Rudy Giuliani Finishes 2024 As He Began It … In Deep Shit – Above the Law

(Photo
by
Drew
Angerer/Getty
Images)

Rudy
Giuliani
is
running
through
the
tape
in
2024,
and
so
is
his
badabing-badabang
lawyer
Joe
Cammarata.
Although
only
one
of
them
is
in
the
running
for

ATL’s
2024
Lawyer
Of
The
Year
.
There’s
always
2025,
Joe!

The
pair
are
currently

bumstumbling

through
two
contempt
motions
in
front
of
Judge
Lewis
Liman
in
the
collection
action
brought
by
Ruby
Freeman
and
Shaye
Moss.
One
involves
Rudy’s
failure
to
comply
with
discovery,
for
which
the
plaintiffs
would
like
to
bar
him
presenting
evidence
that
he
lives
in
Florida
and
is
thus
entitled
to
assert
that
state’s
unlimited
homestead
exemption.
(Giuliani
appears
to
have
declared
himself
a
Florida
resident
in
July,
just
before
he
got
himself
booted
out
of
bankruptcy,
allowing
the
plaintiffs
to
resume
collection
efforts.
Convenient!)

The
other
issue
involves
Giuliani’s
refusal
to
comply
with
Judge
Liman’s
turnover
orders,
despite
strong
signals
from
the
court
that
something

very
unpleasant

would
happen
if
he
didn’t.
Rudy
and
his
lawyers
have
essentially
thrown
up
their
hands
in
dumbfounded
astonishment
when
instructed
that
they
needed
to
deliver
not
just
the
car
but
the
title
as
well.
Who
knew
that
handing
over
the
keys
to
the
apartment,
but
not
the
deed
(which
is
still
in
joint
tenancy
with
his
ex-wife,
several
years
after
the
divorce)
would
not
get
him
full
credit?

But
Cammarata,
whose
practice
consists
largely
of
divorce
cases,
has
come
up
with

ONE
WEIRD
TRICK

to
make
all
that
unpleasantness
go
away.

What
if

nothing
counts
because
Freeman
and
Moss
forgot
to
say
the
magic
words
first?

It
appears
that
according
to
the
Court
docket,
Plaintiffs
as
the
Court
appointed
receivers
failed
to
comply
with
CPLR
§
6402,
and
never
filed
an
“Oath”
with
the
Court
as
required
by
CPLR
§
6402
before
entering
their
duties
to
act
as
receivers.
Hence,
the
receivership
has
not
yet
technically
or
legally
begun.
The
New
York
Civil
Practice
Law
and
Rules
applies
to
the
Judgment
being
enforced
herein.
The
Oath
was
required
to
be
signed
by
Plaintiff
Ruby
Freeman
and
Plaintiff
Wandrea’
Moss
as
the
receivers
and
an
oath
must
have
been
administered
by
any
person
authorized
to
take
acknowledgment
of
deeds
by
the
real
property
law
of
New
York
State,
and
then
filed
with
the
Court
before
the
Plaintiffs
undertook
the
duties
as
Receivers.

Checkmate,
libs!


Or

not.

Indeed, NY
CPLR
§
6402

does
require
temporary
receivers
to
take
an
oath.
But
there’s
no
requirement
that
such
an
oath
be
docketed
with
the
court.
In
their

reply
,
Freeman
and
Moss’s
lawyer
Michael
Gottlieb,
a
litigation
partner
at
Willkie
Farr
(along
with
five
other
lawyers),
attached
said

oaths
,
signed
three
days
after
the
court’s
receivership
order,
noting
that
“there
is
no
requirement
that
the
oaths
be
filed—but
even
if
there
were,
now
that
the
oaths
have
been
filed,
any
merit
in
Mr.
Giuliani’s
argument
would
be
moot.”

Gottlieb
et
al
also
documented
Rudy’s
ongoing
shenanigans
regarding
his
sports
memorabilia,

With
respect
to
the
signed
Joe
DiMaggio
shirt,
Mr.
Giuliani
now
claims
there
“is
no
Signed
Joe
DiMaggio
shirt
that
I
possess”
and
that
“the
Signed
Joe
DiMaggio
shirt
was
hanging
in
the
New
York
Cooperative
apartment
at
the
time
the
apartment
was
turned
over.”
Mr.
Giuliani’s
claim
to
have
suddenly
lost
track
of
the
signed
Joe
DiMaggio
jersey
is
not
credible
for
multiple
independent
reasons.
First,
Mr.
Giuliani’s
former
counsel
represented
to
the
Court
at
the
November
7
Hearing
that
the
signed
Joe
DiMaggio
shirt
was
located
at
the
CTS
facility
in
Ronkonkoma.
Second,
the
signed
Joe
DiMaggio
shirt
was
not
present
at
the
New
York
Apartment
when
counsel
for
PlaintiffsReceivers
visited
on
October
31,
2024,
as
evidenced
by
comparing
the
photo
of
the
real
estate
listing
of
the
room
where
the
framed,
signed
Joe
DiMaggio
jersey
was
hanging
with
the
one
Plaintiffs’
counsel
submitted
from
the
October
visit.
Third,
one
of
Mr.
Giuliani’s
trial
witnesses
and
oldest
friends,
Monsignor
Alan
Placa—who
Mr.
Giuliani
recently
testified
would
be
a
credible
and
trustworthy
witness
testified
under
oath
during
his
recent
deposition
that
he
had
not
traveled
to
New
York
in
seven
years
but
that
he
had
personally
seen
the
framed,
signed
Joe
DiMaggio
shirt
within
the
last
two
years,
and
specifically
“at
the
apartment

actually,
it
was
here
in
Florida”
at
the
Palm
Beach
Condo.
Similarly,
Mr.
Giuliani’s
claim
that
there
“was
no
Reggie
Jackson
picture”
is
belied
by
his
own
Bankruptcy
Schedule,
and
his
former
counsel’s
representation
to
this
Court
that
the
signed
Reggie
Jackson
was
present
at
the
CTS
facility
in
Ronkonkoma.
And
even
if
Mr.
Giuliani’s
claims
about
either
signed
sports
memorabilia
had
any
indicia
of
credibility,
he
fails
to
describe
any
efforts
he
has
made
to
locate
them,
as
he
must
to
avoid
contempt.

Placa
is
a
former
priest
who
retired
under

interesting

circumstances
which
were
always
going
to
make
him
a


problematic
witness
.
In
a

deposition

he
testified
variously
that
he:
was
a
lawyer;
understood
his
role
as
deponent;
kept
calendar
entries
of
Rudy’s
travel
to
Florida;
and
yet
failed
to
produce
them
because
“I
read
through
[the
subpoena]
quickly
and
didn’t
feel
that
I
had
anything
that
was
responsive
at
all.”
He
also
insisted
that
he
had
no
idea
how
a
LinkedIn
profile
showing
him
as
senior
VP
at
Giuliani
Partners
came
to
be,
since
he
never
drew
a
salary
or
went
into
the
office
more
than
a
few
times.
Although
he
did
admit
that
six
FEC
disclosures
in
the
name
of
Alan
Placa,
VP
at
Giuliani
Partners
came
from
him.

Rudy’s

deposition

went
similarly
swimmingly.
Asked
why
he
failed
to
renew
his
drivers
license,
he
said
“I
have
fatwas
issued
against
me
by
the
Ayatollah,
personally.”

He
refused
to
disclose
his
email
address
because:

Ninety-nine
percent
of
it
contains
matters
that
have
nothing
to
do
with
this
case
and
a
lot
of
them
are
privileged.
A
lot
of
them
are
personal
and
it
would
seem
to
me
that
it
constitutes
overbroad
discovery,
prying
into
things

using
this
litigation
for
the
purpose
of
prying
into
things
that
are
frankly
none
of
your
business,
that
have
been
utilized
in
the
past
for
leaking,
for
giving
information
to
other
people,
so
I
don’t
give
my
email
out
generally
anyway.
I
give
it
out
to
people
that
I
believe
will
use
it
for
a
proper
purpose.

Cammarata
instructed
him
not
to
answer,
because
“I
believe
we
have
a
protective
order
with
that
information.”
(Nope.)

Also,
it
does
not
seem
to
have
occurred
to
them
that
discussing
his
testimony
over
lunch
might
waive
the
privilege
to
said
conversation.

“Any
discussions
I
had
during
the
break
with
my
attorney
and
beyond
what
I
said,
which
I
probably
shouldn’t
have
said
at
all,
is
privileged,”
he
shouted,
after
admitting
that
he
had,
indeed,
talked
about
the
deposition
with
his
lawyer.
“But
the
answer
is
I
will
not
answer
questions
about
what
I
talk
to
my
attorney
about.
I
think
I’m
entitled
to
that
privilege
as
an
American
citizen.”

TL,
DR:
Giuliani
is
an

amazing
witness
,
who
will
certainly
have
the
discipline
not
to,
say,

invoke
the
advice
of
counsel
defense
and
waive
privilege

about
why
his
prior
lawyers
ran
for
the
hills.
Or
lie
on
the
stand.
Or
assert
non-existent
privileges
in
defiance
of
the
court’s
prior
order.
Or
shout
at
the
judge.


