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Case 2:11-cv-04203-FSH-PS Document 27

Filed 01/18/12 Page 1 of 1 PageID: 364

Samantha H. Lutzer Attorney at Law 646.374.0351 sam@bowlescrow.com

54 West 21 st Street, Suite 1007 New York, New York 10010 tel: 646.419.4264 fax: 866.844.8305 www.bowlescrow.com

New York Los Angeles

January 18, 2012

Filed by ECF The Hon. Patty Shwartz United States Magistrate Judge USDC, District of New Jersey Martin Luther King Courthouse 50 Walnut Street Room 4015 Newark, NJ 07101 Re: Request for Adjournment of Status Conference Patrick Collins, Inc. v. Hitchcock et al, Case No. 2:11-04203 (FSH) (PS) K-Beech, Inc. v. Booth et al., No. 11-cv-04776(FSH)(PS)

Dear Judge Shwartz: We represent the plaintiff in the two above captioned matters. We write to request an adjournment of the scheduling conference currently scheduled for January 26, 2012, on the grounds that it is premature because defendants will not be able to appear due to the posture of service of pleadings in the case. As the Court will recall, on January 6, 2012, the Court issued orders in both cases denying various motions by defendants (seeking, inter alia, dismissal and protective orders). The Court ordered plaintiff to serve defendants within 90 days of the date of the order, and therefore service must be complete by April 5, 2012. Plaintiff is in the process of serving defendants in accordance with the Court’s deadline, but has not yet completed service. Further, plaintiff only learned the identity of certain defendants (for whom the Court denied the protective orders) 2 days ago. Plaintiff will be moving to amend the complaint again to add these defendants, which is required obtaining the summons and complaint for service. Under the circumstances, therefore, not all parties can be represented at the January 26, 2012 scheduling conference, and plaintiff respectfully suggests that it is premature, and requests that it be adjourned until all parties can be represented. Respectfully submitted, /s/ Samantha H. Lutzer Samantha H. Lutzer (SE0898)