Case 1:24-mc-00353-LJL Document 83 Filed 11/05/24 Page 1 of 1 KENNETH CARUSO LAW 15 West 720d Sireet | New York, NY 10023 E: ken.caruso@kennethearusolaw.com | P: (646) 5994970 November 5, 2024 ViaECP Hon, Lewis J. Liman United States Distict Judge. Daniel Patick Moynihan United Staes Courthouse 500 Pear St. New York, NY 10007-1312 Re: Freeman et al. v Giuiani, 24-me-00353-LIL. Dear Judge Liman: Irepresent M. Giuliani (“Defendant). 1 writ in response 0 the Court’s Orders, entered. on November 4, 2024, and November 5, 2024, directing an in-person conference on November 7, 2024 (ather than a telephone conference), and directing M. Giuliani o appear i person T am informed that M. Giuliani has a contractual commitment, with Frank Specch Network, o perform a liv radio broadeast at 7:00 pm on November 7, 2024 (and also o November 8). In order to keep this commitment, he necds o be in his condo in Palm Beach, where he has his broadcasting equipment. Aceordingly, we ask the Court o revert o the prior order for a elephone conference on November 7, 2024, or 0 reschedule an in-person conference 0 a date next week. Finally, we note that broadeasts, such as those described above, currntly provide M. Giuliani’s only source of earned income. We respetflly suggest hat loss of income, and an expense for travel o New York, should be avoided, if possible Respectfully submitted, [/ Kenneth A, Caruso Kenneth A Caruso ce: Counsel of Record (via ECF)
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