Ventura v. Costco Wholesale Corporation

Filing 11

ORDER granting 10 Letter Motion to Adjourn Conference. The conference is adjourned to December 7, 2023, at 2:30 p.m. SO ORDERED. Initial Conference set for 12/7/2023 at 02:30 PM before Judge Sidney H. Stein.. (Signed by Judge Sidney H. Stein on 11/15/2023) (jca)

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rmcoNNELL -.; ■ FOLEY A TRADITION Of LfGAl EXCELLfNCf SINCE 1938 Connell Foley LLP Michael Bojbasa Of Counsel 875 Third Avenue , 21'1 Floor New York , NY 10022 P 212 .307.3700 F 212 .262.0050 November 15, 2023 VIAECF Honorable Sidney H. Stein United States District Court Southern District of New York 500 Pearl Street New York, New York 10007 Re: MEMO ENDORSED Lourdes Ventura v. Costco Wholesale Corporation Docket No.: 23-CV-06446(SHS) Dear Judge Stein: We represent the defendant Costco Wholesale Corporation ("Costco") in the referenced matter and write here on behalf of both parties to request an adjournment of tomorrow's Initial Pretrial Conference scheduled for 2:30 p.m. Plaintiffs counsel advised our office this afternoon that Plaintiff has agreed to a stipulation capping damages and remanding the matter back to state court for further proceedings. We have provided Plaintiffs counsel with an appropriate stipulation for execution by counsel and Plaintiff, however the parties require additional time to finalize the stipulation so that it may be submitted to the Court. The parties jointly request that tomorrow's Initial Pretrial Conference be adjourned for the reasons stated above. This is the parties second request for an adjournment of the Initial Pretrial Conference. Lastly, the parties apologize for the lateness of this request. The attorney handling this matter on behalf of Costco, Frank J. Pina IV, unexpectedly fell seriously ill earlier this week which caused the delay in the parties seeking this adjournment from the Court. Your Honor's consideration of this matter is greatly appreciated. Respectfully submitted, M/chaet tojbasa Michael Bojbasa Roseland Jersey City Newark New York 7025291- 1 Cherry Hill Philadelphia Honorable Sidney H. Stein Page 2 cc : VIA E-MAIL Michelle Jean-Jacque, Esq. HARMON LINDER & ROGOWSKY Attorneys for Plaintiff LOURDES VENTURA 3 Park Avenue, Suite 2300 New York, New York 10016 (212) 732-3665 The conference is adjourned to December 7, 2023, at 2:30 p.m. Dated: New York, New York November 15, 2023 702529 1-1

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