"Good morning, Your Honor. Julio Portilla, Law Office of Julio E. Portilla, for [plaintiff/defendant] [name]. We are here on [the compliance conference / the status conference / the settlement conference / the fact-finding / trial]." Then one sentence on posture: "Since the last appearance, [what happened]." Then one sentence on the ask: "Today we ask the Court to [specific relief]." Stop talking. Let the court set the agenda.

"Your Honor, discovery is [on track / partially outstanding]. Plaintiff has served [items]; defendant's [items] are outstanding since [date]. We have conferred with counsel and propose the following schedule — I have a proposed order with dates both sides can meet: depositions by [date], expert disclosure by [date], note of issue by [date]." If the other side is in default: "We ask that the order include a 3126 provision if the [date] deadline is missed." If YOU are behind: "We will have [items] served by [date] — I am prepared to be so-ordered on that." (A date you can meet. Nothing else.)

"Your Honor, the matter is at [stage]. Outstanding: [one or two items]. We request a further status date of [60–90 days] to complete [item]." City of New York matters: "We are awaiting [50-h transcript / records from the City]; we have followed up on [dates]. We ask the Court to direct production by [date]." Foreclosure status: "The borrower [has a complete loss-mitigation application pending since ___ / is pursuing a modification]. We ask the matter remain on the status calendar pending the lender's decision. We also note the following deficiencies in plaintiff's proof: [1304 mailing / 1306 filing / standing], and reserve all defenses."

Opening: "Your Honor, we come in good faith with written authority. Our proposal is [one sentence with the number or structure]. The gap is [one issue]." When the other side stonewalls: "We have moved [X]. We would ask the Court's assistance in getting a counter on [the one issue], otherwise we are prepared to proceed to [trial / referee / motion]." Never state a number you have not cleared with the client in writing that morning.

Opening (60 seconds, no more): "Your Honor, this is a [__]-year marriage. The evidence will show three things: [fact], [fact], [fact]. On that record the Court should [the disposition in your Statement of Proposed Disposition]. We will call [witnesses] and offer [exhibit categories]." Objections you will actually need: "Objection — hearsay." "Objection — foundation; the witness has not established personal knowledge." "Objection — beyond the scope." "Objection — the document is not in evidence." Closing frame: tie every ask back to a § 236(B)(5)(d) factor and an exhibit number. "The Court should award [X] because [factor], as shown by [Exhibit __]."

"Your Honor, [petitioner/respondent] is ready to proceed. We have [#] witnesses and exhibits pre-marked A through [__]; copies for the Court and counsel. The finding we ask the Court to make is [one sentence]." Article 10 corroboration: "Your Honor, the child's out-of-court statement requires corroboration under FCA § 1046(a)(vi); [there is none / the only corroboration is ___], and we object to the finding on that basis." If you need time: "We ask for a brief adjournment to [date] to secure [witness / records]; a subpoena was served on [date] and the return is outstanding."

When you do not know: "Your Honor, I do not want to misstate the record. May I have until [tomorrow / 48 hours] to confirm and submit a letter?" When you missed something: "Your Honor, that is my responsibility. Here is what I will do and by when: [one item, one date]." Then do it. When you are double-booked: "Your Honor, I have a conflicting appearance before Justice [__] in [County] at [time]. I ask for a [second call / brief adjournment / permission to appear virtually]." Say this at the START, not when they call the case.

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF [________] Index No. [________] [CAPTION] SUBPOENA DUCES TECUM THE PEOPLE OF THE STATE OF NEW YORK TO: [RECORDS CUSTODIAN / ENTITY], [ADDRESS] WE COMMAND YOU, that all business and excuses being laid aside, you produce at [LOCATION — or: the office of the undersigned] on [DATE] at [TIME], and at any recessed or adjourned date, the following documents in your possession, custody or control: 1. [Describe records with particularity; date range; account/claim/employee identifiers] 2. [ ] A certification pursuant to CPLR 3122-a may be furnished in lieu of a custodian's appearance. The circumstances or reasons such disclosure is sought or required are: [one sentence — CPLR 3101(a)(4) notice to non-party]. Failure to comply with this subpoena is punishable as a contempt of court and shall make you liable to the person on whose behalf this subpoena was issued for a penalty not to exceed $150 and all damages sustained by reason of your failure to comply (CPLR 2308(b)). Dated: [ ] ________________________ Julio E. Portilla, Esq. Attorney for [Party] 380 Lexington Avenue, Suite 446, New York, NY 10168 · (212) 365-0292 [Attach: copy of pleadings if required by part rules; HIPAA authorization or proposed so-ordered subpoena for medical records (CPLR 3122(a)(2)); notice to all parties (CPLR 3120(3)).]

STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) [SERVER NAME], being duly sworn, deposes and says: I am over 18 years of age, not a party to this action, and reside in [County], New York. On [DATE], I served the within [DOCUMENT] upon: [NAME / FIRM], [ADDRESS] — attorney for [party] by depositing a true copy, enclosed in a postpaid properly addressed wrapper, in an official depository under the exclusive care and custody of the United States Postal Service within the State of New York, by [first-class mail / certified mail, return receipt requested, Article No. ____________ ]. ________________________ [Server] Sworn to before me this ___ day of [Month], 20__ ________________________ Notary Public

MATTER | DOCUMENT | ADDRESSEE | DATE MAILED | CERTIFIED ARTICLE NO. | FIRST-CLASS ALSO (Y/N) | RETURN RECEIPT DATE | SCANNED TO FILE (Y/N) | NYSCEF DOC NO. -------|----------|-----------|-------------|-----------------------|------------------------|---------------------|-----------------------|--------------- | | | | 9407 1234 5678 9012 34| | | | Rules of the log: a notice is not "sent" until the article number is in this row. RPAPL 1304 requires BOTH certified and first-class, separate envelope, to each borrower, at the property and last known address — one row each.

[ ] Updated Statement of Net Worth, sworn, served and filed (202.16(k)) [ ] Statement of Proposed Disposition, served and filed (202.16(h)) — see draft below [ ] Witness list with the subject of each witness's testimony [ ] Exhibit list; exhibits pre-marked; three sets (court / adversary / witness) [ ] Expert reports exchanged (appraisals, pension valuation, business valuation) per 202.16(g) [ ] Pretrial memorandum if Part rules require one [ ] Subpoenas served; return dates confirmed [ ] Stipulated facts and stipulated exhibits agreed with opposing counsel — reduce what has to be proved [ ] Client prepared: direct outline reviewed; cross-exam topics anticipated [ ] Settlement position updated after the Nov 5 conference

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------x [PLAINTIFF] FARUOLO, Index No. 365472/2022 Plaintiff, -against- STATEMENT OF PROPOSED [DEFENDANT] FARUOLO, DISPOSITION Defendant. (22 NYCRR 202.16(h)) --------------------------------------------------------------x [Party] respectfully submits the following statement of proposed disposition. 1. GROUNDS. [DRL § 170(7) — irretrievable breakdown / as pleaded.] 2. MARITAL RESIDENCE. [Address]. Proposed: [exclusive occupancy to ___ until ___ / sale with net proceeds divided ___%/___% / buy-out at $___ based on appraisal dated ___]. 3. EQUITABLE DISTRIBUTION (DRL § 236(B)(5)). a. Marital property schedule: [asset — value — proposed allocation] for each account, vehicle, pension/retirement (QDRO where needed), business interest, other. b. Separate property claims: [asset — basis for separate-property claim — tracing]. c. Credits claimed: [wasteful dissipation / separate-property contributions / carrying costs since commencement]. 4. MAINTENANCE (DRL § 236(B)(6)). Guideline calculation attached. Proposed: [$___ per month for ___ years / none], with deviation factors stated if any. 5. CHILD-RELATED TERMS (if applicable). Custody / parenting time: [ ]. Child support (DRL § 240(1-b)): guideline calculation attached; add-ons [ ]. 6. COUNSEL FEES (DRL § 237). [Requested / opposed], with basis. 7. OTHER. Health insurance, life insurance to secure obligations, tax filing status for [year], debt allocation. Dated: New York, New York [DATE] ________________________ Julio E. Portilla, Esq. Attorney for [Party] 380 Lexington Avenue, Suite 446 New York, NY 10168 (212) 365-0292

PRELIMINARY STATEMENT — one paragraph: what this trial decides and the result [Party] asks for. STATEMENT OF FACTS — marriage date, separation, commencement date (the valuation cutoff for active assets), children, each party's income and earning capacity, the assets in dispute. ARGUMENT I. Equitable distribution should be [ ]% / [ ]% because of the § 236(B)(5)(d) factors that matter here: [duration; contributions as spouse/parent/wage earner; wasteful dissipation; tax consequences; others]. Cite the proof you will offer for each. II. Maintenance: guideline result and why the court should [follow / deviate]. III. Separate-property claims: tracing proof for each. IV. Counsel fees: income disparity and litigation conduct. CONCLUSION — the specific disposition requested, matching the Statement of Proposed Disposition.

