FILED: NEW YORK COUNTY CLERK 09/07/2018 10:14 AM INDEX NO.

150522/2017
NYSCEF DOC. NO. 189 RECEIVED NYSCEF: 09/07/2018

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK
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SUMMER ZERVOS, :
: Index No.: 150522/2017
Plaintiff, :
: Hon. Jennifer G. Schecter
v. :
: STIPULATION
DONALD J. TRUMP, :

Defendant. :
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WHEREAS, the parties have an ongoing dispute as to what documents and reaterial

should be produced by Defendant directly, as opposed to through the reechanism of a subpoena;

and

WHEREAS, Plaintiff continues to maintain her objection and reserve all rights with

respect to such subpoena mechanism with respect to the Trump Organization; and

WHEREAS, Defendant enters into this stipulation subject to and reserving all rights to

his immunity, under the Supremacy Clause of the United States Constitution, Article VI, cl. 2, as

a sitting United States President from being sued in a state court while serving as President;

IT IS HEREBY STIPULATED AND AGREED by and between the undersigned

counsel, and it is hereby ordered by the Court, that the Prelirninary Conference Order, entered by

the Court on June 5, 2018 (ECF No. 166), is amended as follows:

1. Written responses and objections and non-ESI documents shall be served by the

undersigned on behalf of their clients on or before September 28, 2018 at 12:00 p.m.

2. Written answers and objections to interrogatories shall be served by counsel for

Plaintiff and Defendant on or before September 28, 2018 at 12:00 p.m.

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FILED: NEW YORK COUNTY CLERK 09/07/2018 10:14 AM INDEX NO. 150522/2017
NYSCEF DOC. NO. 189 RECEIVED NYSCEF: 09/07/2018

3, No later than October 16, 2018 at 4:00 p.m., the undersigned shall e-file a joint

letter notifying the Court of any additional disputes regarding objections and/or responses to

document demands and/or interrogatories (other than as already briefed/addressed as part of

Motion Sequence No. 5).

!
4. Counsel for the undersigned shall appear before the Court for a compliance

conference on October 26, 2018 at 11:00 a.m.

5. The dates for the October 11, 2018 ESI telephone conference and the October 26,

2018 ESI protocol deadline are hereby adjourned until the Court sets new dates for those events.

6. The remaining dates in the Preliminary Conference Order (ECF No. 166) remain

in effect.

7. This stipulation may be executed in counterparts and facsimile or PDF copies

shall be deemed originals.

Dated: New York, New York

September 7_, 2018

CUTI HECKER WANG LLP KASOWITZ BENSON TORRES LLP

By: Mariann Meier Wang By: Marc E. Kasowitz

305 Broadway, Suite 607 1633 Broadway
New York, New York 10007 New York, New York 10019

(212) 620-2600 (212) 506-1700

Counsel for Plaintiff Counsel for Defendant

THE MP RGANIZATION

ByfAlan Garten
725 Fifth Avenue

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