Freeman
v.
Giuliani
 [Docket
via
Court
Listener]





Liz
Dye
 lives
in
Baltimore
where
she
produces
the
Law
and
Chaos substack and podcast.

Rudy Giuliani Finishes 2024 As He Began It … In Deep Shit – Above the Law

(Photo
by
Drew
Angerer/Getty
Images)

Rudy
Giuliani
is
running
through
the
tape
in
2024,
and
so
is
his
badabing-badabang
lawyer
Joe
Cammarata.
Although
only
one
of
them
is
in
the
running
for

ATL’s
2024
Lawyer
Of
The
Year
.
There’s
always
2025,
Joe!

The
pair
are
currently

bumstumbling

through
two
contempt
motions
in
front
of
Judge
Lewis
Liman
in
the
collection
action
brought
by
Ruby
Freeman
and
Shaye
Moss.
One
involves
Rudy’s
failure
to
comply
with
discovery,
for
which
the
plaintiffs
would
like
to
bar
him
presenting
evidence
that
he
lives
in
Florida
and
is
thus
entitled
to
assert
that
state’s
unlimited
homestead
exemption.
(Giuliani
appears
to
have
declared
himself
a
Florida
resident
in
July,
just
before
he
got
himself
booted
out
of
bankruptcy,
allowing
the
plaintiffs
to
resume
collection
efforts.
Convenient!)

The
other
issue
involves
Giuliani’s
refusal
to
comply
with
Judge
Liman’s
turnover
orders,
despite
strong
signals
from
the
court
that
something

very
unpleasant

would
happen
if
he
didn’t.
Rudy
and
his
lawyers
have
essentially
thrown
up
their
hands
in
dumbfounded
astonishment
when
instructed
that
they
needed
to
deliver
not
just
the
car
but
the
title
as
well.
Who
knew
that
handing
over
the
keys
to
the
apartment,
but
not
the
deed
(which
is
still
in
joint
tenancy
with
his
ex-wife,
several
years
after
the
divorce)
would
not
get
him
full
credit?

But
Cammarata,
whose
practice
consists
largely
of
divorce
cases,
has
come
up
with

ONE
WEIRD
TRICK

to
make
all
that
unpleasantness
go
away.

What
if

nothing
counts
because
Freeman
and
Moss
forgot
to
say
the
magic
words
first?

It
appears
that
according
to
the
Court
docket,
Plaintiffs
as
the
Court
appointed
receivers
failed
to
comply
with
CPLR
§
6402,
and
never
filed
an
“Oath”
with
the
Court
as
required
by
CPLR
§
6402
before
entering
their
duties
to
act
as
receivers.
Hence,
the
receivership
has
not
yet
technically
or
legally
begun.
The
New
York
Civil
Practice
Law
and
Rules
applies
to
the
Judgment
being
enforced
herein.
The
Oath
was
required
to
be
signed
by
Plaintiff
Ruby
Freeman
and
Plaintiff
Wandrea’
Moss
as
the
receivers
and
an
oath
must
have
been
administered
by
any
person
authorized
to
take
acknowledgment
of
deeds
by
the
real
property
law
of
New
York
State,
and
then
filed
with
the
Court
before
the
Plaintiffs
undertook
the
duties
as
Receivers.

Checkmate,
libs!


Or

not.

Indeed, NY
CPLR
§
6402

does
require
temporary
receivers
to
take
an
oath.
But
there’s
no
requirement
that
such
an
oath
be
docketed
with
the
court.
In
their

reply
,
Freeman
and
Moss’s
lawyer
Michael
Gottlieb,
a
litigation
partner
at
Willkie
Farr
(along
with
five
other
lawyers),
attached
said

oaths
,
signed
three
days
after
the
court’s
receivership
order,
noting
that
“there
is
no
requirement
that
the
oaths
be
filed—but
even
if
there
were,
now
that
the
oaths
have
been
filed,
any
merit
in
Mr.
Giuliani’s
argument
would
be
moot.”

Gottlieb
et
al
also
documented
Rudy’s
ongoing
shenanigans
regarding
his
sports
memorabilia,

With
respect
to
the
signed
Joe
DiMaggio
shirt,
Mr.
Giuliani
now
claims
there
“is
no
Signed
Joe
DiMaggio
shirt
that
I
possess”
and
that
“the
Signed
Joe
DiMaggio
shirt
was
hanging
in
the
New
York
Cooperative
apartment
at
the
time
the
apartment
was
turned
over.”
Mr.
Giuliani’s
claim
to
have
suddenly
lost
track
of
the
signed
Joe
DiMaggio
jersey
is
not
credible
for
multiple
independent
reasons.
First,
Mr.
Giuliani’s
former
counsel
represented
to
the
Court
at
the
November
7
Hearing
that
the
signed
Joe
DiMaggio
shirt
was
located
at
the
CTS
facility
in
Ronkonkoma.
Second,
the
signed
Joe
DiMaggio
shirt
was
not
present
at
the
New
York
Apartment
when
counsel
for
PlaintiffsReceivers
visited
on
October
31,
2024,
as
evidenced
by
comparing
the
photo
of
the
real
estate
listing
of
the
room
where
the
framed,
signed
Joe
DiMaggio
jersey
was
hanging
with
the
one
Plaintiffs’
counsel
submitted
from
the
October
visit.
Third,
one
of
Mr.
Giuliani’s
trial
witnesses
and
oldest
friends,
Monsignor
Alan
Placa—who
Mr.
Giuliani
recently
testified
would
be
a
credible
and
trustworthy
witness
testified
under
oath
during
his
recent
deposition
that
he
had
not
traveled
to
New
York
in
seven
years
but
that
he
had
personally
seen
the
framed,
signed
Joe
DiMaggio
shirt
within
the
last
two
years,
and
specifically
“at
the
apartment

actually,
it
was
here
in
Florida”
at
the
Palm
Beach
Condo.
Similarly,
Mr.
Giuliani’s
claim
that
there
“was
no
Reggie
Jackson
picture”
is
belied
by
his
own
Bankruptcy
Schedule,
and
his
former
counsel’s
representation
to
this
Court
that
the
signed
Reggie
Jackson
was
present
at
the
CTS
facility
in
Ronkonkoma.
And
even
if
Mr.
Giuliani’s
claims
about
either
signed
sports
memorabilia
had
any
indicia
of
credibility,
he
fails
to
describe
any
efforts
he
has
made
to
locate
them,
as
he
must
to
avoid
contempt.

Placa
is
a
former
priest
who
retired
under

interesting

circumstances
which
were
always
going
to
make
him
a


problematic
witness
.
In
a

deposition

he
testified
variously
that
he:
was
a
lawyer;
understood
his
role
as
deponent;
kept
calendar
entries
of
Rudy’s
travel
to
Florida;
and
yet
failed
to
produce
them
because
“I
read
through
[the
subpoena]
quickly
and
didn’t
feel
that
I
had
anything
that
was
responsive
at
all.”
He
also
insisted
that
he
had
no
idea
how
a
LinkedIn
profile
showing
him
as
senior
VP
at
Giuliani
Partners
came
to
be,
since
he
never
drew
a
salary
or
went
into
the
office
more
than
a
few
times.
Although
he
did
admit
that
six
FEC
disclosures
in
the
name
of
Alan
Placa,
VP
at
Giuliani
Partners
came
from
him.

Rudy’s

deposition

went
similarly
swimmingly.
Asked
why
he
failed
to
renew
his
drivers
license,
he
said
“I
have
fatwas
issued
against
me
by
the
Ayatollah,
personally.”

He
refused
to
disclose
his
email
address
because:

Ninety-nine
percent
of
it
contains
matters
that
have
nothing
to
do
with
this
case
and
a
lot
of
them
are
privileged.
A
lot
of
them
are
personal
and
it
would
seem
to
me
that
it
constitutes
overbroad
discovery,
prying
into
things

using
this
litigation
for
the
purpose
of
prying
into
things
that
are
frankly
none
of
your
business,
that
have
been
utilized
in
the
past
for
leaking,
for
giving
information
to
other
people,
so
I
don’t
give
my
email
out
generally
anyway.
I
give
it
out
to
people
that
I
believe
will
use
it
for
a
proper
purpose.

Cammarata
instructed
him
not
to
answer,
because
“I
believe
we
have
a
protective
order
with
that
information.”
(Nope.)

Also,
it
does
not
seem
to
have
occurred
to
them
that
discussing
his
testimony
over
lunch
might
waive
the
privilege
to
said
conversation.

“Any
discussions
I
had
during
the
break
with
my
attorney
and
beyond
what
I
said,
which
I
probably
shouldn’t
have
said
at
all,
is
privileged,”
he
shouted,
after
admitting
that
he
had,
indeed,
talked
about
the
deposition
with
his
lawyer.
“But
the
answer
is
I
will
not
answer
questions
about
what
I
talk
to
my
attorney
about.
I
think
I’m
entitled
to
that
privilege
as
an
American
citizen.”

