BakeMark USA LLC v. Negron et al

Filing 127

ORDER granting 126 Letter Motion to Adjourn Conference. Application GRANTED. The conference, previously scheduled for September 5, 2024, is hereby ADJOURNED to 12:00 p.m. on the same day. SO ORDERED. Status Conference set for 9/5/2024 at 12:00 PM before Magistrate Judge Barbara C. Moses. (Signed by Magistrate Judge Barbara C. Moses on 8/29/2024) (vfr)

Application GRANTED. The conference, previously scheduled for September 5,
2024, is hereby ADJOURNED to 12:00 p.m. on the same day.
SO ORDERED.

_________________________
Barbara Moses
United States Magistrate Judge
August 29, 2024

Court Plaza North
25 Main Street
P.O. Box 800
Hackensack, NJ 07602-0800
201-489-3000 201-489-1536 fax
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8/29/2024
New York
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Delaware
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Maryland
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Texas
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Florida

August 29, 2024
Via CM/ECF Filing
Honorable Barbara Moses, U.S.M.J.
United States District Court, Southern District of New York
Daniel Patrick Moynihan U.S. Courthouse, 500 Pearl Street, Room 740
New York, New York 10007
Re:

BakeMark USA LLC v. Negron, et al.,
Case No. 1:23-cv-02360-AT-BCM

Dear Judge Moses:
This firm is counsel to defendants, Brian Negron, Jose Negron Jr., and NF Transportation
LLC (collectively, the “Non-Debtor Defendants”),1 in the above-referenced action. We write with
the consent of plaintiff, BakeMark USA LLC (“BakeMark”), to respectfully request an adjournment
of the September 5, 2024, conference currently scheduled for 10:00 a.m. (see Order [ECF No. 125]),
to either: (i) 11:00 a.m. or 12:00 p.m. on the same day, September 5, 2024; or, alternatively (ii) a time
convenient for the Court on September 6, 2024, or September 11, 2024, or some other future date and
time as amenable to the Court’s schedule.
The Non-Debtor Defendants respectfully submit that sufficient good cause for the
adjournment exists as lead counsel for the Non-Debtor Defendants is unavailable at 10:00 a.m.
September 5, 2024, due to a personal matter, and counsel for BakeMark is unavailable later that
afternoon. Consequently, the Non-Debtor Defendants respectfully submit that the requested
adjournment should be granted under the circumstances.
If Your Honor requires any additional information or has any questions, the undersigned can
be reached via email ([e-mail]) or phone [phone]). As always, the
Court’s time and attention to this matter are greatly appreciated.
Respectfully submitted,
COLE SCHOTZ P.C.
/s/ Jason R. Finkelstein
CC: All Counsel of Record Via CM/ECF

Jason R. Finkelstein

Defendant Bakers Depot LLC (“Bakers Depot”) filed for relief under Chapter 11 of the United States Bankruptcy Code,
and Cole Schotz P.C. has not been retained in the bankruptcy proceeding to act as special litigation counsel here.
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