Defendant has acted in good faith and has not violated any rights that may be secured to Plaintiff under any federal, state, or local laws, rules, regulations and guidelines.

Plaintiff was barred from recovering based on equitable doctrines, including, without limitation, laches, unclean hands, waiver, and estoppel, and prior administrative proceedings.

Defendant has met and satisfied any and all obligations to Plaintiff that arose out of and during its respective employment and, therefore, this action is barred, in whole or in part, by the doctrine of accord and satisfaction.

To the extent payments were made in good faith and in conformity with and in reliance on an administrative regulation, order, ruling, approval, interpretation, administrative practice, and enforcement policy of the United States Department of Labor and New York State Department of Labor and Workforce Development, Defendant cannot be liable for relief or recovery.

Plaintiff’s claim for damages for failure to provide them with wage statements pursuant to Section 195(3) of NYLL is barred because (i) Defendant made complete and timely payment of all wages due to Plaintiff or (ii) Defendant reasonably believed in good faith that it was not required to provide the employee with statements pursuant to Section 195 of NYLL.

IT IS HEREBYSTIPULATED ANDAGREEDby and between the Parties and including December 30, Defendants time to answer the complaint is hereby extended until that the 2024.

IT IS FURTHERSTIPULATED ANDAGREEDthat Defendant agrees to waive all defenses relating to jurisdiction.

IT IS FURTHERSTUPULATEDANDAGREEDthat this Stipulation may be signed in counterparts and that a facsimile and/or electronic signature shall be considered and deemed original signatures.

Dated: Flushing, NewYork November 15, 2024 HORNWRIGHT,LLP

By: Neil Flynn, E .

Plaintiff SOON BOON KIM, by her attorneys, Horn Wright, LLP, for her Complaint against Defendant CASTLE NAILS SALON, INC., alleges upon information and belief:

Failure to Pay Overtime Wages in Violation of New York Labor Law, Article 6 Plaintiff repeats, reiterates, and realleges each and every allegation contained in

Failure to Provide Timely and Accurate Wage Statements in Violation of New York Labor Law, Article 6 Plaintiff repeats, reiterates, and realleges each and every allegation contained in

Failure to Provide Notice of Pay Rate in Violation of New York Labor Law, Article 6 Plaintiff repeats, reiterates, and realleges each and every allegation contained in

As a result of Defendants’ actions, Plaintiff has suffered damages in an amount that exceeds the monetary jurisdictional limits of all lower New York State Courts.

PLEASE TAKE NOTICE THAT CASTLE NAILS SALON, INC., by and through its undersigned attorneys, pursuant to Section 3120 of the Civil Practice Law and Rules (“CPLR”), hereby request that Plaintiff SOON BOON KIM (“Plaintiff”) produce and permit discovery by Defendant, or someone acting on its behalf, of the documents and things that are specified herein and are in Plaintiff’s possession, custody or control, for inspection and copying at the offices of Hang & Associates, PLLC, Attorneys for Defendant, 13620 38th Ave., Ste 10G, Flushing, NY 11354, within thirty (30) days of service; or true copies of said documents and things may be delivered on or before that date to the same address within thirty (30) days of service.

This definition includes (but is not limited to) correspondence, memoranda, wires, cables, studies, maps, analyses, diagrams, electronic mail, scraps of paper, notes, loan documentation, application, drawings, charts, graphs, plans, plates, photographs, contracts, agreements, working papers, drafts, reports of investigations or inspections of any kind, diaries, minutes, calendars, other reports, vouchers, invoices, journals, bills, orders, time slips or records, books, computations, field notes, logs, financial records or statements, or work papers, checks, receipts, bank statements, and the like.

All documents that refer or relate to the days and hours that Plaintiff actually worked for the Defendant, including, but not limited to, pay stubs and timecards.