TL,
DR:
Giuliani
is
an

amazing
witness
,
who
will
certainly
have
the
discipline
not
to,
say,

invoke
the
advice
of
counsel
defense
and
waive
privilege

about
why
his
prior
lawyers
ran
for
the
hills.
Or
lie
on
the
stand.
Or
assert
non-existent
privileges
in
defiance
of
the
court’s
prior
order.
Or
shout
at
the
judge.


Freeman
v.
Giuliani
 [Docket
via
Court
Listener]





Liz
Dye
 lives
in
Baltimore
where
she
produces
the
Law
and
Chaos substack and podcast.

Rudy Giuliani Finishes 2024 As He Began It … In Deep Shit – Above the Law

(Photo
by
Drew
Angerer/Getty
Images)

Rudy
Giuliani
is
running
through
the
tape
in
2024,
and
so
is
his
badabing-badabang
lawyer
Joe
Cammarata.
Although
only
one
of
them
is
in
the
running
for

ATL’s
2024
Lawyer
Of
The
Year
.
There’s
always
2025,
Joe!

The
pair
are
currently

bumstumbling

through
two
contempt
motions
in
front
of
Judge
Lewis
Liman
in
the
collection
action
brought
by
Ruby
Freeman
and
Shaye
Moss.
One
involves
Rudy’s
failure
to
comply
with
discovery,
for
which
the
plaintiffs
would
like
to
bar
him
presenting
evidence
that
he
lives
in
Florida
and
is
thus
entitled
to
assert
that
state’s
unlimited
homestead
exemption.
(Giuliani
appears
to
have
declared
himself
a
Florida
resident
in
July,
just
before
he
got
himself
booted
out
of
bankruptcy,
allowing
the
plaintiffs
to
resume
collection
efforts.
Convenient!)

The
other
issue
involves
Giuliani’s
refusal
to
comply
with
Judge
Liman’s
turnover
orders,
despite
strong
signals
from
the
court
that
something

very
unpleasant

would
happen
if
he
didn’t.
Rudy
and
his
lawyers
have
essentially
thrown
up
their
hands
in
dumbfounded
astonishment
when
instructed
that
they
needed
to
deliver
not
just
the
car
but
the
title
as
well.
Who
knew
that
handing
over
the
keys
to
the
apartment,
but
not
the
deed
(which
is
still
in
joint
tenancy
with
his
ex-wife,
several
years
after
the
divorce)
would
not
get
him
full
credit?

But
Cammarata,
whose
practice
consists
largely
of
divorce
cases,
has
come
up
with

ONE
WEIRD
TRICK

to
make
all
that
unpleasantness
go
away.

What
if

nothing
counts
because
Freeman
and
Moss
forgot
to
say
the
magic
words
first?

It
appears
that
according
to
the
Court
docket,
Plaintiffs
as
the
Court
appointed
receivers
failed
to
comply
with
CPLR
§
6402,
and
never
filed
an
“Oath”
with
the
Court
as
required
by
CPLR
§
6402
before
entering
their
duties
to
act
as
receivers.
Hence,
the
receivership
has
not
yet
technically
or
legally
begun.
The
New
York
Civil
Practice
Law
and
Rules
applies
to
the
Judgment
being
enforced
herein.
The
Oath
was
required
to
be
signed
by
Plaintiff
Ruby
Freeman
and
Plaintiff
Wandrea’
Moss
as
the
receivers
and
an
oath
must
have
been
administered
by
any
person
authorized
to
take
acknowledgment
of
deeds
by
the
real
property
law
of
New
York
State,
and
then
filed
with
the
Court
before
the
Plaintiffs
undertook
the
duties
as
Receivers.

Checkmate,
libs!


Or

not.

Indeed, NY
CPLR
§
6402

does
require
temporary
receivers
to
take
an
oath.
But
there’s
no
requirement
that
such
an
oath
be
docketed
with
the
court.
In
their

reply
,
Freeman
and
Moss’s
lawyer
Michael
Gottlieb,
a
litigation
partner
at
Willkie
Farr
(along
with
five
other
lawyers),
attached
said

oaths
,
signed
three
days
after
the
court’s
receivership
order,
noting
that
“there
is
no
requirement
that
the
oaths
be
filed—but
even
if
there
were,
now
that
the
oaths
have
been
filed,
any
merit
in
Mr.
Giuliani’s
argument
would
be
moot.”

Gottlieb
et
al
also
documented
Rudy’s
ongoing
shenanigans
regarding
his
sports
memorabilia,

With
respect
to
the
signed
Joe
DiMaggio
shirt,
Mr.
Giuliani
now
claims
there
“is
no
Signed
Joe
DiMaggio
shirt
that
I
possess”
and
that
“the
Signed
Joe
DiMaggio
shirt
was
hanging
in
the
New
York
Cooperative
apartment
at
the
time
the
apartment
was
turned
over.”
Mr.
Giuliani’s
claim
to
have
suddenly
lost
track
of
the
signed
Joe
DiMaggio
jersey
is
not
credible
for
multiple
independent
reasons.
First,
Mr.
Giuliani’s
former
counsel
represented
to
the
Court
at
the
November
7
Hearing
that
the
signed
Joe
DiMaggio
shirt
was
located
at
the
CTS
facility
in
Ronkonkoma.
Second,
the
signed
Joe
DiMaggio
shirt
was
not
present
at
the
New
York
Apartment
when
counsel
for
PlaintiffsReceivers
visited
on
October
31,
2024,
as
evidenced
by
comparing
the
photo
of
the
real
estate
listing
of
the
room
where
the
framed,
signed
Joe
DiMaggio
jersey
was
hanging
with
the
one
Plaintiffs’
counsel
submitted
from
the
October
visit.
Third,
one
of
Mr.
Giuliani’s
trial
witnesses
and
oldest
friends,
Monsignor
Alan
Placa—who
Mr.
Giuliani
recently
testified
would
be
a
credible
and
trustworthy
witness
testified
under
oath
during
his
recent
deposition
that
he
had
not
traveled
to
New
York
in
seven
years
but
that
he
had
personally
seen
the
framed,
signed
Joe
DiMaggio
shirt
within
the
last
two
years,
and
specifically
“at
the
apartment

actually,
it
was
here
in
Florida”
at
the
Palm
Beach
Condo.
Similarly,
Mr.
Giuliani’s
claim
that
there
“was
no
Reggie
Jackson
picture”
is
belied
by
his
own
Bankruptcy
Schedule,
and
his
former
counsel’s
representation
to
this
Court
that
the
signed
Reggie
Jackson
was
present
at
the
CTS
facility
in
Ronkonkoma.
And
even
if
Mr.
Giuliani’s
claims
about
either
signed
sports
memorabilia
had
any
indicia
of
credibility,
he
fails
to
describe
any
efforts
he
has
made
to
locate
them,
as
he
must
to
avoid
contempt.

Placa
is
a
former
priest
who
retired
under

interesting

circumstances
which
were
always
going
to
make
him
a


problematic
witness
.
In
a

deposition

he
testified
variously
that
he:
was
a
lawyer;
understood
his
role
as
deponent;
kept
calendar
entries
of
Rudy’s
travel
to
Florida;
and
yet
failed
to
produce
them
because
“I
read
through
[the
subpoena]
quickly
and
didn’t
feel
that
I
had
anything
that
was
responsive
at
all.”
He
also
insisted
that
he
had
no
idea
how
a
LinkedIn
profile
showing
him
as
senior
VP
at
Giuliani
Partners
came
to
be,
since
he
never
drew
a
salary
or
went
into
the
office
more
than
a
few
times.
Although
he
did
admit
that
six
FEC
disclosures
in
the
name
of
Alan
Placa,
VP
at
Giuliani
Partners
came
from
him.

Rudy’s

deposition

went
similarly
swimmingly.
Asked
why
he
failed
to
renew
his
drivers
license,
he
said
“I
have
fatwas
issued
against
me
by
the
Ayatollah,
personally.”

He
refused
to
disclose
his
email
address
because:

Ninety-nine
percent
of
it
contains
matters
that
have
nothing
to
do
with
this
case
and
a
lot
of
them
are
privileged.
A
lot
of
them
are
personal
and
it
would
seem
to
me
that
it
constitutes
overbroad
discovery,
prying
into
things

using
this
litigation
for
the
purpose
of
prying
into
things
that
are
frankly
none
of
your
business,
that
have
been
utilized
in
the
past
for
leaking,
for
giving
information
to
other
people,
so
I
don’t
give
my
email
out
generally
anyway.
I
give
it
out
to
people
that
I
believe
will
use
it
for
a
proper
purpose.

Cammarata
instructed
him
not
to
answer,
because
“I
believe
we
have
a
protective
order
with
that
information.”
(Nope.)

Also,
it
does
not
seem
to
have
occurred
to
them
that
discussing
his
testimony
over
lunch
might
waive
the
privilege
to
said
conversation.

