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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Connell Foley LLP

Michael Bojbasa
Of Counsel
[e-mail]

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

www.connellfoley.com

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
[phone]

The conference is adjourned to December 7, 2023, at 2:30 p.m.
Dated: New York, New York
November 15, 2023

702529 1-1