Ryzhov v. $5,379,876.94 In United States Currency Formerly on Deposit in Sunflower Bank, NA et al

Filing 66

ORDER granting 65 Letter Motion for Extension of Time to File. Application GRANTED. Plaintiff shall file any motion for default judgment as to Defendant Tsargrad Media no later than March 27, 2024. The Clerk of Court is directed to terminate ECF No. 65. (Signed by Judge Jesse M. Furman on 2/5/2024) (rro)

IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
1:23-cv-01072-JMF
Evgeny RYZHOV
Plaintiff
-v$5,379,876.94 In United States Currency Formerly
on Deposit in Sunflower Bank, NA et al

Motion for an extension of time

Defendants
_______________________________/
Dear Judge JESSE M. FURMAN:
Pursuant to Fed. R. Civ. P. 4(m), Plaintiff Evgeny Ryzhov moves for entry of an order extending
the time within which Plaintiff has to file any motion for default judgment against Defendant Tsargrad
Media as ordered by the Court's Order ECF No.61., and states:
1.
On February 7, 2023, Plaintiff commenced the above-captioned action against Konstantin
Malofeyev and Tsargrad Media, herein collectively referred to as 'Defendants.' This action asserts claims
against the Defendants for their involvement in the unlawful divestiture of Plaintiff's assets, which were
subsequently laundered through an intricate network of shell companies, investment funds, and foreign
bank accounts spanning globally, ultimately culminating in their transfers into the United States.
Simultaneously, Defendants were involved in orchestrating and executing a smear campaign aimed at
tarnishing the Plaintiff's professional and personal reputation and destroying his international businesses,
thereby impeding his capacity to conduct those businesses and generate income. The Defendants’ acts
have resulted in substantial material and reputational damages to the Plaintiff.
2.
As of the current date, Defendant Tsargrad Media has been duly served with the legal
proceedings in accordance with the relevant procedural requirements. Despite proper service, Tsargrad
Media has neither filed a response nor undertaken any defensive actions in this matter. Consequently, due
to this failure to respond or otherwise engage in the defense, the Clerk of Court has entered a default.
3.
On January 30, 2024, the Honorable Court entered its Order ECF No.61 directing Plaintiff
“to file any motion for default judgment … within three weeks of the date of this Order,” meaning by
February 21, 2024.
4.
However, the Plaintiff is presently immersed in rigorous preparations for the Bar
Examination, which is scheduled for February 27 and 28, 2024. This endeavor demands considerable
allocation of time and resources, consequently impeding the Plaintiff's capacity to dedicate the requisite
effort towards the preparation of a motion for default judgment and associated documents, including a
memorandum of law. The Bar Examination is a critical professional requirement for Plaintiff and is
scheduled to occur only twice a year.
5.
Granting this extension will not prejudice Defendant Tsargrad Media, as it is a reasonable
request given the circumstances and does not suggest any intention on Plaintiff's part to delay the

proceedings unjustifiably. Furthermore, the requested extension is short-term and for a set period, ensuring
that the case will proceed in a timely manner following the Plaintiff's Bar Examination.
6.
Procedurally, Plaintiff respectfully requests that the time within which he has to file any
motion for default judgment be extended to at least thirty - five (35) days, or until March 27, 2024. The
additional time will allow Plaintiff to prepare all necessary documents.
7.
This motion is made in good faith and not for the purpose of undue delay.
8.
Considering that Defendant Tsargrad Media failed to appear in this action and
communicate with Plaintiff by other means, Plaintiff had no opportunity to confer this motion with it.
WHEREFORE, Plaintiff respectfully requests that the time within which he has to file any motion
for default judgment be extended or until March 27, 2024. A proposed order is attached for the Court’s
convenience.

Dated January 31, 2024

Respectfully submitted

By /s/

__________

Evgeny Ryzhov
[e-mail]
[phone]
250 174th apt. 1918,
Sunny Isles Beach, FL 33160
Application GRANTED. Plaintiff shall file any motion for
default judgment as to Defendant Tsargrad Media no later
than March 27, 2024. The Clerk of Court is directed to
terminate ECF No. 65.
SO ORDERED.

February 5, 2024

CERTIFICATE OF SERVICE
I hereby certify that on this 31st day of January 2024, I electronically filed the foregoing document
with the Clerk of the Court. I also certify that true and accurate copies of Plaintiff’s Request for Clerk’s
Certificate of Entry of Default, Affidavit in Support of Request for Entry of Default, and Proposed Entry
of Default were served on this day via email upon the Defendant:
TSARGRAD MEDIA,
email: [e-mail], [e-mail], [e-mail], [e-mail].

By /s/

__________

Evgeny Ryzhov
[e-mail]
[phone]
250 174th apt. 1918,
Sunny Isles Beach, FL 33160