[COURT / COUNTY] Index No. [________] [CAPTION] [PARTY]'S SETTLEMENT CONFERENCE STATEMENT (for the conference of [DATE] before [Justice / JHO / Referee]) 1. NATURE OF THE ACTION. [One sentence. E.g., "Partition and sale of real property at [address] held by the parties as tenants in common."] 2. PROCEDURAL POSTURE. [Pleadings closed / discovery status / motions pending / note of issue.] 3. UNDISPUTED FACTS. [Three to five bullets the other side will not contest.] 4. DISPUTED ISSUES. [Each issue in one line, with the party's position.] 5. [PARTY]'S PROPOSAL. Partition matters: [buy-out at $___ within ___ days / sale by referee with net proceeds split ___/___ after credits of $___ for carrying costs, taxes, insurance, repairs paid by [party] since [date]]. Matrimonial matters: [equitable distribution split, maintenance $/term, residence disposition, fee allocation]. 6. AUTHORITY. Counsel has written authority from [client] to resolve within the terms stated above. 7. WHAT WOULD MAKE SETTLEMENT POSSIBLE TODAY. [The one concession from the other side that closes the gap.] Dated: [ ] ________________________ Julio E. Portilla, Esq. 380 Lexington Avenue, Suite 446 New York, NY 10168 · (212) 365-0292

[ ] Title: how held, percentages, deed date [ ] Encumbrances: mortgage balance, liens, taxes owed [ ] Carrying-cost ledger since [date]: who paid what (RPAPL 1201 / equitable accounting credits) [ ] Occupancy: who occupies; fair rental value if an ouster credit is claimed [ ] Appraisal: date, value, who retained the appraiser [ ] Client's walk-away number and preferred structure (buy-out vs. sale)

MATTER: [ ] INDEX: [ ] PART: [ ] PRIOR ORDER DATED: [ ] DEMAND / ITEM | SERVED BY | DUE | STATUS (served / outstanding / overdue) | NOTES Bill of particulars | | | | Document demands (D&I) | | | | Authorizations (HIPAA/records)| | | | Depositions — plaintiff | | | | Depositions — defendant(s) | | | | Non-party subpoenas | | | | IME / physical exam | | | | Expert disclosure (3101(d)) | | | | Note of issue deadline | | | | MOTIONS I MAY NEED: [ ] compel (3124) [ ] protective order (3103) [ ] extend NOI deadline [ ] strike pleading (3126) WHAT I WILL ASK THE COURT FOR TODAY: [one sentence]

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF [BRONX] [CAPTION] Index No. [ ] COMPLIANCE CONFERENCE ORDER Counsel for all parties having appeared on [DATE], it is hereby ORDERED: 1. Outstanding responses to [party]'s demands dated [ ] shall be served on or before [DATE]. 2. Depositions: plaintiff on or before [DATE]; defendant(s) on or before [DATE]; to proceed in the order stated and not to be adjourned without further order. 3. Authorizations for [records] shall be provided on or before [DATE]. 4. Independent medical examination(s) to be designated within [30] days after plaintiff's deposition and held within [45] days of designation. 5. Expert disclosure pursuant to CPLR 3101(d) on or before [DATE]. 6. Plaintiff shall file a note of issue on or before [DATE]. 7. Any further compliance conference: [DATE] at [TIME]. 8. Failure to comply may result in sanctions under CPLR 3126. Dated: [ ] ENTER: ________________ J.S.C.

