i] Attorneys at Law 45 BROADWAY, SUITE 430, NEW YORK, NEW YORK 10006 TEL: (212) 248-7431 FAX: (212) 901-2107 WWW.NYCEMPLOYMENTATTORNEY.COM A PROFESSIONAL LIMITED LIABILITY COMPANY July 7, 2022 VIA ECF The Honorable Jesse M. Furman United States District Judge United States District Court Southern District of New York 40 Foley Square, Room 1105 New York, NY 10007 Re: Helen Rosales v. Popeyes Louisiana Kitchen, Inc., et al. No. 1:22-cev-01150-JMF Dear Judge Furman: This office represents Plaintiff Helen Rosales in the above-referenced matter. Plaintiff writes to respectfully request the Court to stay the fact discovery deadline in this matter. Defendant’s counsel has been advised of the circumstances of this request and consents to the stay of discovery. The Parties participated in the Mediation Program with this Court and thereafter, again attempted to reach settlement amongst attorneys, accounting for a slight delay in this request. Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, a court has the discretion to grant a motion to stay discovery for “good cause.” Nix v. Hilton Hotels Corp.,

(S.D.N.Y. Feb. 15, 2007). In early June 2022, Plaintiff was accepted into the U.S. Marines, took an Oath of Enlistment, and was scheduled for Recruit Training (“Boot Camp”), which began on July 5, 2022. While at Boot Camp, Plaintiff does not have access to phone, internet, and will not otherwise be able to communicate with her counsel for approximately three months, until on or about September 30, 2022. Thereafter, Plaintiff will attend Combat Training until November 1, 2022. Please see Plaintiff's Enlistment Letter attached. Accordingly, Plaintiff respectfully requests that the Court stay the fact discovery deadline in this matter from the current deadline of September 22, 2022 until November 1, 2022, at which time Plaintiff can resume communication with her counsel. We thank Your Honor for your consideration of this request.

Respectfully yours, Morgaw Mickelsew Brittany A. Stevens, Esq. Morgan Mickelsen, Esq. Attorneys for Plaintiff Phillips & Associates, PLLC 45 Broadway, Suite 430 New York, New York 10006 bstevens @tpglaws.com mimickelsen @tpglaws.com To: — All counsel of record (Via ECF)

Application GRANTED. The pretrial conference currently scheduled for October 5, 2022, is hereby ADJOURNED to November 9, 2022, at 3:30 p.m. The Clerk of Court is directed to terminate ECF No. 35. SO ORDERED. Ope 8, 2022