“Any
discussions
I
had
during
the
break
with
my
attorney
and
beyond
what
I
said,
which
I
probably
shouldn’t
have
said
at
all,
is
privileged,”
he
shouted,
after
admitting
that
he
had,
indeed,
talked
about
the
deposition
with
his
lawyer.
“But
the
answer
is
I
will
not
answer
questions
about
what
I
talk
to
my
attorney
about.
I
think
I’m
entitled
to
that
privilege
as
an
American
citizen.”

TL,
DR:
Giuliani
is
an

amazing
witness
,
who
will
certainly
have
the
discipline
not
to,
say,

invoke
the
advice
of
counsel
defense
and
waive
privilege

about
why
his
prior
lawyers
ran
for
the
hills.
Or
lie
on
the
stand.
Or
assert
non-existent
privileges
in
defiance
of
the
court’s
prior
order.
Or
shout
at
the
judge.


Freeman
v.
Giuliani
 [Docket
via
Court
Listener]





Liz
Dye
 lives
in
Baltimore
where
she
produces
the
Law
and
Chaos substack and podcast.

Rudy Giuliani Finishes 2024 As He Began It … In Deep Shit – Above the Law

(Photo
by
Drew
Angerer/Getty
Images)

Rudy
Giuliani
is
running
through
the
tape
in
2024,
and
so
is
his
badabing-badabang
lawyer
Joe
Cammarata.
Although
only
one
of
them
is
in
the
running
for

ATL’s
2024
Lawyer
Of
The
Year
.
There’s
always
2025,
Joe!

The
pair
are
currently

bumstumbling

through
two
contempt
motions
in
front
of
Judge
Lewis
Liman
in
the
collection
action
brought
by
Ruby
Freeman
and
Shaye
Moss.
One
involves
Rudy’s
failure
to
comply
with
discovery,
for
which
the
plaintiffs
would
like
to
bar
him
presenting
evidence
that
he
lives
in
Florida
and
is
thus
entitled
to
assert
that
state’s
unlimited
homestead
exemption.
(Giuliani
appears
to
have
declared
himself
a
Florida
resident
in
July,
just
before
he
got
himself
booted
out
of
bankruptcy,
allowing
the
plaintiffs
to
resume
collection
efforts.
Convenient!)

The
other
issue
involves
Giuliani’s
refusal
to
comply
with
Judge
Liman’s
turnover
orders,
despite
strong
signals
from
the
court
that
something

very
unpleasant

would
happen
if
he
didn’t.
Rudy
and
his
lawyers
have
essentially
thrown
up
their
hands
in
dumbfounded
astonishment
when
instructed
that
they
needed
to
deliver
not
just
the
car
but
the
title
as
well.
Who
knew
that
handing
over
the
keys
to
the
apartment,
but
not
the
deed
(which
is
still
in
joint
tenancy
with
his
ex-wife,
several
years
after
the
divorce)
would
not
get
him
full
credit?

But
Cammarata,
whose
practice
consists
largely
of
divorce
cases,
has
come
up
with

ONE
WEIRD
TRICK

to
make
all
that
unpleasantness
go
away.

What
if

nothing
counts
because
Freeman
and
Moss
forgot
to
say
the
magic
words
first?

It
appears
that
according
to
the
Court
docket,
Plaintiffs
as
the
Court
appointed
receivers
failed
to
comply
with
CPLR
§
6402,
and
never
filed
an
“Oath”
with
the
Court
as
required
by
CPLR
§
6402
before
entering
their
duties
to
act
as
receivers.
Hence,
the
receivership
has
not
yet
technically
or
legally
begun.
The
New
York
Civil
Practice
Law
and
Rules
applies
to
the
Judgment
being
enforced
herein.
The
Oath
was
required
to
be
signed
by
Plaintiff
Ruby
Freeman
and
Plaintiff
Wandrea’
Moss
as
the
receivers
and
an
oath
must
have
been
administered
by
any
person
authorized
to
take
acknowledgment
of
deeds
by
the
real
property
law
of
New
York
State,
and
then
filed
with
the
Court
before
the
Plaintiffs
undertook
the
duties
as
Receivers.

Checkmate,
libs!


Or

not.

Indeed, NY
CPLR
§
6402

does
require
temporary
receivers
to
take
an
oath.
But
there’s
no
requirement
that
such
an
oath
be
docketed
with
the
court.
In
their

reply
,
Freeman
and
Moss’s
lawyer
Michael
Gottlieb,
a
litigation
partner
at
Willkie
Farr
(along
with
five
other
lawyers),
attached
said

oaths
,
signed
three
days
after
the
court’s
receivership
order,
noting
that
“there
is
no
requirement
that
the
oaths
be
filed—but
even
if
there
were,
now
that
the
oaths
have
been
filed,
any
merit
in
Mr.
Giuliani’s
argument
would
be
moot.”

Gottlieb
et
al
also
documented
Rudy’s
ongoing
shenanigans
regarding
his
sports
memorabilia,

With
respect
to
the
signed
Joe
DiMaggio
shirt,
Mr.
Giuliani
now
claims
there
“is
no
Signed
Joe
DiMaggio
shirt
that
I
possess”
and
that
“the
Signed
Joe
DiMaggio
shirt
was
hanging
in
the
New
York
Cooperative
apartment
at
the
time
the
apartment
was
turned
over.”
Mr.
Giuliani’s
claim
to
have
suddenly
lost
track
of
the
signed
Joe
DiMaggio
jersey
is
not
credible
for
multiple
independent
reasons.
First,
Mr.
Giuliani’s
former
counsel
represented
to
the
Court
at
the
November
7
Hearing
that
the
signed
Joe
DiMaggio
shirt
was
located
at
the
CTS
facility
in
Ronkonkoma.
Second,
the
signed
Joe
DiMaggio
shirt
was
not
present
at
the
New
York
Apartment
when
counsel
for
PlaintiffsReceivers
visited
on
October
31,
2024,
as
evidenced
by
comparing
the
photo
of
the
real
estate
listing
of
the
room
where
the
framed,
signed
Joe
DiMaggio
jersey
was
hanging
with
the
one
Plaintiffs’
counsel
submitted
from
the
October
visit.
Third,
one
of
Mr.
Giuliani’s
trial
witnesses
and
oldest
friends,
Monsignor
Alan
Placa—who
Mr.
Giuliani
recently
testified
would
be
a
credible
and
trustworthy
witness
testified
under
oath
during
his
recent
deposition
that
he
had
not
traveled
to
New
York
in
seven
years
but
that
he
had
personally
seen
the
framed,
signed
Joe
DiMaggio
shirt
within
the
last
two
years,
and
specifically
“at
the
apartment

actually,
it
was
here
in
Florida”
at
the
Palm
Beach
Condo.
Similarly,
Mr.
Giuliani’s
claim
that
there
“was
no
Reggie
Jackson
picture”
is
belied
by
his
own
Bankruptcy
Schedule,
and
his
former
counsel’s
representation
to
this
Court
that
the
signed
Reggie
Jackson
was
present
at
the
CTS
facility
in
Ronkonkoma.
And
even
if
Mr.
Giuliani’s
claims
about
either
signed
sports
memorabilia
had
any
indicia
of
credibility,
he
fails
to
describe
any
efforts
he
has
made
to
locate
them,
as
he
must
to
avoid
contempt.

Placa
is
a
former
priest
who
retired
under

interesting

circumstances
which
were
always
going
to
make
him
a


problematic
witness
.
In
a

deposition

he
testified
variously
that
he:
was
a
lawyer;
understood
his
role
as
deponent;
kept
calendar
entries
of
Rudy’s
travel
to
Florida;
and
yet
failed
to
produce
them
because
“I
read
through
[the
subpoena]
quickly
and
didn’t
feel
that
I
had
anything
that
was
responsive
at
all.”
He
also
insisted
that
he
had
no
idea
how
a
LinkedIn
profile
showing
him
as
senior
VP
at
Giuliani
Partners
came
to
be,
since
he
never
drew
a
salary
or
went
into
the
office
more
than
a
few
times.
Although
he
did
admit
that
six
FEC
disclosures
in
the
name
of
Alan
Placa,
VP
at
Giuliani
Partners
came
from
him.

Rudy’s

deposition

went
similarly
swimmingly.
Asked
why
he
failed
to
renew
his
drivers
license,
he
said
“I
have
fatwas
issued
against
me
by
the
Ayatollah,
personally.”

He
refused
to
disclose
his
email
address
because:

Ninety-nine
percent
of
it
contains
matters
that
have
nothing
to
do
with
this
case
and
a
lot
of
them
are
privileged.
A
lot
of
them
are
personal
and
it
would
seem
to
me
that
it
constitutes
overbroad
discovery,
prying
into
things

using
this
litigation
for
the
purpose
of
prying
into
things
that
are
frankly
none
of
your
business,
that
have
been
utilized
in
the
past
for
leaking,
for
giving
information
to
other
people,
so
I
don’t
give
my
email
out
generally
anyway.
I
give
it
out
to
people
that
I
believe
will
use
it
for
a
proper
purpose.

