Rumayor v. Mastercard International Inc.

Filing 40

MEMO ENDORSEMENT terminating 39 Letter Motion to Stay re: 39 JOINT LETTER MOTION to Stay re: 35 Order on Motion for Extension of Time to Complete Discovery, addressed to Judge Paul A. Engelmayer from Daniel M. Rosenthal date d June 27, 2024. ENDORSEMENT: The Court appreciates the notification. However, per its usual practice, the Court will issue a separate order dismissing the case without prejudice to the right to reopen it within 60 days if the settlement is not consummated. SO ORDERED. (Signed by Judge Paul A. Engelmayer on 7/2/2024) (tg)

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK INIGO RUMAYOR Plaintiff, Case No.: 23-cv-09280 (PAE) V. MASTERCARD INTERNATIONAL INC. Defendant. JOINT MOTION TO STAY ALL DEADLINES VIAECF Hon. Paul A. Engehnayer United States District Judge Thurgood Marshall United States Comt house 40 Foley Square New York, New York 10007 Dear Judge Engelmayer: The pruties submit this letter to seek a stay of all deadlines in this case. The cmTent schedule is set f01th in the Comt's Order granting the pa1t ies' j oint motion to modify the scheduling order (ECF Nos. 34 and 35) and includes a fact discovery deadline of July 12, 2024. Since issuance of that Order, the part ies have reached an agreement in principle on the key terms of a settlement. The part ies are cmTently working together to memorialize and finalize that settlement. Accordingly, the pruties respectfully seek this stay to conserve their resources and those of the Comt. The paliies propose that the stay continue until either patty seeks to lift the stay or the case is dismissed. Dated: June 27, 2024 Respectfully submitted, /s/ Daniel Rosenthal Daniel M. Rosenthal (admitted pro hac vice) JAMES & HOFFMAN, P.C. 1629 K Street NW, Suite 1050 Washington, DC 20006 Tel: (202) 496-0500 Fax: (202) 496-0555 dmrosenthal@jamhoff.com A ttorney f or Plaintiff JACKSON LEWIS P.C . 666 Third Avenue, 28th Fl. New York, New York 10017 Tel.: (212) 545-4000 Mary.Smith@jacksonlewis.com Kevin.MmTay@jacksonlewis.com By: Isl Mary A. Smith Mary A. Smith Kevin W. Munay A ttorneys f or Defendant The Comt appreciates the notification. However, per its usual practice, the Comt will issue a separate order dismissing the case without prejudice to the right to reopen it within 60 days if the settlement is not consummated. SO ORDERED. PaJA.� PAUL A. ENGELMAYER United States District Judge July 2, 2024 2

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