GreenbergTraurig Request GRANTED. Defendants shall answer or otherwise Sylvia E. Simson respond to the Complaint no later than February 21, 2025. The Tel 212.801.9200 tone : Sylvia [email protected] initial pretrial conference currently scheduled for February 6, 2025, shall be adjourned to March 13, 2025, at 10:00 a.m. January 21, 2025 Dated: January 22, 2025 SO ORDERED. New York, New York © Ne VIA ECE dealer Khare United States District Judge Hon. Jennifer L. Rochon United States District Court for the Southern District of New York 500 Pearl Street, Room 20B New York, NY 10007 Re: = iMerchant, Inc. v. JPMorgan Chase & Co, et al. No. 1:24-cv-09727-JLR— JPMorgan Chase Bank, N.A.’s Consent Request For Extension of Time to Respond to Complaint and Consent Request For Adjournment of Initial Conference Dear Judge Rochon: My firm is counsel for defendant JPMorgan Chase Bank, N.A. (“Chase”) in the above- captioned action, which was removed to this Court on December 17, 2024.! Pursuant to Rule 1(F) of Your Honor’s Individual Rules of Practice in Civil Cases, Chase writes to request: (1) an extension of time to respond to the Complaint from the current deadline of January 23, 2025 to February 21, 2025, and (2) an adjournment of the Initial Pretrial Conference currently scheduled for February 6, 2025 to a date that post-dates Chase’s new deadline to respond to the Complaint and is convenient to the Court. Counsel for plaintiff 1Merchant, Inc. has consented to both requests herein. This is Chase’s second request for an extension of its time to respond to the Complaint and its first request for an adjournment of the Initial Pretrial Conference. Both requests set forth herein are sought so Chase can assess the allegations in the Complaint and determine its response. The Court previously granted Chase’s first request for an extension of time to respond to the Complaint on December 19, 2024 before the holiday period. Other than the Initial Pretrial Conference (which Chase requests be adjourned to post-date its response to the Complaint), there is no other deadline or scheduled appearance before the Court that such an extension would affect. We appreciate the Court’s attention to this matter and are available should the Court have any questions.

' As Chase asserted in its Notice of Removal, its co-defendant JPMorgan Chase & Co. is not a proper party to this action. See Doc. No. 1 §§ 17-19; see also Russell y. Citigroup, No. 22-CV-2057,

, at **4-5 (E.D.N.Y. Feb. 24, 2023) (“Courts have routinely held that no cause of action can be maintained against a bank’s holding company based on [alleged] misconduct by its bank subsidiary”). Unless claims against this entity are voluntarily dismissed, the requested extension herein would apply to it as well. Greenberg Traurig, LLP | Attorneys at Law One Vanderbilt Avenue | New York, New York 10017 | T +1 212.801.9200 | F +1 212.801.6400 www.gtlaw.com

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Respectfully submitted, /s/ Sylvia E. Simson Sylvia E. Simson CC (by ECF): All counsel of record