Cordero v. Good Karma 818 LLC., et al.
Case No. 1:25-cv-2901 (MKV)
United States District Court Southern District of New York
November 3, 2025
144 E 44th Street, Suite 703
New York, New York 10017
Phone: 212 563 3223
Fax: 212 563 4534
E-mail: chaubeylaw@gmail.com
Mailing Address:
19 Stillman Lane,
Pleasantville, NY 10570
VIA ECF November 3, 2025
The Hon. Mary Kay Vyskocil
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: Cordero v. Good Karma 818 LLC., et al.
Case No. 1:25-cv-2901 (MKV)
Sub: Request for Extension of Time to file Answer/ Opposition
Dear Hon. Judge Vyskocil:
This office represents Defendants Good Karma 818 LLC d/b/a Mac Suites Hotel, d/b/a Friendly Suites, d/b/a Umbrella Hotel Bronx, and Manny Chadha a/k/a Manoj Kumar, in the captioned matter. I am writing this letter pursuant to your Honor‘s Individual Rule 2(B) and (G), for Requests for Adjournments or Extensions of Time to file Answer to the Complaint on behalf of the Defendants or in the alternative seeking permission to file opposition to the proposed default judgment by the Plaintiff.
It is respectfully submitted that Defendants were served with the Motion for Default Judgment against the Defendants and upon receipt Defendants have retained my office to resolve this matter.
Upon receiving the retainer agreement on or about October 29, 2025, I promptly contacted Michael Samuel, Attorney for the Plaintiff, requesting stipulation regarding the withdrawal of Motion for default judgment and consent to file answer on behalf of the Defendants. Counsel for Plaintiff has neither consented nor denied the request to date.
According to the certificate of service filed by Plaintiff‘s Attorney, the Defendant Corporation was served by mail on October 14, 2025 (Docket #21) and upon individual Defendant on October 21, 2025 (Docket #22). Hence, the due date for Answer or Opposition on behalf of Corporate Defendant is due on November 5, 2025, and for individual Defendant is due on November 11, 2025.
This is the first request to extend the time to file Answer and/ or Opposition to the Default Motion. Adversary has neither consented nor refused the consent. The requested
It is further submitted that the Defendants’ alleged default was neither willful, nor deliberate; Defendants have meritorious defenses and no prejudice will be caused to the Plaintiff.
In view of the above facts and circumstances, Defendants respectfully request extension of four weeks to allow the Defendants to file an Answer to the Complaint and/or Opposition to the Motion for Default Judgment (Docket #18).
Thank you for your honor‘s attention to this manner.
Respectfully Submitted,
Sanjay Chaubey, Esq.
Attorney for Defendants
Cc: Counsel for Plaintiff (via ECF)
Defendants shall answer or otherwise respond to the Complaint on or before November 24, 2025. Plaintiff‘s motion for default judgment, [ECF No. 18], is DENIED as moot. SO ORDERED.
Date: 11/3/2025
New York, New York
Mary Kay Vyskocil
United States District Judge