Quezada v. BOSS Art Culture, LLC

LAW OFFICES OF NOLAN KLEIN, P.A. ATTORNEYS & COUNSELORS 112 W. 347! STREET, SUITE 1800 NEW YORK, NY 10016 PH: (646) 560-3230 633 S. ANDREWS AVE., SUITE 500 FORT LAUDERDALE, FL 33301 PH: (954) 745-0588 www.nklegal.com Nolan K. Klein Esq.

[email protected] November 3, 2021

VIA ECF Honorable Sidney H. Stein MEMO ENDORSED United States District Court 500 Pearl Street New York, NY 10007

Re: Quezada v. Boss Art Culture, LLC

SDNY Case No.: 1:21-cv-02143 Dear Judge Stein:

This law firm represents the Defendant, Boss Art Culture, LLC, in connection with the above-captioned matter. An initial pretrial conference is scheduled on November 9, 2021 at 9:00 a.m.

On September 9, 2021, the parties alerted the Court that a settlement in principle had been reached and would file a stipulation of dismissal once the settlement agreement had been fully executed. Counsel for parties are finalizing execution of the agreement and request an additional ten (10) days for a notice of dismissal with prejudice to be filed. Accordingly, the parties request that the initial pretrial conference scheduled for November 9, 2021 be adjourned, or in the alternative, that Defendant’s counsel, who is in Florida, be permitted to appear by telephone for the conference.

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

NKK/amd NOLAN K. KLEIN, ESQ. cc: Mars Khaimov, Esq. (via ECF) The last day to file a notice of dismissal is extended to November 23, 2021. The conference is adjourned to November 23 at 9:00 a.m. The conference will take place as a telephone conference. Th parties shall dial 888-273-3658 and use access code 7004275 to join the conference. Dated: New York, New York

November 3, 2021 SO Sf