MATTER: [ ] INDEX: [ ] LENDER / SERVICER: [ ] NEXT DATE: [ ] CPLR 3408 SETTLEMENT CONFERENCE [ ] Has a 3408 conference been held? Dates: [ ] [ ] Released from the conference part? Date and order: [ ] [ ] Loss-mitigation / modification application: submitted [date]; status [ ]; missing-document letters [ ] [ ] Good-faith negotiation record (3408(f)) — document every lender delay; a bad-faith finding tolls interest STANDING (raise in the answer or it is waived) [ ] Note: original or copy attached to complaint? Endorsed in blank or specially? Allonge firmly affixed? [ ] Assignment chain of the mortgage matches the note holder at commencement [ ] Plaintiff in possession of the note on the commencement date — proof in the record? STATUTORY CONDITIONS PRECEDENT [ ] RPAPL 1304 90-day notice: separate envelope, 14-point type, correct housing-counselor list, proof of mailing (certified AND first-class) for each borrower [ ] RPAPL 1306 electronic filing with DFS within 3 business days of the 1304 mailing — proof of filing attached? [ ] RPAPL 1303 notice served with the summons, on colored paper, bold 20-point title [ ] Contractual notice of default under the mortgage (¶ 22 on the standard Fannie/Freddie form) — mailed? content compliant? STATUTE OF LIMITATIONS [ ] Prior acceleration (earlier action or acceleration letter)? Date: [ ] [ ] Six years from acceleration (CPLR 213(4)); FAPA (L. 2022 ch. 821) limits de-acceleration and the savings statute — check whether this action is time-barred OTHER [ ] Default-judgment / order of reference pending? Opposition due [ ] [ ] Affidavit of merit / business-records foundation: is the servicer affiant competent as to the prior servicer's records? [ ] Client's goal: [keep the home / modification / short sale / deed in lieu / time]

"Your Honor, the borrower is [engaged in loss mitigation / has a complete modification package pending since ___]. We ask that the matter remain in [the settlement part / on the status calendar] until the lender issues a decision. We also note the following defects in the lender's compliance: [1304 proof of mailing / 1306 filing / standing]. We reserve all defenses." Then hand up the one-page status chart.

MATTER: [ ] DOCKET: [ ] JUDGE / REFEREE: [ ] TYPE: [Art. 10 / custody (Art. 6) / support (Art. 4) / family offense (Art. 8)] [ ] Petition and any amended petition re-read; the exact finding I am asking for written in one sentence [ ] Witness list and order of proof; each witness's three key facts [ ] Exhibits pre-marked; three sets; business-records certifications (CPLR 4518) in hand for agency, school, medical, police records [ ] Subpoenas served; proof of service; return dates [ ] Article 10 only: FCA § 1046 evidence rules checked — child out-of-court statements need corroboration (1046(a)(vi)); prior-record and hospital records admissibility [ ] Family offense only: elements of each Penal Law offense alleged; preponderance standard (FCA § 832) [ ] Custody only: best-interests factors; forensic report received; Lincoln hearing requested? [ ] Support only: income documentation; CSSA worksheet; imputation argument if applicable [ ] Client prepared for direct and cross; demeanor discussed [ ] Settlement / ACD / consent-finding option discussed with client and with opposing counsel / AFC / agency attorney

"Your Honor, the evidence will show [three facts]. On that record the Court should find [the specific finding]. The petitioner / respondent will offer [witnesses] and [exhibits]."

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK — COMMERCIAL DIVISION ───────────────────────────────────── STEPHEN CHEN, Plaintiff, -against- ASTAIRE CAPITAL LLC, CHRIS ELAM, and JOHN DOES 1–10, Defendants. ───────────────────────────────────── Index No. 653576/2026 Hon. Joel M. Cohen, J.S.C. Part 03M NOTICE OF MOTION TO REARGUE [OR RENEW] PURSUANT TO CPLR 2221 PLEASE TAKE NOTICE that upon the annexed Affirmation of Julio E. Portilla, Esq., dated [DATE], and the Memorandum of Law submitted herewith, Plaintiff Stephen Chen will move this Court at the Courthouse located at 60 Centre Street, New York, New York, [MOTION DATE AND TIME], for an Order: (1) granting reargument [and/or renewal] of the Court's Order dated October 20, 2026 (NYSCEF Doc. No. 34), which granted Defendants' Motion to Compel Arbitration and stayed this action; and (2) upon reargument [and/or renewal], denying Defendants' Motion to Compel Arbitration in its entirety; and (3) granting such other and further relief as the Court deems just and proper. Dated: New York, New York [DATE] Respectfully submitted, THE LAW OFFICE OF JULIO E. PORTILLA, P.C. By: _______________________ Julio E. Portilla, Esq. 380 Lexington Avenue, Suite 446 New York, NY 10168 (212) 365-0292 jp@julioportillalaw.com TO: Rob Dawes, Esq. [Defendants' counsel address] rob@dawes.one