Cammarata
instructed
him
not
to
answer,
because
“I
believe
we
have
a
protective
order
with
that
information.”
(Nope.)

Also,
it
does
not
seem
to
have
occurred
to
them
that
discussing
his
testimony
over
lunch
might
waive
the
privilege
to
said
conversation.

“Any
discussions
I
had
during
the
break
with
my
attorney
and
beyond
what
I
said,
which
I
probably
shouldn’t
have
said
at
all,
is
privileged,”
he
shouted,
after
admitting
that
he
had,
indeed,
talked
about
the
deposition
with
his
lawyer.
“But
the
answer
is
I
will
not
answer
questions
about
what
I
talk
to
my
attorney
about.
I
think
I’m
entitled
to
that
privilege
as
an
American
citizen.”

TL,
DR:
Giuliani
is
an

amazing
witness
,
who
will
certainly
have
the
discipline
not
to,
say,

invoke
the
advice
of
counsel
defense
and
waive
privilege

about
why
his
prior
lawyers
ran
for
the
hills.
Or
lie
on
the
stand.
Or
assert
non-existent
privileges
in
defiance
of
the
court’s
prior
order.
Or
shout
at
the
judge.


Freeman
v.
Giuliani
 [Docket
via
Court
Listener]





Liz
Dye
 lives
in
Baltimore
where
she
produces
the
Law
and
Chaos substack and podcast.

Morning Docket: 12.31.24 – Above the Law

(Photo
by
Kevin
Winter/Getty
Images)

*
Brad
Pitt
and
Angelina
Jolie
are
now
divorced…
8
years
after
the
fact.
[CNN]

*
Trump’s
TikTok
brief
is…
flimsy.
[One
First
]

*
Pressure
mounts
to
regulate
insurance
companies
using
AI
algorithms
to
deny
claims.
[Bloomberg
Law
News
]

*
Justice
Breyer
to
start
hearing
appellate
cases
again.
[Reuters]

*
Full
ethics
inquiry
required
to
decide
that
a
state
judge
can
accept
a
$250
gift
card
from
a
non-profit
if
it
is
a
retirement
gift.
Clarence
Thomas
giggles.
[New
York
Law
Journal
]

Morning Docket: 12.31.24 – Above the Law

(Photo
by
Kevin
Winter/Getty
Images)

*
Brad
Pitt
and
Angelina
Jolie
are
now
divorced…
8
years
after
the
fact.
[CNN]

*
Trump’s
TikTok
brief
is…
flimsy.
[One
First
]

*
Pressure
mounts
to
regulate
insurance
companies
using
AI
algorithms
to
deny
claims.
[Bloomberg
Law
News
]

*
Justice
Breyer
to
start
hearing
appellate
cases
again.
[Reuters]

*
Full
ethics
inquiry
required
to
decide
that
a
state
judge
can
accept
a
$250
gift
card
from
a
non-profit
if
it
is
a
retirement
gift.
Clarence
Thomas
giggles.
[New
York
Law
Journal
]

Rudy Giuliani Finishes 2024 As He Began It … In Deep Shit – Above the Law

(Photo
by
Drew
Angerer/Getty
Images)

Rudy
Giuliani
is
running
through
the
tape
in
2024,
and
so
is
his
badabing-badabang
lawyer
Joe
Cammarata.
Although
only
one
of
them
is
in
the
running
for

ATL’s
2024
Lawyer
Of
The
Year
.
There’s
always
2025,
Joe!

The
pair
are
currently

bumstumbling

through
two
contempt
motions
in
front
of
Judge
Lewis
Liman
in
the
collection
action
brought
by
Ruby
Freeman
and
Shaye
Moss.
One
involves
Rudy’s
failure
to
comply
with
discovery,
for
which
the
plaintiffs
would
like
to
bar
him
presenting
evidence
that
he
lives
in
Florida
and
is
thus
entitled
to
assert
that
state’s
unlimited
homestead
exemption.
(Giuliani
appears
to
have
declared
himself
a
Florida
resident
in
July,
just
before
he
got
himself
booted
out
of
bankruptcy,
allowing
the
plaintiffs
to
resume
collection
efforts.
Convenient!)

The
other
issue
involves
Giuliani’s
refusal
to
comply
with
Judge
Liman’s
turnover
orders,
despite
strong
signals
from
the
court
that
something

very
unpleasant

would
happen
if
he
didn’t.
Rudy
and
his
lawyers
have
essentially
thrown
up
their
hands
in
dumbfounded
astonishment
when
instructed
that
they
needed
to
deliver
not
just
the
car
but
the
title
as
well.
Who
knew
that
handing
over
the
keys
to
the
apartment,
but
not
the
deed
(which
is
still
in
joint
tenancy
with
his
ex-wife,
several
years
after
the
divorce)
would
not
get
him
full
credit?

But
Cammarata,
whose
practice
consists
largely
of
divorce
cases,
has
come
up
with

ONE
WEIRD
TRICK

to
make
all
that
unpleasantness
go
away.

What
if

nothing
counts
because
Freeman
and
Moss
forgot
to
say
the
magic
words
first?

It
appears
that
according
to
the
Court
docket,
Plaintiffs
as
the
Court
appointed
receivers
failed
to
comply
with
CPLR
§
6402,
and
never
filed
an
“Oath”
with
the
Court
as
required
by
CPLR
§
6402
before
entering
their
duties
to
act
as
receivers.
Hence,
the
receivership
has
not
yet
technically
or
legally
begun.
The
New
York
Civil
Practice
Law
and
Rules
applies
to
the
Judgment
being
enforced
herein.
The
Oath
was
required
to
be
signed
by
Plaintiff
Ruby
Freeman
and
Plaintiff
Wandrea’
Moss
as
the
receivers
and
an
oath
must
have
been
administered
by
any
person
authorized
to
take
acknowledgment
of
deeds
by
the
real
property
law
of
New
York
State,
and
then
filed
with
the
Court
before
the
Plaintiffs
undertook
the
duties
as
Receivers.

Checkmate,
libs!


Or

not.

Indeed, NY
CPLR
§
6402

does
require
temporary
receivers
to
take
an
oath.
But
there’s
no
requirement
that
such
an
oath
be
docketed
with
the
court.
In
their

reply
,
Freeman
and
Moss’s
lawyer
Michael
Gottlieb,
a
litigation
partner
at
Willkie
Farr
(along
with
five
other
lawyers),
attached
said

oaths
,
signed
three
days
after
the
court’s
receivership
order,
noting
that
“there
is
no
requirement
that
the
oaths
be
filed—but
even
if
there
were,
now
that
the
oaths
have
been
filed,
any
merit
in
Mr.
Giuliani’s
argument
would
be
moot.”

Gottlieb
et
al
also
documented
Rudy’s
ongoing
shenanigans
regarding
his
sports
memorabilia,

With
respect
to
the
signed
Joe
DiMaggio
shirt,
Mr.
Giuliani
now
claims
there
“is
no
Signed
Joe
DiMaggio
shirt
that
I
possess”
and
that
“the
Signed
Joe
DiMaggio
shirt
was
hanging
in
the
New
York
Cooperative
apartment
at
the
time
the
apartment
was
turned
over.”
Mr.
Giuliani’s
claim
to
have
suddenly
lost
track
of
the
signed
Joe
DiMaggio
jersey
is
not
credible
for
multiple
independent
reasons.
First,
Mr.
Giuliani’s
former
counsel
represented
to
the
Court
at
the
November
7
Hearing
that
the
signed
Joe
DiMaggio
shirt
was
located
at
the
CTS
facility
in
Ronkonkoma.
Second,
the
signed
Joe
DiMaggio
shirt
was
not
present
at
the
New
York
Apartment
when
counsel
for
PlaintiffsReceivers
visited
on
October
31,
2024,
as
evidenced
by
comparing
the
photo
of
the
real
estate
listing
of
the
room
where
the
framed,
signed
Joe
DiMaggio
jersey
was
hanging
with
the
one
Plaintiffs’
counsel
submitted
from
the
October
visit.
Third,
one
of
Mr.
Giuliani’s
trial
witnesses
and
oldest
friends,
Monsignor
Alan
Placa—who
Mr.
Giuliani
recently
testified
would
be
a
credible
and
trustworthy
witness
testified
under
oath
during
his
recent
deposition
that
he
had
not
traveled
to
New
York
in
seven
years
but
that
he
had
personally
seen
the
framed,
signed
Joe
DiMaggio
shirt
within
the
last
two
years,
and
specifically
“at
the
apartment

actually,
it
was
here
in
Florida”
at
the
Palm
Beach
Condo.
Similarly,
Mr.
Giuliani’s
claim
that
there
“was
no
Reggie
Jackson
picture”
is
belied
by
his
own
Bankruptcy
Schedule,
and
his
former
counsel’s
representation
to
this
Court
that
the
signed
Reggie
Jackson
was
present
at
the
CTS
facility
in
Ronkonkoma.
And
even
if
Mr.
Giuliani’s
claims
about
either
signed
sports
memorabilia
had
any
indicia
of
credibility,
he
fails
to
describe
any
efforts
he
has
made
to
locate
them,
as
he
must
to
avoid
contempt.

