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[quote=Anonymous][quote=Anonymous][quote=Anonymous][quote=Anonymous]The Lively letter specifically invokes Liman’s individual rules 1.C and 4.C which relate respectively to letter motions and discovery disputes.  It doesn’t just make the judge aware of the dispute in another court, it goes on to set forth all the basis for all of Lively’s objections to the subpoena.  Pursuant to Liman’s own rules, any party not in agreement with arguments put forth in a letter filed pursuant to his Rule 1.C should so inform the Court within 2 days.  https://nysd.uscourts.gov/sites/default/files/practice_documents/LJL%20Liman%20Individual%20Practices%20in%20Civil%20Cases_updated%209.26.24.pdf[/quote]

Adding only letters seeking relief of some type are to be submitted under 1.C.  Letters simply to notify the Court  of an occurrence are to be filed under 1.B.[/quote]

I see what you're saying in citing to 1.C.  If you actually look at the docket entries, though, it's clear that the Governski's letter was not filed as a motion.  All the prior letter motions by Lively actually say LETTER MOTION in the title and not just letter, and the letters themselves are clearly styled as motions that will require a response.  The docket link also lists the corresponding doc as a MOTION.

43    Jan 27, 2025   LETTER MOTION for Conference RE: Mr. Freedman's Extrajudicial Conduct addressed to Judge Lewis J. Liman from Michael J. Gottlieb dated 1/27/2025.

190   Apr 30, 2025  LETTER MOTION to Compel Wayfarer Parties to respond to interrogatories 3, 4, 5, and 7 and request for production no. 32 addressed to Judge Lewis J. Liman from Sigrid S. McCawley dated April 30, 2025.

200   May 9, 2025   LETTER MOTION to Compel Wayfarer Studios LLC and Tera Hanks, Mitz Toskovic, Ahmed Musiol, Ashmi Elizabeth Dang, Shekinah Reese, Jariesse Blackmon, AJ Marbory, Dion Suleman, and Jennifer Benson to produce relevant, non-privileged material in response to subpoenas, addressed to Judge Lewis J. Liman from Esra A. Hudson dated May 9, 2025. Document filed by Blake Lively.

But Governski's letter re the DC case is simply entered as a LETTER, not a motion, and the docket provides a link to a letter and not a motion.  You are correct that Governski cites to 4.C (perhaps to permit a response), but the letter is not styled as a motion (as the others above are) and does not seek any relief or action from the judge.  The docket entry itself properly identified the doc for what it was, which was not in any way a motion:

213   May 13, 2025   [b]LETTER[/b] addressed to Judge Lewis J. Liman from Meryl C. Governski dated 5/13/2025 re: Wayfarer Parties' Subpoena to Venable LLP. Document filed by Blake Lively, Ryan Reynolds..(Governski, Meryl) (Entered: 05/13/2025)

Main Document:    Letter               [PDF]

I understand what you're saying about 4.C and how it could have caused confusion here, though.  But the docket entries themselves are clear, as is the styling and the substance of this letter, and Governski clearly was not in any way asking Liman to insert himself into the D.D.C. dispute.  
[/quote]

Opposing Counsel is going to look at the substance of what was actually served, not a docket entry,  If Governski intended a letter of notice, she filed it under the wrong rules.  It was her error, not Freedman’s.[/quote]

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