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK — COMMERCIAL DIVISION ───────────────────────────────────── STEPHEN CHEN, Plaintiff, -against- ASTAIRE CAPITAL LLC, CHRIS ELAM, and JOHN DOES 1–10, Defendants. ───────────────────────────────────── Index No. 653576/2026 AFFIRMATION OF JULIO E. PORTILLA, ESQ. IN SUPPORT OF MOTION TO REARGUE [AND/OR RENEW] JULIO E. PORTILLA, an attorney duly admitted to practice law before the Courts of the State of New York, hereby affirms the following under penalty of perjury: 1. I am counsel to Plaintiff Stephen Chen in the above-captioned action. I submit this Affirmation in support of Plaintiff's motion to reargue [and/or renew] the Court's Order dated October 20, 2026 (NYSCEF Doc. No. 34) (the "Order"), which granted Defendants' Motion to Compel Arbitration (Motion Seq. No. 001) and stayed this action pending arbitration. 2. This motion is made pursuant to CPLR 2221(d) [and/or 2221(e)] on the grounds that [SELECT: the Court overlooked or misapprehended the following matters of law or fact / new facts have been discovered that were not available at the time of the prior motion and that would change the Court's determination]. 3. [GROUNDS FOR REARGUE — describe specifically which argument made in Plaintiff's opposition papers the Court did not address in its decision, or which controlling authority was overlooked. Example: "In Plaintiff's Memorandum of Law in Opposition, dated [DATE] (NYSCEF Doc. No. [X]), Plaintiff argued that [ARGUMENT]. The Court's October 20, 2026 Order did not address this argument."] 4. [GROUNDS FOR RENEW (if applicable) — describe new facts and explain why they were not available before. Example: "Since the submission of the motion, Plaintiff has obtained [DOCUMENT/EVIDENCE], which was not previously available because [REASON], and which demonstrates [RELEVANCE TO ARBITRABILITY]."] 5. For the reasons set forth in the accompanying Memorandum of Law, the Court's Order compelling arbitration should be vacated upon reargument [and/or renewal]. WHEREFORE, Plaintiff respectfully requests that the Court grant this motion and enter an Order vacating the October 20, 2026 Order and denying Defendants' Motion to Compel Arbitration. Dated: New York, New York [DATE] ___________________________ Julio E. Portilla, Esq.

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK — COMMERCIAL DIVISION ───────────────────────────────────── STEPHEN CHEN, Index No. 653576/2026 Plaintiff, -against- ASTAIRE CAPITAL LLC et al., Defendants. ───────────────────────────────────── PLAINTIFF'S MEMORANDUM OF LAW IN SUPPORT OF MOTION TO REARGUE [AND/OR RENEW] PURSUANT TO CPLR 2221 PRELIMINARY STATEMENT Plaintiff Stephen Chen respectfully moves for reargument [and/or renewal] of the Court's October 20, 2026 Order granting Defendants' Motion to Compel Arbitration. [SUMMARIZE IN 2-3 SENTENCES WHY THE ORDER SHOULD BE RECONSIDERED.] ARGUMENT POINT I: THE STANDARD FOR REARGUMENT IS SATISFIED A motion to reargue pursuant to CPLR 2221(d) is properly granted where "the court overlooked or misapprehended the relevant facts or misapplied any controlling principle of law." Foley v. Roche, 68 A.D.2d 558, 567 (1st Dep't 1979). The purpose of reargument is not to provide an unsuccessful party the opportunity to present new arguments, but to correct the record where the court has made an error. William P. Pahl Equip. Corp. v. Kassis, 182 A.D.2d 22, 27 (1st Dep't 1992). Here, reargument is warranted because the Court overlooked [OR misapprehended] the following: [INSERT SPECIFIC ARGUMENT — e.g., "Plaintiff's opposition established that the arbitration clause at issue does not encompass the claims alleged in the Complaint because [REASON]. The Court's Order does not address this argument."] POINT II: THE ARBITRATION CLAUSE DOES NOT COMPEL ARBITRATION OF PLAINTIFF'S CLAIMS [INSERT CORE ARBITRABILITY ARGUMENT — address: (a) scope of clause, (b) whether specific claims fall within it, (c) any applicable waiver or unconscionability arguments, (d) controlling First Department authority supporting Plaintiff's position.] [POINT III — ADD ADDITIONAL ARGUMENTS AS APPLICABLE] CONCLUSION For the foregoing reasons, Plaintiff respectfully requests that the Court grant reargument and, upon reargument, vacate the October 20, 2026 Order and deny Defendants' Motion to Compel Arbitration in its entirety. Dated: New York, New York [DATE] THE LAW OFFICE OF JULIO E. PORTILLA, P.C. By: Julio E. Portilla, Esq.

