M MARK DAVID SHIRIAN P.c. ATTORNEYS AT LAW

MARK DAVID SHIRIAN P.C. 228 EAST 45™ STREET, SUITE 1700-B NEw YORK, NY 10017 TEL: (212) 931- 6530 FAX: (212) 898 - 0163 WWW.SHIRIANPC.COM MARK D. SHIRIAN [email protected] July 12, 2023 VIA CM/ECF Hon. Jennifer L. Rochon, U.S. District Judge U.S. District Court for the Southern District of New York 500 Pearl Street, Room 1920 New York, NY 10007 Re: Tzur v. Henkel of America, Inc. et al Civil Case No.: 1:23-cv-02923 Dear Judge Rochon: My office represents Plaintiff Mira Tzur. I write to respectfully request a 30-day extension of time from July 17, 2023 to August 17, 2023 in order respond to Defendants’ motions to dismiss (Document Nos. 19 and 21), which is presently due on July 17, 2023. I make this request because the parties are scheduled to appear for a settlement conference on July 24, 2023 before Magistrate Judge Jennifer E. Willis. The Defendants do not object to this request. Additionally, the Defendants respectfully request two weeks to submit replies, which would be due on August 31, 2023. The Plaintiff does not object to this request. Additionally, the parties are scheduled to appear for an Initial Pretrial Conference on August 1, 2023. The parties respectfully request an adjournment of the Initial Pretrial Conference, in light of Defendants’ motions to dismiss, which are presently pending. Thank You for Your consideration of this request. Respectfully submitted, N--E— Mark D. Shirian ce: All attorneys of record (via ECF service) request to extend the deadline to respond to Defendants' motions to dismiss is granted. Plaintiff shall respond no later th 17, 2023. The request to adjourn the Initial Pretrial Conference is granted in part. The filing of a motion to dismiss | automatically stay discovery, nor does it always constitute good cause to stay discovery. See, e.g., Hong Leong Fin. Ltd. v. Pinnacle Performance Ltd.,

(S.D.N.Y. 2013). The parties may make a motion, or indicate 1 to a stay, prior to the Initial Pretrial Conference. In light of the settlement conference at the end of July, the August | Initial Pretrial Conference is adjourned to August 16, 2023 at 11:30 a.m. SO ORDERED. 7) vy?) az