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B 210 Madison Avenue New York, NY 10016 F i Tel 212. 867. 4466 BBWG Belkin Burden Wenig & Goldman, LLP Fax 212.297.1859 Baa aT, O@OBRE TB AT Law 495 Post Road East Westport, CT 06880 Tel 203.227. 1534 ex 203.227. 6044 Jeffrey L. Goldman, ee Parmer 212. 867. 4466 Exe 312 March 7, 2016 jgoldman@bbwp.com, VIA ELECTRONIC FILING The Honorable Cynthia Kern ‘New York County Courthouse 60 Centre Street, Room 647 New York, New York 10007 Re: People of the State of New York v. The Trump Entrepreneur Initiative LLC, etal. Index No. 451463/2013 Dear Justice Kern: 1 write on behalf of the Trump Respondents in response to the letter of Petitioner's counsel dated March 7, 2016. While I too agree a conference at a mutually convenient date and time is necessary to discuss how to proceed, I object to Petitioner's counsel’s spin of the recent First Department decision and attempt reargue the prior Court’s rulings. Suffice it to say that the State’s appeal from this Court’s denial of summary judgment was denied as the Appellate Division, First Department held that notwithstanding what it had riled in addressing whether 63(12) was a standalone cause of action, what should have been considered and the scope of the statute of limitations, “Nevertheless, Petitioner is not entitled to summary determination of its fraud claims, under either the common law or the statute, because ‘material issues of fact exist as to those claims.” There is no basis for any further review of the denial of summary judgment. As it relates to discovery, the State never appealed from the Court’s discovery rulings and to the extent appealed by Trump Respondents, the Court found that the “rulings were well within its broad discretionary power to control the special proceeding,” Therefore, a conference is required to address the outstanding discovery required from the State, Respectfully submitted, Sete ce: Jane M. Azia, Bureau Chief— via eCourts Consumer Frauds & Protection Charles T. Spada, Esq. — via Courts IGOLDWAN/2658,4082/1797059

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