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK — COMMERCIAL DIVISION ───────────────────────────────────── STEPHEN CHEN, Plaintiff-Appellant, -against- ASTAIRE CAPITAL LLC, CHRIS ELAM, and JOHN DOES 1–10, Defendants-Respondents. ───────────────────────────────────── Index No. 653576/2026 Hon. Joel M. Cohen, J.S.C. NOTICE OF APPEAL PLEASE TAKE NOTICE that Plaintiff-Appellant Stephen Chen hereby appeals to the Appellate Division of the Supreme Court of the State of New York, First Judicial Department, from the Order of the Supreme Court, New York County, Commercial Division (Cohen, J.S.C.), entered on October 20, 2026 (NYSCEF Doc. No. 34), which granted Defendants' Motion to Compel Arbitration (Motion Seq. No. 001) and stayed this action pending arbitration, and from each and every part thereof. Dated: New York, New York [DATE] Respectfully submitted, THE LAW OFFICE OF JULIO E. PORTILLA, P.C. By: _______________________ Julio E. Portilla, Esq. 380 Lexington Avenue, Suite 446 New York, NY 10168 (212) 365-0292 jp@julioportillalaw.com Attorney for Plaintiff-Appellant Stephen Chen TO: Rob Dawes, Esq. Counsel for Defendants-Respondents rob@dawes.one Clerk of the Court Supreme Court, New York County 60 Centre Street New York, NY 10007

[DATE] VIA [AAA ONLINE FILING / JAMS ONLINE FILING] AND VIA EMAIL TO: rob@dawes.one American Arbitration Association [OR JAMS] [FORUM ADDRESS] Re: Demand for Arbitration Stephen Chen v. Astaire Capital LLC, Chris Elam, and John Does 1–10 Arising from [DESCRIBE UNDERLYING AGREEMENT — e.g., "Investment Agreement dated [DATE]"] Dear Case Filing Team: Pursuant to the arbitration clause contained in [IDENTIFY AGREEMENT AND CLAUSE — e.g., "Section [X] of the [Agreement Name] dated [DATE]"], Claimant Stephen Chen hereby demands arbitration against Respondents Astaire Capital LLC and Chris Elam. PARTIES Claimant: Stephen Chen c/o The Law Office of Julio E. Portilla, P.C. 380 Lexington Avenue, Suite 446 New York, NY 10168 jp@julioportillalaw.com Respondents: Astaire Capital LLC [ADDRESS] Chris Elam [ADDRESS] Counsel: Rob Dawes, Esq. — rob@dawes.one NATURE OF DISPUTE [DESCRIBE THE CLAIMS — e.g., "This dispute arises from Respondents' breach of [the Agreement], including [specific breaches]. Claimant seeks damages arising from [nature of harm]."] AMOUNT IN CONTROVERSY Claimant seeks damages in an amount to be determined, but no less than $[AMOUNT], plus interest, attorneys' fees [IF PROVIDED BY AGREEMENT OR STATUTE], and costs. ARBITRATION CLAUSE The parties agreed to arbitrate disputes arising from [THE AGREEMENT] pursuant to [QUOTE THE CLAUSE VERBATIM]. This demand is made in accordance with that clause and the [AAA Commercial Arbitration Rules / JAMS Comprehensive Arbitration Rules]. RELIEF REQUESTED Claimant requests: (1) a full arbitration hearing on the merits; (2) an award of damages in an amount no less than $[AMOUNT]; (3) [ADDITIONAL RELIEF]; and (4) such other relief as the arbitrator(s) deem just. Enclosed herewith is Claimant's filing fee in the amount of $[CHECK AAA/JAMS FEE SCHEDULE]. Respectfully submitted, THE LAW OFFICE OF JULIO E. PORTILLA, P.C. By: _______________________ Julio E. Portilla, Esq. cc: Rob Dawes, Esq. (rob@dawes.one) NYSCEF — Index No. 653576/2026 [file notice of commencement]

