New v. JP Morgan Chase, NA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Rob D. New, ) ) Civil Action No. 1:23-cv-09371-DEH Plaintiff, ) ) JP Morgan Chase Bank, N.A. ) PLAINTIFF’S NOTICE OF MOTION ) Defendant. ) TO STAY PROCEEDINGS ) ) ) PLEASE TAKE NOTICE that Plaintiff, Rob D. New, by counsel, respectfully moves this Court for an Order to Stay Proceedings pending the resolution of a Motion to Substitute or Join Plaintiff and Lift Stay currently pending in the United States District Court for the Central District of California. Worldwide Film Productions, LLC v. JPMorgan Chase Bank, N.A., John Torres and Ray Davido, Case No. 2:19-cv-10337-DSF-JPR. This motion is brought pursuant to this Court’s general power to administer its docket. Curtis v. Citbank, N.A., 226 F.3d 133 (2nd Cir. 2000).

In support of this motion, Plaintiff designates the following, which are filed simultaneously herewith: • Plaintiff Rob D. New’s Memorandum of Law in Opposition to Defendant’s Motion to Dismiss this Case or, Alternatively, to Compel Arbitration or Dismiss Pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure and in Support of Plaintiff’s Motion to Stay Proceedings (Section I of the Argument Section). • The Declaration of Jason R. Delk with Exhibits.

Dated: January 30, 2024. Respectfully Submitted, /s/ Jason R. Delk Jason R. Delk (admitted pro hac vice) Daniel J. Gibson (admitted pro hac vice) DELK McNALLY, LLP South Walnut Street Muncie, Indiana 47305 [email protected] [email protected] Attorneys for Plaintiff Deanna Koestel, Esq.

PASHMAN STEIN WALDER & HAYDEN The Woolworth Building Broadway, Suite 820 New York City, NY 10279 Attorneys for Plaintiff Defendant shall file a letter, not to exceed three (3) pages, in response to this letter by Tuesday, February 6, 2024.

The Clerk of Court is respectfully requested to close ECF No. 26.

SO ORDERED.

Dale E. Ho United States District Judge Dated: February 1, 2024 New York, New York