NY Daily Newswire, LLC v. Tango Publishing Corporation

Filing 11

ORDER granting 10 Letter Motion to Adjourn Conference. September 30 conference is adjourned to December 6, 2024 at 11:00 a.m. Dial-In No.: 1-888-363-4749, Access Code: 3667981. SO ORDERED. Initial Conference set for 12/6/2024 at 11:00 AM before Judge P. Kevin Castel. (Signed by Judge P. Kevin Castel on 9/23/2024) (vfr)

Case 1:24-cv-05597-PKC

Document 10

Filed 09/20/24

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333 EARLE OVINGTON BOULEVARD, SUITE 402
UNIONDALE, NEW YORK 11553
T: 516-203-7600
F: 516-282-7878

September 20, 2024
Via ECF
Hon. P. Kevin Castel
U.S. District Court
Southern District of New York
500 Pearl Street
New York, New York 10007
Re:

September 30 conference is adjourned to
December 6, 2024 at 11:00 a.m.
Dial-In No.: 1-888-363-4749,
Access Code: 3667981.
SO ORDERED.
Dated: 9/23/2024

NY Daily Newswire, LLC v. Tango Publishing Corporation d/b/a Tango Media
Case No: 1:24-cv-05597-PKC

Dear Judge Castel:
This firm represents plaintiff NY Daily Newswire, LLC (“Plaintiff”) in the above-referenced
matter and writes pursuant to Rule 1.C. of the Court’s Individual Practices to respectfully request
an adjournment of the September 30, 2024, Initial Pretrial Conference, along with the associated
filing deadline(s) [Dkt. No. 7].
i.

The current date for the Initial Pretrial Conference is September 30, 2024, and the
current submission deadline is September 20, 2024. [Dkt. No. 7];

ii.

Service upon defendant Tango Publishing Corporation d/b/a Tango Media
(“Defendant”) has not yet been effectuated and as such, Defendant has not yet
appeared in this matter or filed a response to the Complaint. This firm had
previously contacted Defendant’s prior counsel from an earlier unrelated case to
inquire into counsel’s continued representation of Defendant however, prior
counsel advised that they would not be representing Defendant at that time. Plaintiff
will continue all efforts to serve process upon Defendant and anticipates service
being effectuated within the time set forth in Rule 4(m) of the Federal Rules of
Civil Procedure. Plaintiff seeks an adjournment of the Initial Pretrial Conference
and the associated filing deadline(s) to a date following the completion of service
upon Defendant;

iii.

No previous requests have been made or granted/denied;

iv.

Defendant has not yet appeared in this action and therefore neither opposes nor
consents to this request;

Case 1:24-cv-05597-PKC

Document 10

Filed 09/20/24

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PAGE 2

v.

This request is made in good faith and not for purposes of delay and granting this
request will not prejudice any party to this matter.

Thank you for your consideration of this request.
Respectfully submitted,
SANDERS LAW GROUP
/s Jaymie Sabilia-Heffert
Jaymie Sabilia-Heffert, Esq.