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK — COMMERCIAL DIVISION ───────────────────────────────────── STEPHEN CHEN, Plaintiff-Appellant, -against- ASTAIRE CAPITAL LLC, CHRIS ELAM, and JOHN DOES 1–10, Defendants-Respondents. ───────────────────────────────────── Index No. 653576/2026 Hon. Joel M. Cohen, J.S.C. NOTICE OF MOTION FOR STAY OF ORDER PENDING APPEAL PURSUANT TO CPLR 5519(c) PLEASE TAKE NOTICE that Plaintiff-Appellant Stephen Chen moves this Court, pursuant to CPLR 5519(c), for an Order staying enforcement of the Court's Order dated October 20, 2026 (NYSCEF Doc. No. 34) — including the requirement that Plaintiff commence arbitration within 90 days — pending determination of Plaintiff-Appellant's appeal to the Appellate Division, First Department. GROUNDS: Plaintiff-Appellant has filed a Notice of Appeal from the October 20, 2026 Order. Absent a stay, Plaintiff will be required to commence arbitration by January 18, 2027, rendering the appeal potentially moot or prejudicially expensive if the Appellate Division subsequently determines that arbitration was improper. Plaintiff demonstrates: (1) likelihood of success on the merits of the appeal [SUMMARIZE GROUNDS]; (2) irreparable harm absent a stay [DESCRIBE — e.g., cost and burden of arbitration that cannot be undone]; (3) a balancing of equities favoring a stay; and (4) no substantial prejudice to Defendants from a brief stay pending appeal. [AFFIRMATION AND MEMORANDUM OF LAW TO FOLLOW — adapt from CPLR 2221 memorandum framework, substituting stay-pending-appeal standard from Grisi v. Shainswit, 119 A.D.2d 418 (1st Dep't 1986)] Dated: New York, New York [DATE] THE LAW OFFICE OF JULIO E. PORTILLA, P.C. By: _______________________ Julio E. Portilla, Esq. TO: Rob Dawes, Esq. rob@dawes.one

[DATE] VIA NYSCEF Hon. Joel M. Cohen, J.S.C. Supreme Court, New York County Commercial Division, Part 03M 60 Centre Street New York, NY 10007 Re: Chen v. Astaire Capital LLC et al. Index No. 653576/2026 — Joint Status Letter Dear Justice Cohen: We write jointly on behalf of Plaintiff Stephen Chen and Defendants Astaire Capital LLC and Chris Elam, pursuant to the Court's Order dated October 20, 2026, to provide a status update on the arbitration proceedings in the above-captioned matter. STATUS OF ARBITRATION [OPTION A — IF ARBITRATION COMMENCED:] Arbitration was commenced on [DATE] by the filing of a Demand for Arbitration with [AAA / JAMS], Case No. [FORUM CASE NUMBER]. The parties are [currently in the arbitrator selection process / engaged in preliminary proceedings / [OTHER STATUS]]. [OPTION B — IF CPLR 2221 OR APPEAL PENDING:] Plaintiff filed a motion to reargue [and/or appeal] the Court's October 20, 2026 Order on [DATE]. That motion [or appeal] is currently pending. [Plaintiff has also commenced arbitration as required by the Court's Order / Plaintiff intends to commence arbitration by the January 18, 2027 deadline notwithstanding the pending motion.] ANTICIPATED NEXT STEPS The parties anticipate [DESCRIBE — e.g., "completing arbitrator selection by [DATE] and proceeding to a preliminary hearing in [MONTH]"]. The parties will submit the next status letter on or before [DATE — 180 days from this letter]. Respectfully submitted, THE LAW OFFICE OF JULIO E. PORTILLA, P.C. [DEFENDANTS' COUNSEL FIRM] By: ___________________________ By: ___________________________ Julio E. Portilla, Esq. Rob Dawes, Esq. Counsel for Plaintiff Counsel for Defendants