Placa
is
a
former
priest
who
retired
under

interesting

circumstances
which
were
always
going
to
make
him
a


problematic
witness
.
In
a

deposition

he
testified
variously
that
he:
was
a
lawyer;
understood
his
role
as
deponent;
kept
calendar
entries
of
Rudy’s
travel
to
Florida;
and
yet
failed
to
produce
them
because
“I
read
through
[the
subpoena]
quickly
and
didn’t
feel
that
I
had
anything
that
was
responsive
at
all.”
He
also
insisted
that
he
had
no
idea
how
a
LinkedIn
profile
showing
him
as
senior
VP
at
Giuliani
Partners
came
to
be,
since
he
never
drew
a
salary
or
went
into
the
office
more
than
a
few
times.
Although
he
did
admit
that
six
FEC
disclosures
in
the
name
of
Alan
Placa,
VP
at
Giuliani
Partners
came
from
him.

Rudy’s

deposition

went
similarly
swimmingly.
Asked
why
he
failed
to
renew
his
drivers
license,
he
said
“I
have
fatwas
issued
against
me
by
the
Ayatollah,
personally.”

He
refused
to
disclose
his
email
address
because:

Ninety-nine
percent
of
it
contains
matters
that
have
nothing
to
do
with
this
case
and
a
lot
of
them
are
privileged.
A
lot
of
them
are
personal
and
it
would
seem
to
me
that
it
constitutes
overbroad
discovery,
prying
into
things

using
this
litigation
for
the
purpose
of
prying
into
things
that
are
frankly
none
of
your
business,
that
have
been
utilized
in
the
past
for
leaking,
for
giving
information
to
other
people,
so
I
don’t
give
my
email
out
generally
anyway.
I
give
it
out
to
people
that
I
believe
will
use
it
for
a
proper
purpose.

Cammarata
instructed
him
not
to
answer,
because
“I
believe
we
have
a
protective
order
with
that
information.”
(Nope.)

Also,
it
does
not
seem
to
have
occurred
to
them
that
discussing
his
testimony
over
lunch
might
waive
the
privilege
to
said
conversation.

“Any
discussions
I
had
during
the
break
with
my
attorney
and
beyond
what
I
said,
which
I
probably
shouldn’t
have
said
at
all,
is
privileged,”
he
shouted,
after
admitting
that
he
had,
indeed,
talked
about
the
deposition
with
his
lawyer.
“But
the
answer
is
I
will
not
answer
questions
about
what
I
talk
to
my
attorney
about.
I
think
I’m
entitled
to
that
privilege
as
an
American
citizen.”

TL,
DR:
Giuliani
is
an

amazing
witness
,
who
will
certainly
have
the
discipline
not
to,
say,

invoke
the
advice
of
counsel
defense
and
waive
privilege

about
why
his
prior
lawyers
ran
for
the
hills.
Or
lie
on
the
stand.
Or
assert
non-existent
privileges
in
defiance
of
the
court’s
prior
order.
Or
shout
at
the
judge.


Freeman
v.
Giuliani
 [Docket
via
Court
Listener]





Liz
Dye
 lives
in
Baltimore
where
she
produces
the
Law
and
Chaos substack and podcast.

Rudy Giuliani Finishes 2024 As He Began It … In Deep Shit – Above the Law

(Photo
by
Drew
Angerer/Getty
Images)

Rudy
Giuliani
is
running
through
the
tape
in
2024,
and
so
is
his
badabing-badabang
lawyer
Joe
Cammarata.
Although
only
one
of
them
is
in
the
running
for

ATL’s
2024
Lawyer
Of
The
Year
.
There’s
always
2025,
Joe!

The
pair
are
currently

bumstumbling

through
two
contempt
motions
in
front
of
Judge
Lewis
Liman
in
the
collection
action
brought
by
Ruby
Freeman
and
Shaye
Moss.
One
involves
Rudy’s
failure
to
comply
with
discovery,
for
which
the
plaintiffs
would
like
to
bar
him
presenting
evidence
that
he
lives
in
Florida
and
is
thus
entitled
to
assert
that
state’s
unlimited
homestead
exemption.
(Giuliani
appears
to
have
declared
himself
a
Florida
resident
in
July,
just
before
he
got
himself
booted
out
of
bankruptcy,
allowing
the
plaintiffs
to
resume
collection
efforts.
Convenient!)

The
other
issue
involves
Giuliani’s
refusal
to
comply
with
Judge
Liman’s
turnover
orders,
despite
strong
signals
from
the
court
that
something

very
unpleasant

would
happen
if
he
didn’t.
Rudy
and
his
lawyers
have
essentially
thrown
up
their
hands
in
dumbfounded
astonishment
when
instructed
that
they
needed
to
deliver
not
just
the
car
but
the
title
as
well.
Who
knew
that
handing
over
the
keys
to
the
apartment,
but
not
the
deed
(which
is
still
in
joint
tenancy
with
his
ex-wife,
several
years
after
the
divorce)
would
not
get
him
full
credit?

But
Cammarata,
whose
practice
consists
largely
of
divorce
cases,
has
come
up
with

ONE
WEIRD
TRICK

to
make
all
that
unpleasantness
go
away.

What
if

nothing
counts
because
Freeman
and
Moss
forgot
to
say
the
magic
words
first?

It
appears
that
according
to
the
Court
docket,
Plaintiffs
as
the
Court
appointed
receivers
failed
to
comply
with
CPLR
§
6402,
and
never
filed
an
“Oath”
with
the
Court
as
required
by
CPLR
§
6402
before
entering
their
duties
to
act
as
receivers.
Hence,
the
receivership
has
not
yet
technically
or
legally
begun.
The
New
York
Civil
Practice
Law
and
Rules
applies
to
the
Judgment
being
enforced
herein.
The
Oath
was
required
to
be
signed
by
Plaintiff
Ruby
Freeman
and
Plaintiff
Wandrea’
Moss
as
the
receivers
and
an
oath
must
have
been
administered
by
any
person
authorized
to
take
acknowledgment
of
deeds
by
the
real
property
law
of
New
York
State,
and
then
filed
with
the
Court
before
the
Plaintiffs
undertook
the
duties
as
Receivers.

Checkmate,
libs!


Or

not.

Indeed, NY
CPLR
§
6402

does
require
temporary
receivers
to
take
an
oath.
But
there’s
no
requirement
that
such
an
oath
be
docketed
with
the
court.
In
their

reply
,
Freeman
and
Moss’s
lawyer
Michael
Gottlieb,
a
litigation
partner
at
Willkie
Farr
(along
with
five
other
lawyers),
attached
said

oaths
,
signed
three
days
after
the
court’s
receivership
order,
noting
that
“there
is
no
requirement
that
the
oaths
be
filed—but
even
if
there
were,
now
that
the
oaths
have
been
filed,
any
merit
in
Mr.
Giuliani’s
argument
would
be
moot.”

Gottlieb
et
al
also
documented
Rudy’s
ongoing
shenanigans
regarding
his
sports
memorabilia,

With
respect
to
the
signed
Joe
DiMaggio
shirt,
Mr.
Giuliani
now
claims
there
“is
no
Signed
Joe
DiMaggio
shirt
that
I
possess”
and
that
“the
Signed
Joe
DiMaggio
shirt
was
hanging
in
the
New
York
Cooperative
apartment
at
the
time
the
apartment
was
turned
over.”
Mr.
Giuliani’s
claim
to
have
suddenly
lost
track
of
the
signed
Joe
DiMaggio
jersey
is
not
credible
for
multiple
independent
reasons.
First,
Mr.
Giuliani’s
former
counsel
represented
to
the
Court
at
the
November
7
Hearing
that
the
signed
Joe
DiMaggio
shirt
was
located
at
the
CTS
facility
in
Ronkonkoma.
Second,
the
signed
Joe
DiMaggio
shirt
was
not
present
at
the
New
York
Apartment
when
counsel
for
PlaintiffsReceivers
visited
on
October
31,
2024,
as
evidenced
by
comparing
the
photo
of
the
real
estate
listing
of
the
room
where
the
framed,
signed
Joe
DiMaggio
jersey
was
hanging
with
the
one
Plaintiffs’
counsel
submitted
from
the
October
visit.
Third,
one
of
Mr.
Giuliani’s
trial
witnesses
and
oldest
friends,
Monsignor
Alan
Placa—who
Mr.
Giuliani
recently
testified
would
be
a
credible
and
trustworthy
witness
testified
under
oath
during
his
recent
deposition
that
he
had
not
traveled
to
New
York
in
seven
years
but
that
he
had
personally
seen
the
framed,
signed
Joe
DiMaggio
shirt
within
the
last
two
years,
and
specifically
“at
the
apartment

actually,
it
was
here
in
Florida”
at
the
Palm
Beach
Condo.
Similarly,
Mr.
Giuliani’s
claim
that
there
“was
no
Reggie
Jackson
picture”
is
belied
by
his
own
Bankruptcy
Schedule,
and
his
former
counsel’s
representation
to
this
Court
that
the
signed
Reggie
Jackson
was
present
at
the
CTS
facility
in
Ronkonkoma.
And
even
if
Mr.
Giuliani’s
claims
about
either
signed
sports
memorabilia
had
any
indicia
of
credibility,
he
fails
to
describe
any
efforts
he
has
made
to
locate
them,
as
he
must
to
avoid
contempt.

