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`July 14, 2020
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`VIA ECF
`Honorable Vince Chhabria
`Northern District of California
`450 Golden Gate Avenue
`San Francisco, CA 94102
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`Re: Ponderosa Twins Plus One et al v. iHeartMedia, Inc., et al.
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`Civil Case No.: 2016-cv-05648
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`Dear Judge Chhabria:
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`Our firm represents the Plaintiff and submits this letter to respectfully request additional time to
`file the amended complaint. Currently, the Court has ordered Plaintiff to file his amended
`complaint by July 17, 2020. Plaintiff has been in serious settlement discussions with certain
`Defendants that may obviate the need to file an amended complaint against some, or all,
`Defendants. Plaintiff respectfully requests 21 additional days to continue settlement discussions
`and file his amended complaint, if necessary, on or before August 7, 2020. If Plaintiff files an
`amended complaint, Defendants’ motion would be due on or before August 31, 2020. Plaintiff
`sought consent from Defendants but did not receive a response. No other deadlines will be
`affected. This is Plaintiff’s first request for additional time to file his amended complaint.
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`Respectfully submitted,
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`/s/ Salvatore C. Badala
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`400 BROADHOLLOW ROAD, SUITE 305, MELVILLE, NEW YORK 11747 | (212) 397-1000
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`1
`NAPOLILAW.COM
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`Case 3:16-cv-05648-VC Document 100 Filed 07/14/20 Page 2 of 2
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`CERTIFICATE OF SERVICE
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`The undersigned attorney certifies that on July 14, 2020, he electronically filed a copy of the
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`attached via the CM/ECF filing system, which sent notification of such filing to all Filing Users.
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`/s/ Salvatore C. Badala
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`2
`NAPOLILAW.COM
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`400 BROADHOLLOW ROAD, SUITE 305, MELVILLE, NEW YORK 11747 | (212) 397-1000
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