-—_——S EE eo SE OO we — Vee te ee ee a “a SN

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

Stephen Yang, [| [) [z C [z W fz Plaintitt | OCT 06 2025 iD

Inventus Media, Inc., Defendant.

Case No.: 1:25-cv-00004-PAE

DEFENDANT’S SECOND MOTION TO STAY PROCEEDINGS PENDING ‘ SETTLEMENT DISCUSSIONS

Inventus Media, Inc. (“Defendant”), respectfully moves this Court for a second stay of proceedings for a period of 30 days to allow the parties to continue good-faith settlement discussions. In support of this motion, Defendant states as follows:

1. On September 8, 2025, the Court granted a stay of proceedings to facilitate settlement discussions between the parties.

2. Since that time, the parties have continued to engage in meaningful and ongoing settlement negotiations, The defendant has submitted three proposals for settlement.

3. Defendant believes that an additional stay will conserve judicial resources and the parties’ expenses by potentially avoiding protracted litigation,

4. Defendant has advised the Plaintiff’s counsel of this requested motion to stay proceedings but at time of filing had not responded.

5, Defendant respectfully requests that the Court stay all deadlines and proceedings for an additional 30 days to allow the parties to continue their settlement efforts.

WHEREFORE, Defendant respectfully requests that the Court grant this motion and stay all proceedings for 30 days and grant such other and further relief as the Court deems just and

proper.

Dated: October 06, 2025

White Plains, New York

Inventus Medig Inc.

Andrew K. McLean.

Owner and Sole Employee

Inventus Media, Inc.

Nae Te ee ee Ree ee SN ee Pe ee bP bee ES SES t □□ Ff NPT

Certificate of Service

I hereby certify that on October 6, 2025, a true and correct copy of the foregoing Motion for Extension of Time was served upon Plaintiff’s counsel by electronic filing email and by first- class mailto:

Dina Nouhtan, Esq. Sanders Law Group Nannies BGEIVE 333 Earle Ovington Blvd, Suite 402 | OCT 06 2025 | Uniondale, New York 11553 p R 0 SE 0 Email: [email protected] seeccrrtacaci

It has come to the Court's attention that defendant □ : Inventus Media, Inc., a corporation, has failed to retain counsel in this case, Because a corporation "cannot proceed pro se," Jones v. Niagara — Frontier Transp. Auth,

, 22 (2d Cir. 1983), defendant has until November 7, 2025 to Andrew Kk. McLean obtain counsel and have that attorney formally appear on its behalf. Otherwise, the Court will be Inventus Media forced to lift the stay, Dkt. 26, and consider the plaintiffs motion for default judgment, see Dkt. 14, SO ORDERED.

PAUL A. ENGELMAYER United States District Judge Date: October 8, 2025 New York, New York