USD SUN I □□ DOCUMENT YAAKOV SAKS □ ELECTRONICALLY FILED JUDAH STEIN®= DOC #: ELIYAHU BABAD4: DATE FILED: _8/6/2025 RAMI M. SALIM“* . MEMORANDUM ENDORSED STEIN | SAKS, PLLC

One University Plaza, Suite 620, Hackensack, NJ 07601 | tel: 201.282.6500 | fax: 201.282.6501 | www.steinsakslegal.com August 5, 2025 Via CM/ECF The Honorable Gregory H. Woods United States District Court Southern District of New York Re: Jones v. Daniela’s Flower Shop II, Inc. Case #: 1:25-cv-03681-GHW Dear Judge Woods: We represent the plaintiff in the above matter. We write to respectfully request that the initial conference currently scheduled for August 12, 2025 be adjourned because Defendant Daniela’s Flower Shop II, Inc. has not made an appearance or reached out to Plaintiff. Defendant has been successfully served and Plaintiff currently has a Certificate of Default against Defendant. We thank Your Honor and the Court for its kind considerations and courtesies.

Respectfully submitted, s/ Rami M. Salim Rami M. Salim, Esq. ce: All Counsel of Record via ECF Defendant has not yet appeared in this matter, the initial pre-trial conference scheduled for August 12, 2025 is adjourned to September 24, 2025 at 00 p.m. The joint status letter and proposed case management plan described in the Court’s May 6, 2025 order are due no later than September 17, 2025. | event Plaintiff intends to prosecute its case by way of order to show cause why default judgment should not be entered, the Court expects it to do so, in compliance with the procedure articulated in the Court’s Individual Rules of Practice in Civil Cases, no later than August 19, 2025. Plaintiff is specifically rected to comply with Rule 3(G) of the Court’s Individual Rules. Court reminds Plaintiff that in order for the Court to enter default judgment, the Court must determine whether Plaintiffs allegations establish liability a matter of law, accepting factual allegations as true, except those relating to damages, and drawing all reasonable inferences in Plaintiffs favor. See Finkel

(2d Cir. 2009). The Court expects that PlaintifPs memorandum of law will address why Plaintiff is entitled to judgment in light the Court’s decision in Sookul v. Fresh Clean Threads, Inc.,

(S.D.N-Y. 2024). is directed to serve a copy of this order on Defendant and to retain proof of service. The Clerk of Court is directed to terminate the motion pendin; Dkt. No. 11. ORDERED.