BOND £aiene & KING 22 Corporate Woods Boulevard, Suite 501 | Albany, NY 12211 | bsk.com SANJEEVE K. DESOYZA, ESQ. [email protected] P: 518.533.3206 F: 518.533.3299 September 11, 2025 VIA ELECTRONIC FILING VALERIE FIGUBREDO —_—_—_—__—— United States Magistrate Judge Hon. Valerie Figueredo, U.S. Magistrate Judge | +1. Court will comida heen U.S. District Court, Southern District of New York} dismiss at ECF No. 7 in light of the Daniel Patrick Moynihan facts alleged in the amended United States Courthouse complaint at ECF No. 15. The Clerk 500 Pearl St of Court is respectfully directed to New York NY 10007-1312 terminate the gavel at ECF No. 22.

Re: Kareem B. Taylor v. A&H Security Services, LLC Civil Action No. 1:25-cv-7180 (VEC)(VF) Dear Judge Figueredo: Our office represents Defendant A&H Security Services, LLC (“A&H Security”) in the above- referenced matter. As the Court is aware, A&H Security filed its 12(b)(6) motion to dismiss the complaint on September 3, 2025 (Dkt. No. 7). In response, Plaintiff both opposed A&H Security's motion (Dkt. No. 18) and submitted an Amended Complaint on September 2, 2025 (Dkt. 15). "(When a plaintiff properly amends her complaint after a defendant has filed a motion to dismiss that is still pending, the district court has the option of either denying the pending motion as moot or evaluating the motion in light of the facts alleged in the amended complaint.” Pettaway v. Nat'l Recovery Sols., LLC,

(2d Cir. 2020). In light of Plaintiff filing an Amended Complaint, A&H Security seeks clarification as to whether the Court anticipates denying A&H Security’s 12(b)(6) motion to dismiss as moot, and requiring A&H Security respond to the Amended Complaint, or whether the Court prefers to evaluate the motion in light of the facts alleged in the Amended Complaint. Thank you for your attention to this matter. Respectfully submitted, NECK & KING, PLLC

Sanjeeve K. DeSoyza Member SKD/RJL 22272394 .v1-9/11/25