From: chris kise
To: Wallace, Kevin
Cc:
ckise@continentalpllc.com
Subject: Re: People v. Trump, et al., No. 452564/2022
Date: Wednesday, October 25, 2023 5:32:48 PM
yes haystack has run the searches and is now de-duplicating etc the population
so we have at least a starting point.
thanks.
best
From: Wallace, Kevin <
Kevin.Wallace@ag.ny.gov>
Date: Wednesday, October 25, 2023 at 7:34 AM
To: chris kise <
chris@ckise.net>
Subject: RE: People v. Trump, et al., No. 452564/2022
Chris –
I wanted to follow-up on this and see if this was something the Defendants were still planning to
turn over. If not we can send the Court the expanded letter it requested.
Thanks,
KCW
From: chris kise <
chris@ckise.net>
Sent: Thursday, October 19, 2023 8:02 PM
To: Wallace, Kevin <
Kevin.Wallace@ag.ny.gov>
Subject: Re: People v. Trump, et al., No. 452564/2022
thanks for the email.
let’s discuss in the morning but i think this can work.
From: Wallace, Kevin <
Kevin.Wallace@ag.ny.gov>
Date: Thursday, October 19, 2023 at 7:01 PM
To: chris kise <
chris@ckise.net>
Subject: RE: People v. Trump, et al., No. 452564/2022
Chris –
5 of 9
Dropped the others from this thread. Taking you up on the offer to have Haystack undertake a
review, could we agree to have Haystack conduct a sweep of data from September 2016 with the
following search terms:
Forbes
Ekovich
NOI
Trepp
Niketown
“40 Wall”
Triplex
Penthouse
“Joel R. Anderson”
10,996.39
“1290 Avenue”
“555 California”
“per key”
“Palos Verdes”
“residential lots”
“seven springs”
Both sides could then review the results to determine if there are any unproduced responsive
documents and if there are figure out how to proceed from there. (Depending on the volume
Defendants could manually pull privileged docs or do an automated pull.)
Happy to discuss this approach tomorrow morning.
KCW
From: chris kise <
chris@ckise.net>
Sent: Thursday, October 19, 2023 7:53 AM
To: Wallace, Kevin <
Kevin.Wallace@ag.ny.gov>; Allison R. Greenfield <
argreenf@nycourts.gov>
Cc: Hon. Arthur Engoron <
aengoron@nycourts.gov>; Garth A. Johnston <
GAJOHNST@nycourts.gov>;
crobert@robertlaw.com;
ahabba@habbalaw.com;
barbara.jones@bracewell.com; Kokalas, Tom
<
thomas.kokalas@bracewell.com>;
ckise@continentalpllc.com; Amer, Andrew
<
Andrew.Amer@ag.ny.gov>; Faherty, Colleen <
Colleen.Faherty@ag.ny.gov>; Solomon, Louis
<
Louis.Solomon@ag.ny.gov>
Subject: Re: People v. Trump, et al., No. 452564/2022
Suggest you wait until 10 as nothing will happen between now and then
anyway.
And the distraction of potentially needless escalation is something neither of us
has time for.
6 of 9
From: Wallace, Kevin <
Kevin.Wallace@ag.ny.gov>
Date: Thursday, October 19, 2023 at 7:37 AM
To: chris kise <
chris@ckise.net>, Allison R. Greenfield <
argreenf@nycourts.gov>
Cc: Hon. Arthur Engoron <
aengoron@nycourts.gov>, Garth A. Johnston
<
GAJOHNST@nycourts.gov>,
crobert@robertlaw.com <
crobert@robertlaw.com>,
ahabba@habbalaw.com <
ahabba@habbalaw.com>,
barbara.jones@bracewell.com
<
barbara.jones@bracewell.com>, Kokalas, Tom <
thomas.kokalas@bracewell.com>,
ckise@continentalpllc.com <
ckise@continentalpllc.com>, Amer, Andrew
<
Andrew.Amer@ag.ny.gov>, Faherty, Colleen <
Colleen.Faherty@ag.ny.gov>, Solomon, Louis
<
Louis.Solomon@ag.ny.gov>
Subject: RE: People v. Trump, et al., No. 452564/2022
Baring alternative direction from the Court we will file the letter on NYSCEF at 8:00 am.
From: chris kise <
chris@ckise.net>
Sent: Thursday, October 19, 2023 7:08 AM
To: Allison R. Greenfield <
argreenf@nycourts.gov>; Wallace, Kevin <
Kevin.Wallace@ag.ny.gov>
Cc: Hon. Arthur Engoron <
aengoron@nycourts.gov>; Garth A. Johnston <
GAJOHNST@nycourts.gov>;
crobert@robertlaw.com;
ahabba@habbalaw.com;
barbara.jones@bracewell.com; Kokalas, Tom
<
thomas.kokalas@bracewell.com>;
ckise@continentalpllc.com; Amer, Andrew
<
Andrew.Amer@ag.ny.gov>; Faherty, Colleen <
Colleen.Faherty@ag.ny.gov>; Solomon, Louis
<
Louis.Solomon@ag.ny.gov>
Subject: Re: People v. Trump, et al., No. 452564/2022
[EXTERNAL]
Good morning.
Suggest respectfully we first discuss this at sidebar today before having it
develop further.
Thank you.
Respectfully,
Chris Kise
From: Allison R. Greenfield <
argreenf@nycourts.gov>
Date: Thursday, October 19, 2023 at 7:06 AM
To: Wallace, Kevin <
Kevin.Wallace@ag.ny.gov>
7 of 9
Cc: Hon. Arthur Engoron <
aengoron@nycourts.gov>, Garth A. Johnston
<
GAJOHNST@nycourts.gov>, chris kise <
chris@ckise.net>,
crobert@robertlaw.com
<
crobert@robertlaw.com>,
ahabba@habbalaw.com <
ahabba@habbalaw.com>,
barbara.jones@bracewell.com <
barbara.jones@bracewell.com>, Kokalas, Tom
<
thomas.kokalas@bracewell.com>,
ckise@continentalpllc.com <
ckise@continentalpllc.com>,
Amer, Andrew <
Andrew.Amer@ag.ny.gov>, Faherty, Colleen <
Colleen.Faherty@ag.ny.gov>,
Solomon, Louis <
Louis.Solomon@ag.ny.gov>
Subject: Re: People v. Trump, et al., No. 452564/2022
Dear Mr. Wallace,
Justice Engoron has directed that you file the attached letter on NYSCEF.
Thank you.
Sent from my iPhone
On Oct 18, 2023, at 7:17 PM, Wallace, Kevin <
Kevin.Wallace@ag.ny.gov> wrote:
Your Honor,
Please see the attached letter concerning the sidebar held on Thursday, October 12,
2023.
Respectfully submitted,
KCW
Kevin Wallace
Senior Enforcement Counsel
Economic Justice Division
New York State Office of the Attorney General
28 Liberty Street | New York, NY 10005
Tel: 212.416.6376 |
kevin.wallace@ag.ny.gov
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8 of 9
<2023.10.18.letter.pdf>