Placa
is
a
former
priest
who
retired
under

interesting

circumstances
which
were
always
going
to
make
him
a


problematic
witness
.
In
a

deposition

he
testified
variously
that
he:
was
a
lawyer;
understood
his
role
as
deponent;
kept
calendar
entries
of
Rudy’s
travel
to
Florida;
and
yet
failed
to
produce
them
because
“I
read
through
[the
subpoena]
quickly
and
didn’t
feel
that
I
had
anything
that
was
responsive
at
all.”
He
also
insisted
that
he
had
no
idea
how
a
LinkedIn
profile
showing
him
as
senior
VP
at
Giuliani
Partners
came
to
be,
since
he
never
drew
a
salary
or
went
into
the
office
more
than
a
few
times.
Although
he
did
admit
that
six
FEC
disclosures
in
the
name
of
Alan
Placa,
VP
at
Giuliani
Partners
came
from
him.

Rudy’s

deposition

went
similarly
swimmingly.
Asked
why
he
failed
to
renew
his
drivers
license,
he
said
“I
have
fatwas
issued
against
me
by
the
Ayatollah,
personally.”

He
refused
to
disclose
his
email
address
because:

Ninety-nine
percent
of
it
contains
matters
that
have
nothing
to
do
with
this
case
and
a
lot
of
them
are
privileged.
A
lot
of
them
are
personal
and
it
would
seem
to
me
that
it
constitutes
overbroad
discovery,
prying
into
things

using
this
litigation
for
the
purpose
of
prying
into
things
that
are
frankly
none
of
your
business,
that
have
been
utilized
in
the
past
for
leaking,
for
giving
information
to
other
people,
so
I
don’t
give
my
email
out
generally
anyway.
I
give
it
out
to
people
that
I
believe
will
use
it
for
a
proper
purpose.

Cammarata
instructed
him
not
to
answer,
because
“I
believe
we
have
a
protective
order
with
that
information.”
(Nope.)

Also,
it
does
not
seem
to
have
occurred
to
them
that
discussing
his
testimony
over
lunch
might
waive
the
privilege
to
said
conversation.

“Any
discussions
I
had
during
the
break
with
my
attorney
and
beyond
what
I
said,
which
I
probably
shouldn’t
have
said
at
all,
is
privileged,”
he
shouted,
after
admitting
that
he
had,
indeed,
talked
about
the
deposition
with
his
lawyer.
“But
the
answer
is
I
will
not
answer
questions
about
what
I
talk
to
my
attorney
about.
I
think
I’m
entitled
to
that
privilege
as
an
American
citizen.”

TL,
DR:
Giuliani
is
an

amazing
witness
,
who
will
certainly
have
the
discipline
not
to,
say,

invoke
the
advice
of
counsel
defense
and
waive
privilege

about
why
his
prior
lawyers
ran
for
the
hills.
Or
lie
on
the
stand.
Or
assert
non-existent
privileges
in
defiance
of
the
court’s
prior
order.
Or
shout
at
the
judge.


Freeman
v.
Giuliani
 [Docket
via
Court
Listener]





Liz
Dye
 lives
in
Baltimore
where
she
produces
the
Law
and
Chaos substack and podcast.

Rudy Giuliani Finishes 2024 As He Began It … In Deep Shit – Above the Law

(Photo
by
Drew
Angerer/Getty
Images)

Rudy
Giuliani
is
running
through
the
tape
in
2024,
and
so
is
his
badabing-badabang
lawyer
Joe
Cammarata.
Although
only
one
of
them
is
in
the
running
for

ATL’s
2024
Lawyer
Of
The
Year
.
There’s
always
2025,
Joe!

The
pair
are
currently

bumstumbling

through
two
contempt
motions
in
front
of
Judge
Lewis
Liman
in
the
collection
action
brought
by
Ruby
Freeman
and
Shaye
Moss.
One
involves
Rudy’s
failure
to
comply
with
discovery,
for
which
the
plaintiffs
would
like
to
bar
him
presenting
evidence
that
he
lives
in
Florida
and
is
thus
entitled
to
assert
that
state’s
unlimited
homestead
exemption.
(Giuliani
appears
to
have
declared
himself
a
Florida
resident
in
July,
just
before
he
got
himself
booted
out
of
bankruptcy,
allowing
the
plaintiffs
to
resume
collection
efforts.
Convenient!)

The
other
issue
involves
Giuliani’s
refusal
to
comply
with
Judge
Liman’s
turnover
orders,
despite
strong
signals
from
the
court
that
something

very
unpleasant

would
happen
if
he
didn’t.
Rudy
and
his
lawyers
have
essentially
thrown
up
their
hands
in
dumbfounded
astonishment
when
instructed
that
they
needed
to
deliver
not
just
the
car
but
the
title
as
well.
Who
knew
that
handing
over
the
keys
to
the
apartment,
but
not
the
deed
(which
is
still
in
joint
tenancy
with
his
ex-wife,
several
years
after
the
divorce)
would
not
get
him
full
credit?

But
Cammarata,
whose
practice
consists
largely
of
divorce
cases,
has
come
up
with

ONE
WEIRD
TRICK

to
make
all
that
unpleasantness
go
away.

What
if

nothing
counts
because
Freeman
and
Moss
forgot
to
say
the
magic
words
first?

It
appears
that
according
to
the
Court
docket,
Plaintiffs
as
the
Court
appointed
receivers
failed
to
comply
with
CPLR
§
6402,
and
never
filed
an
“Oath”
with
the
Court
as
required
by
CPLR
§
6402
before
entering
their
duties
to
act
as
receivers.
Hence,
the
receivership
has
not
yet
technically
or
legally
begun.
The
New
York
Civil
Practice
Law
and
Rules
applies
to
the
Judgment
being
enforced
herein.
The
Oath
was
required
to
be
signed
by
Plaintiff
Ruby
Freeman
and
Plaintiff
Wandrea’
Moss
as
the
receivers
and
an
oath
must
have
been
administered
by
any
person
authorized
to
take
acknowledgment
of
deeds
by
the
real
property
law
of
New
York
State,
and
then
filed
with
the
Court
before
the
Plaintiffs
undertook
the
duties
as
Receivers.

Checkmate,
libs!


Or

not.

Indeed, NY
CPLR
§
6402

does
require
temporary
receivers
to
take
an
oath.
But
there’s
no
requirement
that
such
an
oath
be
docketed
with
the
court.
In
their

reply
,
Freeman
and
Moss’s
lawyer
Michael
Gottlieb,
a
litigation
partner
at
Willkie
Farr
(along
with
five
other
lawyers),
attached
said

oaths
,
signed
three
days
after
the
court’s
receivership
order,
noting
that
“there
is
no
requirement
that
the
oaths
be
filed—but
even
if
there
were,
now
that
the
oaths
have
been
filed,
any
merit
in
Mr.
Giuliani’s
argument
would
be
moot.”

Gottlieb
et
al
also
documented
Rudy’s
ongoing
shenanigans
regarding
his
sports
memorabilia,

With
respect
to
the
signed
Joe
DiMaggio
shirt,
Mr.
Giuliani
now
claims
there
“is
no
Signed
Joe
DiMaggio
shirt
that
I
possess”
and
that
“the
Signed
Joe
DiMaggio
shirt
was
hanging
in
the
New
York
Cooperative
apartment
at
the
time
the
apartment
was
turned
over.”
Mr.
Giuliani’s
claim
to
have
suddenly
lost
track
of
the
signed
Joe
DiMaggio
jersey
is
not
credible
for
multiple
independent
reasons.
First,
Mr.
Giuliani’s
former
counsel
represented
to
the
Court
at
the
November
7
Hearing
that
the
signed
Joe
DiMaggio
shirt
was
located
at
the
CTS
facility
in
Ronkonkoma.
Second,
the
signed
Joe
DiMaggio
shirt
was
not
present
at
the
New
York
Apartment
when
counsel
for
PlaintiffsReceivers
visited
on
October
31,
2024,
as
evidenced
by
comparing
the
photo
of
the
real
estate
listing
of
the
room
where
the
framed,
signed
Joe
DiMaggio
jersey
was
hanging
with
the
one
Plaintiffs’
counsel
submitted
from
the
October
visit.
Third,
one
of
Mr.
Giuliani’s
trial
witnesses
and
oldest
friends,
Monsignor
Alan
Placa—who
Mr.
Giuliani
recently
testified
would
be
a
credible
and
trustworthy
witness
testified
under
oath
during
his
recent
deposition
that
he
had
not
traveled
to
New
York
in
seven
years
but
that
he
had
personally
seen
the
framed,
signed
Joe
DiMaggio
shirt
within
the
last
two
years,
and
specifically
“at
the
apartment

actually,
it
was
here
in
Florida”
at
the
Palm
Beach
Condo.
Similarly,
Mr.
Giuliani’s
claim
that
there
“was
no
Reggie
Jackson
picture”
is
belied
by
his
own
Bankruptcy
Schedule,
and
his
former
counsel’s
representation
to
this
Court
that
the
signed
Reggie
Jackson
was
present
at
the
CTS
facility
in
Ronkonkoma.
And
even
if
Mr.
Giuliani’s
claims
about
either
signed
sports
memorabilia
had
any
indicia
of
credibility,
he
fails
to
describe
any
efforts
he
has
made
to
locate
them,
as
he
must
to
avoid
contempt.

