—¥ | SHAMIS & GENTILE, P.A. GLASS ACTION LAW FIRM

ny Shamis & Gentile, P.A.

* Ave, Suite 1205 * Miami, FL 33132 Telephone 305-479-2299 « Fax 786-623-0915 November 26, 2024 ee VIA ECF / po qa tt □ Honorable P. Kevin Castel 4 beet United States District Judge form wh A Southern District of New York } sf Oe Daniel Patrick Moynihan wel cs aa ef) United States Courthouse Vee ar Gee 500 Pearl Street . © Fh, □ SDs New York, New York 10007-1312 Ge 4 rl / Gb □□ fo □ Re: Ballesteros v. Ambulnz NY, LLC, Case No. 1:24-cv-06366-PKC | | Dear Judge Castel rat -te! ANY- FERN ear Judge Castel: . ° Meetiny 2305 B10 34 70% We represent Plaintiff Maria Ballesteros in the above-referenced action. In accordance with Your Honor’s Individual Practices in Civil Cases, Section 1.C, we write to respectfully request that the Initial Pretrial Conference, set for December 9, 2024 at 10:30 AM, be briefly adjourned to December 19, 2024. See ECF No. 9 As per the Court’s Order, the Parties are required to submit a Case Management Plan immediately prior to the Initial Pretrial Conference on December 9. ECF No. 5. The Parties are currently scheduled for a full-day private mediation on December 5, 2024. The Parties have been engaged in substantial efforts to facilitate an effective mediation and are optimistic on the potential for resolution at mediation, or shortly thereafter. In light of the respective schedules of counsel, the Parties believe it most efficient to focus their efforts toward resolution of the case at this time. The brief ten-day adjournment requested is not sought for purposes of delay but will instead afford the Parties meaningful time to confer regarding an appropriate discovery plan should mediation be unsuccessful, Alternatively, should the Court wish to proceed with the December 9 conference, the Parties respectfully request that the deadline to submit a Case Management Plan be extended until after the conference (and to be discussed during the conference). The Parties are happy to appear before the Court on December 9 to discuss their progress in mediation the respective pre-motion

: SHAMIS & GENTILE, PLA. CLASS ACTION LAW FIRM

pl ili i SS Shamis & Gentile, P.A.

* Ave, Suite 1205 * Miami, FL 33132 Telephone 305-479-2299 * Fax 786-623-0915 letters regarding Defendant's anticipated Motion to Dismiss, and any other issues the Court deems pertinent, but respectfully request relief from the requirement of submitting a proposed case management plan beforehand. Defendant previously requested an adjournment of its time to respond to the Complaint, including a request to adjourn the Initial Pretrial Conference as required by Your Honor’s Individual Practices in Civil Cases Section 1.C(vii) on September 9, 2024. The Court granted Defendant’s request on September 10, 2024, adjourning the Initial Pretrial Conference to the current date of December 9, 2024. The Parties also submitted a stipulation staying the case pending mediation, but the Court denied that request without prejudice until after the Initial Pretrial Conference. Plaintiff’s counsel has consulted with counsel for Defendant, who consents to the relief requested herein.

Respectfully submitted, By: Andrew Shamis Andrew J, Shamis (NY Bar #5195185) SHAMIS & GENTILE, P.A. 14 NE ist Avenue, Suite 400 Miami, FL 33132 Telephone: 305-479-2299 [email protected]

cc: Counsel of Record (via ECF)