India instead of Brazil. As a result, JAS brings the instant lawsuit against MSC for damages arising from the non-delivery of the cargo to the consignee. In turn, MSC asserts a counterclaim against JAS for detention and demurrage charges. At this time, the Parties are diligently working to amicably resolve the instant matter. To date, the Parties have made considerable progress in resolving this matter; however, the Parties are continuing with efforts concerning the disposition of the cargo in India, which is a central and material aspect of the settlement. Based upon the parties’ understandings, the process with Indian customs for disposing of the cargo could take an additional 3-6 months to complete. Courts have the discretion to stay proceedings pending continuation of settlement negotiations between parties. Cook v. Moran Atlantic Towing Corp.,

(S.D.N.Y. 1977). For all of the reasons set forth herein, the Parties respectfully request a stay of all pending deadlines and the instant matter pending settlement as this will serve the interests of judicial economy. The parties are confident that they will work out a resolution of this case; however, as noted, there is a timing issue with respect to the process for the disposition of the cargo.

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The Honorable Edgardo Ramos United States District Judge July 24, 2020 Page 2 Should your Honor have any questions regarding the foregoing, please do not hesitate to contact our office. Thank you for your consideration in this matter. Respectfully submitted, SPECTOR RUBIN, P.A. Andrew Spector Andrew R. Spector cc: All Counsel of Record (via ECF)

The parties’ request for a stay of all deadlines in this case pending finalization of their settlement is granted. The parties are directed to provide the Court with a status update within six months of the date of this order in the event they do not settle. It is SO ORDERED. tees \), te Edgardo Ramos, U.S.D.J Dated: 7/24/2020 New York, New York

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