Case 1:18-mj-03161-KMW Document 71 Filed 06/01/18 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------------X In the Matter of Search Warrants Executed on April 9, 2018 --------------------------------------------------------X USDSSDNY DOCUMENT ELECTRONICALLY FILED DOC#: Li Date: May 30, 2018 at 9:09:00 AM EDT To: "Joanna Hendon, Esq." , "Christopher W. Dysard" Subject: FW: Clifford v. Trump: Stipulation and Proposed Order Re Motion for Reconsideration From: Ahmed Ibrahim [mailto:aibrahim@eaganavenatti.com] Sent: Wednesday, May 23, 2018 11:41 AM To: Brent Blakely (bblakely@blakelylawgroup.com); Charles Harder; Ryan Stonerock Cc: Michael J. Avenatti; Judy K. Regnier Subject: Clifford v. Trump: Stipulation and Proposed Order Re Motion for Reconsideration Counsel: Attached 1s a stip and order regarding the briefing schedule and hearing on Pla1nt1ff's motion for reconsideration discussed on the call earlier. We would like to get this on file today, so please let us know 1f you have any changes. Thank you. Ahmed Ibrahim, Esq. EAGAN AVENATTI, LLP 520 Newport Center Drive, Suite 1400 Newport Beach, CA 92660 (949) 706-7000 (949) 706-7050 (Fax) ajbrahim@eaganavenattj.com The preceding email message (1nclud1ng any attachments) contains 1nformat1on that may be conf1dent1a1, protected by the attorney-client or other applicable privileges, or constitutes non-public information It 1s intended to be conveyed only to the designated rec1p1ent(s). If you are not an intended recipient of this message, please notify the sender by replying to this message and then delete it from your system use, d1ssem1nat1on, or reproduction of this message by unintended rec1p1ents 1s not authorized and may be unlawful ..,, " Case 1:18-mj-03161-KMW Document 71 Filed 06/01/18 Page 3 of 6 From: Charles Harder Date: May 30, 2018 at 9: 10:42 AM EDT To: "Joanna Hendon, Esq." , "Christopher W. Dysard" Subject: FW: Meeting today From: Michael J. Avenatti [mailto:mavenatti@eaganavenatti.com] Sent: Thursday, April 12, 2018 8:43 AM To: Charles Harder Cc: Ahmed Ibrahim; Brent H. Blakely Esq.; Ryan Stonerock Subject: Re: Meeting today Counsel: This is not acceptable. You are the one that has made these meet and confers a much larger issue than they needed be - going so far as to raise them with the Court in a very public manner. Accordingly, it is not acceptable for you to now refuse to meet and confer in person. You demanded this and now need to act accordingly. We went through the inconvenience to come to your office the first time - we dealt with the traffic. It was agreed that the next meet and confer would be in our office, which is only equitable. We then accommodated you by phone out of courtesy for your trial (with Mr. Harder failing to participate) You repaid that favor by filing baseless attacks against me on the public record. You followed that up with your recent objection, by which you again attempted to soil us with the Court and defeat our motion by technicality. To be clear, if the meet and confers are important enough for you to attack us not once but twice, then they are important enough for you to comply with the Court's Order. We will expect to have at least one attorney present from each party at our office for the meet and confer. If you would like to participate by phone, we have no objection provided another lawyer representing your client is present. The same holds true for Mr. Harder. Please let us know what time works. Case 1:18-mj-03161-KMW Document 71 Filed 06/01/18 Page 4 of 6 Michael Michael J. Avenatti, Esq. Eagan A venatti, LLP 520 Newport Center Drive, Ste. 1400 Newport Beach, CA 92660 Tel: (949) 706-7000 Fax: (949) 706-7050 Cell: (949) 887-4118 mavenattj@ea.ganavenatti.com The preceding email message (including any attachments) contains information that may be confidential, protected by the attorney-client or other applicable privileges, or constitutes non-public information. It is intended to be conveyed only to the designated recipient(s). If you are not an intended recipient of this message, please notify the sender by replying to this message and then delete it from your system. Use, dissemination, or reproduction of this message by unintended recipients is not authorized and may be unlawful. On Apr 12, 2018, at 11 :30 AM, Charles Harder wrote: Dear Mr. A venatti: Mr. Blakely is available to drive down to your office today, for a meeting around 12 noon. I am available to call into the meeting at that time. My office is much further away from yours than Mr. Blakely's, and my schedule today does not allow me to spend three hours in Southern California traffic, for what will probably be a 30-40 minute meeting. Would you mind if I participated by telephone? If you insist on a meeting with everyone physically present, I can host the meeting at my office in Beverly Hills. Also, will you be physically present at the meeting? Because you were not present at the last in person meeting - you called into the meeting, where Mr. Blakely and I were both physically present. Thank you. Sincerely, Charles J. Harder HARDERLLP 132 S. Rodeo Drive, Fourth Floor Beverly Hills, CA 90212 (424) 203-1600 ?'rl Case Document 71 Filed 06/01/18 Page 5 of 6 Case 1:18-mj-03161-KMW Document 71 Filed 06/01/18 Page 6 of 6 From: Charles Harder Date: May 30, 2018 at 9:09:28 AM EDT To: "Joanna Hendon, Esq." , "Christopher W. Dysard" Subject: FW: Clifford v. Trump: SONY Action From: Ahmed Ibrahim [maHto:aibrahim@eaganavenatti.com] Sent: Tuesday, May 22, 2018 5:59 PM To: Charles Harder Cc: Michael J. Avenatti Subject: Clifford v. Trump: SDNY Action Dear Charles, As you probably know, we filed a separate action against your client, Mr. Trump, for defamation. Attached 1s a copy of the Complaint. Will you please advise whether you will accept service on Mr. Trump's behalf? If so, we can draw up the necessary paperwork. Thank you. Ahmed Ibrahim, Esq. EAGAN AVENATTI, LLP 520 Newport Center Drive, Suite 1400 Newport Beach, CA 92660 (949) 706-7000 (949) 706-7050 (Fax) aibrahim@eaaanaveoatli,com The preceding email message (1nclud1ng any attachments) contains 1nformat1on that may be confidential, protected by the attorney-cl,ent or other applicable pr,v,leges, or constitutes non-public 1nformat1on it 1s intended to be conveyed only to the designated rec,p1ent(s) If you are not an intended rec,p1ent of this message, please not,fy the sender by reply,ng to this message and then delete 1t from your system Use, d1ssem1nat1on, or reproduction of this message by unintended rec,p1ents is not authorized and may be unlawful