Case 1:24-cv-05347-PKC-LKE Document 32 Filed 06/16/25 Page 1 of 3 PageID #: 638 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK LOIS MARTIN, individually and on behalf of all others similarly situated, NOTICE OF DEFENDANTS’ MOTION Plaintiffs, TO DISMISS PLAINTIFFS’ AMENDED CLASS ACTION COMPLAINT v. Oral Argument Requested ARBOR REALTY TRUST, INC., IVAN KAUFMAN, and PAUL ELENIO, 1:24-cv-05347-PKC-LKE Defendants. PLEASE TAKE NOTICE that Defendants Arbor Realty Trust, Inc., Ivan Kaufman, and Paul Elenio (collectively, “Defendants”), by and through their respective counsel, shall move before the Honorable Pamela K. Chen, United States District Judge for the Eastern District of New York, at a date and time to be set by the Court, in Courtroom 4F of the United States District Courthouse at 225 Cadman Plaza East, Brooklyn, NY 11201 for an Order dismissing Plaintiffs’ Amended Class Action Complaint dated January 21, 2025, with prejudice pursuant to Federal Rules of Civil Procedure 9(b) and 12(b)(6) and the Private Securities Litigation Reform Act of 1995, 15 U.S.C. § 78u-4 et seq., and granting Defendants such other and further relief as the Court may deem just and proper. PLEASE TAKE FURTHER NOTICE that in support of the Motion to Dismiss, Defendants will rely upon the accompanying Memorandum of Law in Support of Their Motion to Dismiss the Amended Class Action Complaint, the Declaration of Angela M. Liu, dated April 10, 2025, with attached exhibits, and all pleadings filed with the Court in this matter. Case 1:24-cv-05347-PKC-LKE Document 32 Filed 06/16/25 Page 2 of 3 PageID #: 639 Dated: April 10, 2025 Respectfully submitted, By: /s/Andrew J. Levander Andrew J. Levander Neil A. Steiner Angela M. Liu DECHERT LLP Three Bryant Park 1095 Sixth Avenue New York, NY 10036 Tel: (212) 698-3500 andrew.levander@dechert.com neil.steiner@dechert.com angela.liu@dechert.com Attorneys for Defendants Case 1:24-cv-05347-PKC-LKE Document 32 Filed 06/16/25 Page 3 of 3 PageID #: 640 CERTIFICATE OF SERVICE I, the undersigned, hereby certify that on this 10th day of April 2025, I caused a copy of the foregoing document to be transmitted by email and First-Class mail to all counsel of record. In accordance with Rule 3.D. of the Honorable Judge Pamela K. Chen’s Individual Practices and Rules, on the day the motion is fully briefed, I shall direct that a copy of all motion papers be electronically filed with the Court, which will automatically send notice and a copy of the filings to all counsel of record. /s/Andrew J. Levander Andrew J. Levander