Case 1:22-cv-09511-DEH-KHP Document 133 Filed 03/28/24 Page 1 of 1
`
`March 26, 2024
`
`VIA ECF
`Hon. Katharine H. Parker
`United States District Judge
`500 Pearl Street, Room 750
`New York, New York 10007
`
`Re:
`
`Case No. 1:22-cv-09511
`
`Hon. Judge Parker:
`
`David Marcus
`
`Partner
`
`david@adelmanmatz.com
`
`Dir: (646) 915-1190
`
`3/27/2024
`
`Request GRANTED. All deadlines are hereby stayed until
`Friday, April 26, 2024. The parties shall file a joint status
`letter with the court by Friday, April 19, 2024 to provide
`an update on settlement negotiations and pursuit of
`default judgments.
`
`3/28/2024
`
`We represent plaintiff, Phase One Network, Inc. (“Plaintiff”) in the above-referenced
`action. We are pleased to advise the Court that Plaintiff and Defendants Ye f/k/a Kanye West
`d/b/a “Yeezy Tech”, Getting Out Our Dreams II, LLC, G.O.O.D. Music and Yeezy LLC
`(collectively the “Ye Defendants”) have agreed to a settlement in principle and will begin the
`process of negotiating a settlement agreement. Plaintiff does not request a conditional 30-day
`order as Plaintiff intends to move for default against the non-settling defendants, Alex Klein, Kano
`Computing Limited and Stemplayer Ltd.(the “Stemplayer Defendants”), each of whom are in
`default as they did not file an Answer to Plaintiff’s original complaint. Although Plaintiff obtained
`a certification of default against the Stemplayer Defendants, a new certification of default will
`have to be obtained as Plaintiff recently filed its Amended Complaint. [Dkt No. 131].
`
`Accordingly, we write pursuant to Rules I (b-c) of Your Honor’s Individual Practices in
`Civil Cases to respectfully request that the Court issue a 30-day stay of all Court deadlines under
`the Federal Rules and deadlines issued by this Court. Such a stay will relieve the Ye Defendants
`of their obligation to answer the Amended Complaint or otherwise move so that Plaintiff and the
`Ye Defendants can negotiate and finalize their settlement agreement. At the conclusion of this 30-
`day stay, Plaintiff will obtain a new certification of default against the Stemplayer Defendants and
`then move for default judgment. If settlement with the Ye Defendants is formalized, which we
`expect it to be, no further extension of the discovery and pre-trial deadlines will be necessary.
`
`We appreciate the Court’s time and consideration.
`
`Respectfully submitted,
`ADELMAN MATZ P.C.
`
`David Marcus, Esq.
`
`Cc: All counsel of record (via ECF)
`
`Adelman Matz P.C.
`
` Phone: (646) 650-2207 • Fax: (646) 650-2108
`
`Mailing:
`
`1159 Second Avenue, Suite 153
`
`New York, New York 10065
`
`Office:
`
`800 Third Avenue, 25th Floor
`
`New York, New York 10022
`
`