LAW OFFICES OF NOLAN KLEIN, P.A. ATTORNEYS & COUNSELORS

STREET, SUITE 1800 NEW YORK, NY 10120 PH: (646) 560-3230 633 S. ANDREWS AVE., SUITE 500 FORT LAUDERDALE, FL 33301 PH: (954) 745-0588 www.nklegal.com Nolan Klein, Esq. [email protected] May 18, 2022 VIA CM/ECF Honorable Judge Ronnie Abrams Southern District of New York 40 Foley Square, Room 2203 New York, NY 10007 Re: Mercer v. 939 First Ave. Liquors, Inc., et al. SDNY Case No.: 1:22-cv-01978-RA Dear Judge Abrams: This office represents the Plaintiff, Stacey Mercer, in the above-captioned case. An initial pre-trial conference is scheduled for May 26, 2022 at 11:00 a.m. The parties’ case management plan is due May 20, 2022. To date, Defendants 939 First Ave. Liquors, Inc. d/b/a Fine Wines on First and First Ave 945 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 first 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, scheduled for May 26, 2022 is adjourned sine Court will set a new date for the conference once Law Offices of Nolan Klein, P.A. have been served and have appeared in this action. shall promptly file proof of service on the docket. By: __/s/Nolan Klein NOLAN KLEIN (NK4223)

Ronnie Abrams 19, 2022