RIVKIN RADLER: Www aiVKiNRADLER. COM ATTORNEYS AT LAW 25 Main Street Court PlazaNorth, Suite 501 Hackensack, 07601-7082 T 201.287.2460 F 201.489.0495 Toe DEL P1zz0 The motion to adjourn is GRANTED, and the in (201) 287-2472 pretrial conference is adjourned sine die. Discov nancy. [email protected] is STAYED on consent of the parties pending May 27, 2022 resolution of the motion to dismiss. VIA ECF The Hon. Lewis J. Liman, USS.D.J. SO ORDERED. United States District Court for the . = Southern District of New York ZOMG 500 Pearl Street, Room 701 vai Sls i es New York, New York 10007 Date: May 31, 2022 New York, NY Re: Bernhard Kiihmstedt v. Complex Media, Inc., individually and doing business as “KicksDeals.com,”” and Does 1-10, No.: 1:22-cv-1995 (LJL) C(KHP) Dear Judge Liman: This firm represents defendant, Complex Media, Inc. (‘Complex Media”). We write pursuant to paragraph 1.C. of Your Honor’s Individual Practices in Civil Cases to request adjournment of the upcoming June 10, 2022, initial conference, which the Court scheduled by Order of May 5, 2022 (D.E. 10), and to request a stay of discovery pending resolution of Complex Media’s Motion to Dismiss the Complaint, which was filed on May 13, 2022 and based, among other bases, on there being no redressable injury as required for Article III standing (the “Motion’”’). (D.E. 14). We seek this adjournment and stay such that the parties can preserve resources and not engage in discovery until a decision on the motion is issued. This is the first request for adjournment and stay. Plaintiff consents to this request. Under Fed. R. Civ. P. 26(c)(1), this Court has considerable discretion to stay discovery, and has done so where plaintiff consented pending a resolution on a motion to dismiss. See Fed. R. Civ. P. 26(c)(1); see also Monegro v. Street Insider Dot Com Inc., No.: 21-cv-3339 (LJL),

, at *2 (S.D.N.Y. Feb. 11, 2022) (‘The Court granted request by Defendant, with Plaintiff’ s consent, to stay discovery pending the Court’s decision on this motion to dismiss.”); see also, Integrated Sys. And Power, Inc. v. Honeywell Int’l, Inc., No.: 09-cv-5874,

, at *1 (S.D.N.Y. Sept. 1, 2009) (granting stay of discovery). We thank the Court for its time and consideration. Respectfully submitted, RIVKIN RADLER LLP s/ Nancy A. Del Pizzo Nancy A. Del Pizzo c: Counsel of Record via ECF

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