Michael Toikach v. Christian Dior, Inc. et al.

Gl BSON DU N N Mylan L. Denerstein Partner T: #1 212.351.3850 : +1 718.869.1671 November 12, 2025 tee teech amare tk) VIA ELECTRONIC FILING The pbhadse Le The Honorable John G. Koeltl \ United States District Court Uv [26 2 Oo OfiuccleA, ' Southern District of New York Pearl Street SO brclasef 6 (se Lp New York, NY 10007-1312 Sables ( 13/8 uS D3, Re: Michael Toikach v. Christian Dior, Inc. et al., No. 25-cv-6058-JGK (S.D.N.Y.) Dear Judge Koeltl: Pursuant to Section 1(C) of this Court’s Individual Practices, we write with the consent of Plaintiffs counsel to request an adjournment of the initial case management conference currently scheduled for November 20, 2025. The parties have conferred and Plaintiff consents to the relief requested herein. This is the first time the parties have requested an adjournment of the initial case management conference.

On August 8, 2025, plaintiffs in several recently filed related actions filed a Motion to Consolidate Actions and Appoint Interim Class Counsel and an Executive Committee in the first- filed case, captioned Beata Toikach v. Christian Dior, Inc., No. 25-cv-6055-JAV (S.D.N.Y. Aug. 8, 2025), ECF No. 12 (the “Motion to Consolidate”). This Motion to Consolidate is pending before the Honorable Jeannette A. Vargas and seeks to (1) consolidate this, and the other related actions, into the first-filed action; (2) appoint Plaintiffs’ proposed leadership structure; (3) stay this action and the Defendants’ responsive pleading deadlines in this action; and (4) require the filing of a consolidated class action complaint in the proposed lead case. A copy of the Motion to Consolidate is attached hereto as Exhibit A.

Additionally, on August 29, 2025, a Motion to Transfer and Centralize was filed before the Judicial Panel on Multidistrict Litigation. See in re Salesforce, Inc. Customer Data Sec. Breach Litig., MDL No. 3164 (J.P.M.L.), ECF No. 1. That Motion seeks to transfer this, and other, actions into a putative MDL in the U.S. District Court for the Northern District of California. This Motion is pending before the JPML, which is scheduled to hear argument on December 4, 2025, and expected to issue a decision on transfer and centralization before the end of the year. See In re Salesforce, ECF No. 121 (scheduling panel hearing on December 4, 2025).1 The parties respectfully request that in light of the pending Motion to Consolidate, the pending JPML Motion, and Christian Dior, Inc.'s January 5, 2026, deadline to respond to the complaint (see Dkt. 9), the initial case management conference be adjourned until after the JPML has ruled on the JPML Motion to Transfer and Centralize. The parties believe that a brief adjournment of the initial case management coriference will serve the interests of efficiency and conserve the resources of the Court and all parties by allowing the JPML to rule on the potential transfer and centralization of this action. See McCrary v. Merrill Lynch, Pierce, Fenner & Smith See “Inside the JPML,” 108 JUDICATURE 2 (2024), https://judicature.duke.edu/articles/inside-the-ipml/ (Chair of the JPML stating that “[t]he JPML strives to issue its orders within two weeks of the hearing session’).

Gibson, Dunn & Crutcher LLP Park Avenue | New York, NY 10166-0193 | T: 212.351.4000 | F: 212.351.4035 | gibsondunn.cam GIBSON DUNN November 12, 2025 Page 2 Inc., 2024 WL 5315308 (S.D.N.Y. Dec. 16, 2024) (staying “discovery and other proceedings . . . pending the resolution of the Motion to Consolidate before the JPML” in light of the risk of “duplicative proceedings” and the “interests in efficiency and economy”). Courts in other actions being contemplated for the MDL have similarly adjourned initial case management conferences pending the JPML’s decision. See, e.g., Ansryan v. Christian Dior Inc., No. 1:25-cv-6705-VEC (S.D.N.Y.), ECF No. 9.

The parties further agree to file a joint status report within one week of the earlier of (1) the JPML’s decision on the Motion to Transfer and Centralize, or (2) any ruling on the Motion to Consolidate.

We thank the Court for its consideration of this request.

Respectfully Submitted, /s/ Mylan Denerstein Mylan L. Denerstein CC: All Counsel of Record via ECF