UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------------- X MOHAMED ALSHAMI, NADEEM MOHAMMAD, DERRICK TROTMAN, DAVID IRIZARRY, and JEFFREY PAWALL, On behalf of themselves and all others similarly situated No. 24-CV-00569-VSB Plaintiffs, -against- STATE OF NEW YORK, Defendant. --------------------------------------------------------- X NOTICE OF MOTION FOR A STAY PLEASE TAKE NOTICE that, upon the accompanying Memorandum of Law, and all prior pleadings, papers and proceedings herein, defendant the State of New York will move this Court, before the Honorable Vernon S. Broderick, at the United States Courthouse for the Southern District of New York, located at 40 Foley Square, New York, New York, for an order pursuant to Rule 26(c) of the Federal Rules of Civil Procedure staying discovery pending the resolution of the State’s motion to dismiss, and granting such other and further relief as is deemed to be just and proper. Dated: New York, New York May 22, 2024 Respectfully submitted, LETITIA JAMES Attorney General State of New York Attorney for Defendant By: /s/ EVA L. DIETZ Eva L. Dietz Assistant Attorney General 28 Liberty Street New York, New York 10005 (212) 416-6211 [email protected] APPLICATION GRANTED SO ORDERED AJey..." VERNON S. BRODERICK USD. 6/5/2024 Having considered the relevant factors, including whether Defendant has made a “strong showing” that Plaintiffs’ claims are “unmeritorious,” “the breadth discovery and the burden of responding to it,” and “the risk ofunfair prejudice to the party opposing the stay,” Alapaha View Ltd. v. Prodigy Network, LLC, 20-CV-7572,

, at *2 (S.D.N.Y. May 10, 2021), I find that Defendant has met its burden to show good cause why discovery should be stayed. Accordingly, discovery is hereby STAYED pending my decision on the motion to dismiss. The Clerk of Court is respectfully directed to terminate the open motion at Doc. 24.