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Hon. Lewis J. Liman United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Freeman et al. v. Giuliani, No. 24-mc-353 (LJL Dear Judge Liman: Plaintiffs and Receivers Ruby Freeman and Wandrea® Moss (“Plaintiffs™) respectfully submit this report pursuant to the Court’s Order of October 31, 2024 (ECF No. 75) regarding the status of Defendant’s compliance with the October 22, 2024 Turnover and Receivership Order (ECF No. 62) (the “Receivership Order™). As of this writing, Defendant has yet to transfer any property into the Receivers’ custody. More concerningly, and as set forth in more detail below, Defendant and his counsel have refused or been unable to answer basic questions about the location of most of the property subject to the receivership. Meanwhile, when the Receivers’ representatives were finally granted access to the New York Apartment, they learned for the first time upon entering that Defendant had moved virtually all of its contents out approximately four weeks ago—something that neither Defendant nor Defendant’s counsel had bothered to mention. On October 30, 2024, Plaintiffs reported to the Court that a representative of the Receivers’ moving and storage company, along with attorneys for the Receivers, would be provided access to Defendant’s apartment at 45 East 66th Street, Apartment 10W (the “Apartment™). That visit occurred on the morning of October 31, 2024.