j i USDC SDNY 21st Fl 1251 Avenue of the Americas la Davis Wrignt DOCUMENT J Tremaine tip ELECTRONICALLY FILED Now York, Ny tooaeniss DOC #: Carl Mazurek eee a ania (212) 402-4069 tel [email protected] Application granted in part. The date for the parties to file January 12, 2024 , the materials currently due on January 16, 2023 is VIA ECF adjourned sine die. The telephonic conference on January 23, 2024 will go forward so that the Court may Hon. Robert W. Lehrburger discuss the case with the parties. Discovery is stayed at United States Courthouse least until and through the scheduled conference. Southern District of New York SO ORDERED: 500 Pearl Street, Room 1960 Je-— New York, NY 10007 AM2I20246 FO HON. ROBERT W. LEHRBURGER UNITED STATES MAGISTRATE JUDGE Re: Pryimachenko v. Home Box Office, Inc., et al. (Case No. 1:23-cv-10034) Dear Judge Lehrburger, We represent Defendant Home Box Office, Inc. (“HBO”) in the above-captioned action. Pursuant to Rule III-B of Your Honor’s Individual Practices in Civil Cases, we write to respectfully request that the Court enter a stay of discovery in this matter pending resolution of HBO’s anticipated motion to dismiss Plaintiff Adrii Pryimachenko’s (“Plaintiff”) First Amended Complaint. HBO also respectfully asks that the Court adjourn the January 16, 2024 deadline for the parties to file a joimt letter and proposed Case Management Plan, and adjourn the initial scheduling conference set for January 23, 2024, until after the Court has resolved HBO’s motion to dismiss. Plaintiff agrees to all of these requests, and this is the first time such relief has been sought. “Upon a showing of good cause[,| a district court has considerable discretion to stay discovery pursuant to Rule 26(c).” Republic of Turkey v. Christie’s, Inc.,

(S.D.N.Y. 2018) (citation and alterations omitted); see also Arungwa v. Brennan et al., No. 1:17-cv-09586-GHW, Dkt. 26 (S.D.N-Y. 2018) (granting letter motion for stay of discovery until resolution of defendant’s motion to dismiss). Here, a stay would not prejudice any party: not only has Plaintiff consented to the stay, but it would serve the interest of efficiency because it would allow the parties to avoid expending substantial resources on discovery prior to the Court’s resolution of HBO’s motion to dismiss. We thank the Court for its consideration of this submission.

Respectfully, DAVIS WRIGHT TREMAINE LLP {s/ Carl Mazurek Carl Mazurek

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