Parties Postpone Subpoena Enforcement in Trump Records Dispute

September 26, 2019

Judge Victor Marrero
U.S. District Court Judge
Southern District of New York
500 Pearl Street, New York, N.Y.

Re: Donald J. Trump v. Cyrus R. Vance, Jr.
Case No. 1:19-cv-08694 (VM)

Dear Judge Marrero:

We represent the office of Cyrus R. Vance, Jr., District Attorney of New York County (the “Office”), a defendant in this matter.

Pursuant to the Court's order of September 25, 2019 (Dkt. # 25), and without prejudice to any right asserted by any patty, we write to inform the Court that the parties have reached a temporary arrangement.

The Office agrees to forbear enforcement of Mazars USA LLP's (“Mazars”) obligations to produce documents pursuant to the Mazars subpoena at issue in this litigation until 1:00 p.m. two business days after the Court rules on the pending motions to dismiss and for injunctive relief, or until 1:00 p.m. on Monday, October 7, 2019, whichever is sooner. In the interim, the parties agree that Mazars will resume gathering and preparing all documents responsive to the subpoena. The parties further agree that, subject to a contrary court order, Mazars will begin a rolling production of such documents immediately upon the expiration of this agreement, with Mazars' first production to be made by hand delivery at 4:00 p.m. on the day this agreement expires.

We are available at the Court's convenience should any questions arise concerning this undertaking.

Very truly yours,

Carey R. Dunne, General Counsel
Christopher Conroy
Solomon B. Shinerock
James H. Graham
Allen J. Vickey
Assistant District Attorneys
New York County District Attorney's Office

Agreed on September 26, 2019:

William Consovoy
Marc Mukasey
Alan Futerfas
Counsel of Record for the Plaintiff

Jerry D. Bernstein
Inbal Paz Garrity
Nicholas R. Tambone
Counsel of Record for Defendant Mazars USA, LLP

CC:
all counsel of record (via email)