Mandelbaum &> Salsburg Attorneys at Law | USDC SDNY DOCUMENT ELECTRONICALLY FILED New Jersey e New York e Florida Joel G. MacMull, Partner DOC #: 3 Becker Farm Road [email protected] Roseland, New Jersey 07068 973.295.3652 Direct DATE FILED: 1/1 1/2022 973.736.4600 Main 973.325.7467 Fax 570 Lexington Avenue, 21st Floor New York, New York 10022 212.776.1834 Main www.lawfirm.ms

January 6, 2022

VIA ECF Hon. Alison J. Nathan, U.S.D.J. Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 Re: Young v. Northwest Computer Accessories, Inc. Case No. 21-cv-09071-(AJN)-RWL Dear Judge Nathan, We represent defendant Northwest Computer Accessories, Inc. (“Defendant”) in connection with the above-captioned matter. We write to the Court now, with the consent of plaintiff, to request 30 days to respond or otherwise move against the Complaint. (ECF 1.) Pursuant to Fed. R. Civ. P. 6(b)(1), Defendant submits good cause exists for the requested extension of time. This office was only retained on Tuesday of this week in connection with this matter and, based on a discussion with plaintiff's counsel this morning, the parties are optimistic that they will be able to resolve this matter amicably in the coming days. While plaintiff has filed an affidavit of service which purports to have effectuated service of the Complaint on November 19, 2021 (ECF 6), “Aaron “Doe” was not authorized to accept service on behalf of the Defendant. Ud.) Nevertheless, while this office is aware of the standard set forth in Enron Oil Corp. v. Diakuhara,

(2d Cir. 1993) concerning why a default should not be entered, plaintiff has not filed a motion for a default pursuant to § 3(K) of Your Honor’s Individual

Mandelbaum > Salsburg | Attorneys at Law Practices, has indicated that he does not intend to do so, and is agreeable to the 30 day extension of time being requested. Accordingly, we respectfully submit the requirements set forth in Enron Oil Corp. are not applicable here. In further compliance with § 1(E) of Your Honor’s Practices, Defendant further states as follows: 1.) The original due date for Defendant to respond to the Complaint (assuming arguendo the validity of service) was December 10, 2021; 2.) No prior request for an extension of time to respond to the Complaint has been made; 3.) Defendant respectfully requests an additional thirty (30) days — until February 7, 2022 — to file its Answer or otherwise move. The Court’s continued attention to this matter is appreciated. ee submitted, Ze Nl

ce: All Counsel of Record (via ECF only)

1/11/2022 HON. ROBERT VY. LEHRBURGER UNITED STATES MAGISTRATE JUDGE