Electronic copies of Plaintiff’s complete profile on any and all social network websites, including but not limited to Facebook, Friendster.com, MySpace.com, linkedin.com, Monster.com including all updates, pictures, changes, or modifications to Plaintiffs’ profile, and all status updates, messages, wall comments, causes joined, groups joined, activity streams, blog entries, details, blurbs, comments, applications, job applications filed, and resume postings for the period from April 13, 2019 to the present.

Any written statements, affidavits or calculations that Plaintiff or anyone else has made concerning Plaintiff’s wages, hours, or terms of employment with Defendants.

PLEASE TAKE NOTICE THAT, pursuant to Rule 3107 of the Civil Practice Law and Rules, Defendant CASTLE NAILS SALON, INC., will take the deposition upon oral examination of SOON BOON KIM via Zoom video conference, on a date and time to be agreed upon by the parties.

The deposition shall be taken before a duly authorized officer who is certified to administer oaths and take depositions, and a licensed stenographer.

The taking of this deposition may continue from day to day or be adjourned to a date as may be agreed upon, until completed.

Please take further notice that Plaintiff SOON BOON KIM is directed to produce at this deposition all records identified in Defendant’s First Set of Interrogatories and Defendant’s First Notice of Discover and Production Document Requests that have not been previously produced.

Dated: Flushing, New York February 20, 2025

Defendant CASTLE NAILS SALON, INC., by and through its undersigned attorneys, Pursuant to Section 3130 of the Civil Practice Law and Rules (“CPLR”), hereby propounds the following Interrogatories (the “Interrogatories”) to be answered by Plaintiff SOON BOON KIM (“Plaintiff”) in writing under oath within thirty (30) days of the date of service.

State the start and end dates of your employment at CASTLE NAILS SALON, INC. Interrogatory No.2: From April 13, 2019, to July 11, 2024, please list in full detail all information about (1) occupation in which Plaintiff was engaged; (2) Plaintiff’s salaries; and (3) rate of payment.

Interrogatory No.6: State if Plaintiff has ever been charged with a crime resulting in conviction, probation, community service, withhold of adjudication, pre-trial diversion, jail sentence, or revocation/suspension of their driver’s license.

Interrogatory No.7: Identify any person who has knowledge or information regarding Plaintiff’s alleged employment at CASTLE NAILS SALON, INC. Interrogatory No.8: For every workweek during your employment at CASTLE NAILS SALON, INC. that you worked more than 40 hours and for which you allege you were not properly compensated for overtime pay under the Fair Labor Standards Act or the New York Labor Law, state the precise number of hours you claim you worked and the rate of overtime that you believe you are owed.

Interrogatory No.15: State if You have made any type of complaint (written, verbal, formal, informal), or who expressed any concern, regarding Defendants' wage and hour practices or policies.

Female Color of skin: White Hair color: Blonde Other: , being duly sworn, deposes and says: deponent Sean Warner in the State of NY, and that on and resides is not a party to this the age of eighteen (18) years; action, 2:29 PM , at November25, 2024 of State of the State of NY, of the Secretary the office , at at 99 Washington Ave, 6th FI, Albany, NewYork 12231 deponent served: located

is over on Castle Nails Salon, Inc. , Sue Zouky to and leaving with the Defendant by delivering in this action, of State, of the State of NewYork, personally AUTHORIZEDAGENTin the Office of the Secretary of State of the State of NewYork, thereof and that at two (2) true copies Office of the Secretary $40 That said service of State a fee of making such service, deponent paid said Secretary

was madepursuant to Section at the the time of dollars; Deponent further of the Secretary defendant.

to be the agent says that deponent knew the person so served as aforesaid in the Office of State of the State of NewYork, duly authorized to acce t such service on behalf of said Sworn to before meon this --- 25th day of November, 2024

NOTARYPUBLIC, State of NewY No. 01cO6158874, Albany County Commission Expires Jan 8, 2027 Sean Warner Invoice-Work Order # 2454344 File # 24-1086 Attorney