Placa
is
a
former
priest
who
retired
under

interesting

circumstances
which
were
always
going
to
make
him
a


problematic
witness
.
In
a

deposition

he
testified
variously
that
he:
was
a
lawyer;
understood
his
role
as
deponent;
kept
calendar
entries
of
Rudy’s
travel
to
Florida;
and
yet
failed
to
produce
them
because
“I
read
through
[the
subpoena]
quickly
and
didn’t
feel
that
I
had
anything
that
was
responsive
at
all.”
He
also
insisted
that
he
had
no
idea
how
a
LinkedIn
profile
showing
him
as
senior
VP
at
Giuliani
Partners
came
to
be,
since
he
never
drew
a
salary
or
went
into
the
office
more
than
a
few
times.
Although
he
did
admit
that
six
FEC
disclosures
in
the
name
of
Alan
Placa,
VP
at
Giuliani
Partners
came
from
him.

Rudy’s

deposition

went
similarly
swimmingly.
Asked
why
he
failed
to
renew
his
drivers
license,
he
said
“I
have
fatwas
issued
against
me
by
the
Ayatollah,
personally.”

He
refused
to
disclose
his
email
address
because:

Ninety-nine
percent
of
it
contains
matters
that
have
nothing
to
do
with
this
case
and
a
lot
of
them
are
privileged.
A
lot
of
them
are
personal
and
it
would
seem
to
me
that
it
constitutes
overbroad
discovery,
prying
into
things

using
this
litigation
for
the
purpose
of
prying
into
things
that
are
frankly
none
of
your
business,
that
have
been
utilized
in
the
past
for
leaking,
for
giving
information
to
other
people,
so
I
don’t
give
my
email
out
generally
anyway.
I
give
it
out
to
people
that
I
believe
will
use
it
for
a
proper
purpose.

Cammarata
instructed
him
not
to
answer,
because
“I
believe
we
have
a
protective
order
with
that
information.”
(Nope.)

Also,
it
does
not
seem
to
have
occurred
to
them
that
discussing
his
testimony
over
lunch
might
waive
the
privilege
to
said
conversation.

“Any
discussions
I
had
during
the
break
with
my
attorney
and
beyond
what
I
said,
which
I
probably
shouldn’t
have
said
at
all,
is
privileged,”
he
shouted,
after
admitting
that
he
had,
indeed,
talked
about
the
deposition
with
his
lawyer.
“But
the
answer
is
I
will
not
answer
questions
about
what
I
talk
to
my
attorney
about.
I
think
I’m
entitled
to
that
privilege
as
an
American
citizen.”

TL,
DR:
Giuliani
is
an

amazing
witness
,
who
will
certainly
have
the
discipline
not
to,
say,

invoke
the
advice
of
counsel
defense
and
waive
privilege

about
why
his
prior
lawyers
ran
for
the
hills.
Or
lie
on
the
stand.
Or
assert
non-existent
privileges
in
defiance
of
the
court’s
prior
order.
Or
shout
at
the
judge.


Freeman
v.
Giuliani
 [Docket
via
Court
Listener]





Liz
Dye
 lives
in
Baltimore
where
she
produces
the
Law
and
Chaos substack and podcast.

How the Pentagon domesticated the chatbot: 2024 in review – Breaking Defense

Sailors
assigned
to
Navy
Cyber
Defense
Operations
Command
monitor,
analyze,
detect
and
respond
to
unauthorized
activity
within
U.S.
Navy
information
systems
and
computer
networks.
(DVIDS)

WASHINGTON

Large
Language
Models
haven’t
achieved

human-like
consciousness

and
transformed
or
shattered
society

at
least
not
yet

as
prominent
figures
like
Elon
Musk

suggested

early
in
the
hype
cycle.
But
they
also
haven’t
been
crippled
to
the
point
of
inutility
by
their
tendency
to

“hallucinate”
false
answers
.

Instead,
generative
AI
is
emerging
as
a
useful
tool
for
a
wide
but
hardly
unlimited
range
of
purposes,
from
summarizing
reams
of
regulations
to
drafting

procurement
memoranda

and

supply
plans
.

So,

two
years

after
the
public
unveiling
of
ChatGPT,

16
months

after
the
Department
of
Defense
launched

Task
Force
Lima

to
figure
out
the
perils
and
potential
of
generative
AI,
the
Pentagon’s
Chief
Digital
&
AI
Office
(CDAO)
effectively
declared
the
new
technology
was
adequately
understood
and
sufficiently
safeguarded
to
deploy.
On
Dec.
11
the
CDAO
officially
wrapped
up
the
exploratory
task
force
a
few
months
ahead
of
schedule,
institutionalized
its
findings,
and
created
a
standing

AI
Rapid
Capabilities
Cell

(AIRCC)
with
$100
million
in
seed
funding
to
accelerate
GenAI
adoption
across
the
DoD.



[This
article
is
one
of many

in
a
series

in
which
Breaking
Defense
reporters
look
back
on
the
most
significant
(and
entertaining)
news
stories
of
2024
and
look
forward
to
what
2025
may
hold.]

The
AIRCC’s
forthcoming
pilot
projects
are
hardly
the
first
Pentagon
deployments
of
GenAI.
The
Air
Force
gave
its
personnel
access
to

a
chatbot
called
NIPRGPT

in
June,
 for
example,
while

the
Army
deployed
a
GenAI
system

by
Ask
Sage
that
could
even
be
used
to
draft
formal
acquisition
documents.
But
these
two
cases
also
show
the
kinds
of
“guardrails”
the
Pentagon
believes
are
necessary
to

safely
and
responsibly

use
generative
AI.



RELATED:

In
AI
we
trust:
how
DoD’s
Task
Force
Lima
can
safeguard
generative
AI
for
warfighters

To
start
with,
neither
AI
is
on
the
open
internet:
They
both
run
only
on
closed
Defense
Department
networks

the
Army
cloud
for
Ask
Sage,
the
DoD-wide
NIPRnet
for
NIPRPT.
That
sequestration
helps

prevent
leakage
of
users’
inputs
,
such
as
detailed
prompts
which
might
reveal
sensitive
information.
Commercial
chatbots,
by
contrast,
often
suck
up
everything
their
users
tell
them
to
feed
their
insatiable
appetite
for
training
data,
and
it’s
possible
to
prompt
them
in
such
a
way
that
they

regurgitate,
verbatim
,
the
original
information
they’ve
been
fed

something
the
military
definitely
doesn’t
want
to
happen.

Another
increasingly
common
safeguard
to
run
the
user’s
input
through
multiple
Large
Language
Models
and
use
them
to
doublecheck
each
other.
Ask
Sage,
for
instance,
has
over
150
different
models
under
the
hood.
That
way,
while
any
individual
AI
may
still
hallucinate
random
absurdities,
it’s
unlikely
that
two
completely
different
models
from
different
makers
will
generate
the
same
mistakes.

Finally,
in
2024
it
became
a
best
practice
in
both
DoD
and
the
private
sector
to
put
generative
AI
on
a
diet,
feeding
it
only
carefully
selected
and
trustworthy
data,
often
using
a
process
called

Retrieval
Augmented
Generation

(RAG).
By
contrast,
many
free
public
chatbots
were
trained
on
vast
swathes
of
the
Internet,
without
any
human
factchecking
beforehand
or
any
algorithmic
ability
to
detect
errors,
frauds,
or
outright
jokes

like
an
old
Reddit
post
about
putting

glue
on
pizza

that
Google’s
AI
began
regurgitating
as
a
serious
recipe
in
one
notable
example
this
year.

Some
defense
officials
said
this
year
they
a
savvy
adversary
could
go
further
and
deliberately
insert
errors
into
training
data,

“poisoning”

any
AI
built
on
it
to
make
errors
they
could
exploit.
By
contrast,
the
Pentagon
prefers
AIs
which
are
trained
on
official
documents
and
other
government
datasets,
and
which

cite
specific
pages
and
paragraphs

as
supporting
evidence
for
their
answers
so
the
human
user
can
double-check
for
themselves.

None
of
these
safeguards
is
surefire,
and
it’s
still
possible
for
generative
AI
to
go
wrong.
But
at
least
the
guardrails
are
now
strong
enough
that
the
Pentagon
feels
safe
to
drive
ahead
into
2025.