Tanilli v. Moinian Development Group, LLC

6.8 eo Ure we | 1 A 4V 1 CG SHAMIS & GENTILE, P.A.

CLASS ACTION LAW FIRM Shamis & Gentile, P.A. 14 NE 1* Ave, Suite 705 * Miami, FL 33132 Telephone 305-479-2299 * Fax 786-623-0915 USDC SDNY November 17, 2025 DOCUMENT ELECTRONICALLY FILED Honorable Valerie E. Caproni DOC #: United States District Judge DATE FILED: 11/18/2025 Southern District of New York Daniel Patrick Moynihan United States Courthouse Pearl St. New York, New York 10007 Re: — Tanilli v. Moinian Development Group, LLC, No. 1:25-cv-07898 Dear Judge Caproni: Undersigned counsel represents Plaintiff Maria Tanilli (“Plaintiff”) in this Action. Pursuant to this Court’s Individual Practices in Civil Cases, Section 2.C, Plaintiff respectfully requests that the Initial Pretrial Conference, presently scheduled for December 5, 2025, at 10:00 a.m., be adjourned to a date in January 2026.

The requested adjournment is necessary because undersigned counsel has pre-planned travel outside of the United States during the currently scheduled conference date. Plaintiff is unable to obtain Defendant’s position on the relief sought as service was only effectuated on November 14, 2025, and Defense Counsel has not yet appeared.

In light of the above, Plaintiffrespectfully requests that the Court adjourn the Initial Pretrial Conference in this Action to a date in January 2026. This is Plaintiff's first request.

We thank the Court for its consideration of this request.

Respectfully submitted, /s/ Leanna Loginov SHAMIS & GENTILE, P.A.

14 NE Ist Ave, Suite 705 CG SHAMIS & GENTILE, P.A.

CLASS ACTION LAW FIRM Shamis & Gentile, P.A. 14 NE 1* Ave, Suite 705 * Miami, FL 33132 Telephone 305-479-2299 * Fax 786-623-0915 Miami, FL 33132 Telephone (305) 479-2299 Facsimile (786) 623-0915 Email: [email protected] The Initial Pretrial Conference scheduled for December 5, 2025, is adjourned to January 9, 2026, at 10:00 a.m. in Courtroom 20C of the Daniel Patrick Moynihan Courthouse, 500 Pearl Street, New York, New York 10007. The parties’ joint submission, guidelines for which are contained in the Court's September 25, 2025 Order, Dkt. 7, is due no later than December 30, 2025.

SO ORDERED. 11/18/2025 HON. VALERIE CAPRONI UNITED STATES DISTRICT JUDGE