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September 3, 2025 VIA ECF The Honorable Jessica G. L. Clarke United States District Court MEMO ENDORSED Southern District of New York 500 Pearl Street New York, NY 10007 RE: Kissimina, Nade, et al vs. Ed’s Lobster Bar LLC, et al Case No.: 1:24-cv-04261-JGLC Dear Judge Jessica G. L. Clarke, Pursuant to Rule 6 of the Federal Rules of Civil Procedure, a district court may extend a deadline for good cause if the request is made before the original deadline, or its extension expires. Manigault v. ABC Inc.,

, *15 (2d Cir. 2019) (citing Fed. R. Civ. P. 6(b)(1)(A)). In accordance with Your Honor’s Individual Practice Rule 2(e), the parties jointly and respectfully seek an extension of the following upcoming deadlines: 1. Motions for Summary Judgement: currently due October 2, 2025 2. Oppositions to Motions for Summary Judgment: currently due October 21, 2025 3. Replies to Motions for Summary Judgment: currently due October 31, 2025 The parties have conferred as required by the Court’s individual practices, and all counsel have agreed to the proposed extensions. This is the first request for an adjournment

Page 2 or extension of these deadlines. Therefore, this extension will not impact any other deadlines or prejudice any parties. The reasons for this request are as follows: 1. At this time, counsel for Plaintiff's counsel will need additional time to draft the motion for summary judgment. The parties jointly propose the following revised schedule: 1. Motions for Summary Judgement: October 16, 2025 2. Oppositions to Motions for Summary Judgment: November 4, 2025 3. Replies to Motions for Summary Judgment: November 14, 2025 This request is made in compliance with the Court’s requirement that extension requests be submitted at least 48 hours prior to the deadline. This request is made for a proper purpose and not to delay. No party will be prejudiced by the brief extensions of time requested. The case is at a nascent stage, thus no trial has yet been set on the Court’s calendar. Given the outstanding discovery issues, the parties respectfully submit that good cause exists for the extension that has been requested.

Thank you,

lication GRANTED. The C d h /s/Janelle Romero tyth sbowe Janelle Romero, NY Bar No. 5750195 OE ONS: CONSUMER JUSTICE LAW FIRM ORDERED. . 7150 Parsons Blvd., Suite 1001 _ f “0 ko Flushing, NY 11365 He KAA T: (718) 874-8247 F: (480) 613-7733 G. L. CLARKE E: [email protected] States District Judge ed: September 4, 2025 New York, New York