Case 1:22-cv-09511-JPC-KHP Document 92 Filed 08/07/23 Page 1 of 2
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`August 7, 2023
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`VIA ECF
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`Hon. Katharine H. Parker
`United States District Judge
`500 Pearl Street, Room 750
`New York, New York 10007
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`Sarah M. Matz
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`Partner
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`sarah@adelmanmatz.com
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`Dir: (646) 650-2213
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`8/7/2023
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`Re:
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`Phase One Network, Inc. v. Ye f/k/a Kanye West d/b/a “Yeezy Tech”, et al
`Case No. 1:2022-cv-09511
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`Hon. Judge Parker:
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`We are litigation counsel for the plaintiff, Phase One Network, Inc. (“Plaintiff”) in the
`above-referenced action. We write pursuant to Rules I(b) and (c) of Your Honor’s Individual
`Practices to request an extension of time of the Case Management Conference currently scheduled
`for August 8, 2023 at 10:45 a.m. [Dkt. No. 83].
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`Motion to Dismiss Plaintiff’s Complaint, filed on or about June 23, 2023 (the “Motion to
`Dismiss”).
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`On June 20, 2023, the Court scheduled a Case Management Conference for August 8, 2023
`at 10:45 a.m. (the “August 8th Case Management Conference”). Plaintiff now requests an
`adjournment of the August 8th Case Management Conference to September 19, 2023, i.e. six (6)
`weeks. This will be the first adjournment of a case management conference in this case. One
`previous request for an adjournment was made, as Defendants Ye f/k/a Kanye West d/b/a “Yeezy
`Tech”, Getting Out Our Dreams II, LLC, and Getting Out Our Dreams, Inc. a/k/a G.O.O.D.
`Music (collectively “Ye Defendants”), previously requested an adjournment of the Initial Case
`Management Conference, which Plaintiff opposed, and which was denied by the Court. [Dkt No.
`54].
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`The reason for this request is, given that the briefing schedule as to Ye Defendants’ motion
`to dismiss was extended [Dkt. No. 90], and Plaintiff recently served its first set of discovery
`demands on Ye Defendants on July 25, 2023, it would be more fruitful to hold a case management
`conference in mid-September, at which point there will be more for the parties to report to the
`Court. Further, Plaintiff and Ye Defendants are continuing to engage in informal settlement
`discussions and believe that an adjournment of the August 8th Case Management Conference will
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`Adelman Matz P.C.
`
` Phone: (646) 650-2207 • Fax: (646) 650-2108
`
`Mailing:
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`1159 Second Avenue, Suite 153
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`New York, New York 10065
`
`Office:
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`800 3rd avenue, 25th floor
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`New York, New York 10022
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`Case 1:22-cv-09511-JPC-KHP Document 92 Filed 08/07/23 Page 2 of 2
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`August 7, 2023
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`Page 2 of 2
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`be beneficial in that regard. This extension request does not affect any other scheduled dates in
`this matter.
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`Counsel for Plaintiff and Ye Defendants have conferred and Ye Defendants are in
`agreement with the extension request.
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`Further, good cause exists for this request to be granted although the request was not made
`48 hours prior to the conference, because upon preparation for the conference, the parties agreed
`that there was not a substantial amount of information to report to the Court and that in the interest
`of judicial economy the request for an adjournment should be made.
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`We greatly appreciate the Court’s time and consideration, and should the Court need any
`additional information we are available at the Court’s convenience.
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`Respectfully Submitted,
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`ADELMAN MATZ P.C.
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`Sarah M. Matz, Esq.
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`8/7/2023
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`2
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