Exhibit B

Case 1:22-cv-23753-KMM Document 87-2 Entered on FLSD Docket 03/09/2023 Page 1 of 7
[External to Akerman]

Re: Activity in Case 1:22-cv-23753-KMM Garrison v. Bankman-Fried et al (Joint Scheduling

Report)

Adam,

This appears to be a workable resolution. As you requested, we will attach the email chain as an exhibit to the Local Rule 7.1(a)(3) certification and

file the motion as "Unopposed," noting that the details of Plaintiffs' position are in the certification and exhibit.

Thanks,

Christopher S. Carver

Counsel for Defendant Ortiz

From:	Adam	Moskowitz	<Adam@moskowitz-law.com>

Sent:	Thursday,	March	9,	2023	9:17	AM

To:	Jeffrey	Neiman

Cc:	Jessica.StebbinsBina@lw.com;	zach@colson.com;	Joseph	Kaye;	Mckenzie	Phillip;	Brandon	Floch;	Milena	Ordenes;	Jeffrey	Marcus;	Michael	Pineiro;

abrePler@berkbrePler.com;	Susan.Engel@lw.com;	Andrew.Clubok@lw.com;	BriPany.Record@lw.com;	Elizabeth.Greenman@lw.com;	Marvin.Putnam@lw.com;

michele.johnson@lw.com;	Bob@colson.com;	scasey@colson.com;	tlydon@mgclaw.com;	Eshaba@dkrpa.com;	aperaza@dkrpa.com;	DRothstein@dkrpa.com;

eric.fitzgerald@mgclaw.com;	hillary.ladov@mgclaw.com;	Lorenza	B.	Ospina;	MKahn@gibsondunn.com;	Carver,	Christopher	(Ptnr-Ftl);	Oletsky,	Jason	(Ptnr-Ftl);

Johnson,	Ka]e	(Assoc-Ftl);	jmishkin@mmwr.com;	danielsco^riedberg@gmail.com;	defink@venable.com;	stephanie.avakian@wilmerhale.com;

agoldstein@cooley.com;	aboies@bsfllp.com;	xboies@gmail.com;	szg@grossmanroth.com;	szack@bsfllp.com;	balexander@bsfllp.com;	tulrich@bsfllp.com;

jose@markmigdal.com;	Michelle@markmigdal.com;	Rejane	Passos

Subject:	Re:	Ac]vity	in	Case	1:22-cv-23753-KMM	Garrison	v.	Bankman-Fried	et	al	(Joint	Scheduling	Report)

Thank you Jeff, Jessica and Zach. Our sole goal is to make sure we are adhering to the Court’s order, which sometimes with so many defendants,

can be more difficult. We want to make it easy for everyone. 

Why don’t you file your Motion for Extension of time around 11am as you planned, you can even call it unopposed (so we can see any response by

the Court), and simply attach a copy of my email from this morning, so the Court knows we were ready to proceed with the JSR. Moreover, as

requested, we will go ahead and cancel the 1pm Zoom. 

I hope this resolution is amenable to everyone. Thanks, Adam 

Sent from my iPhone

On Mar 9, 2023, at 9:06 AM, Jeffrey Neiman <jneiman@mnrlawfirm.com> wrote:

Carver, Christopher (Ptnr-Ftl)

Thu 3/9/2023 11:06 AM

To:Adam Moskowitz <Adam@moskowitz-law.com>;

Cc:Jessica.StebbinsBina@lw.com <Jessica.StebbinsBina@lw.com>; zach@colson.com <zach@colson.com>; Joseph Kaye <joseph@moskowitz-law.com>; Mckenzie Phillip

<mphillip@mnrlawfirm.com>; Brandon Floch <bfloch@mnrlawfirm.com>; Milena Ordenes <mordenes@mnrlawfirm.com>; Jeffrey Marcus <jmarcus@mnrlawfirm.com>; Michael

Pineiro <mpineiro@mnrlawfirm.com>; abrettler@berkbrettler.com <abrettler@berkbrettler.com>; Susan.Engel@lw.com <Susan.Engel@lw.com>; Andrew.Clubok@lw.com

<Andrew.Clubok@lw.com>; Brittany.Record@lw.com <Brittany.Record@lw.com>; Elizabeth.Greenman@lw.com <Elizabeth.Greenman@lw.com>; Marvin.Putnam@lw.com

<Marvin.Putnam@lw.com>; michele.johnson@lw.com <michele.johnson@lw.com>; Bob@colson.com <Bob@colson.com>; scasey@colson.com <scasey@colson.com>;

tlydon@mgclaw.com <tlydon@mgclaw.com>; Eshaba@dkrpa.com <Eshaba@dkrpa.com>; aperaza@dkrpa.com <aperaza@dkrpa.com>; DRothstein@dkrpa.com

<DRothstein@dkrpa.com>; eric.fitzgerald@mgclaw.com <eric.fitzgerald@mgclaw.com>; hillary.ladov@mgclaw.com <hillary.ladov@mgclaw.com>; Lorenza B. Ospina

<lorie@moskowitz-law.com>; MKahn@gibsondunn.com <MKahn@gibsondunn.com>; Oletsky, Jason (Ptnr-Ftl) <jason.oletsky@akerman.com>; Johnson, Katie (Assoc-Ftl)

<katie.johnson@akerman.com>; jmishkin@mmwr.com <jmishkin@mmwr.com>; danielscottfriedberg@gmail.com <danielscottfriedberg@gmail.com>; defink@venable.com

<defink@venable.com>; stephanie.avakian@wilmerhale.com <stephanie.avakian@wilmerhale.com>; agoldstein@cooley.com <agoldstein@cooley.com>; aboies@bsfllp.com

<aboies@bsfllp.com>; xboies@gmail.com <xboies@gmail.com>; szg@grossmanroth.com <szg@grossmanroth.com>; szack@bsfllp.com <szack@bsfllp.com>;

balexander@bsfllp.com <balexander@bsfllp.com>; tulrich@bsfllp.com <tulrich@bsfllp.com>; jose@markmigdal.com <jose@markmigdal.com>; Michelle@markmigdal.com

<Michelle@markmigdal.com>; Rejane Passos <rejane@moskowitz-law.com>; Carver, Christopher (Ptnr-Ftl) <christopher.carver@akerman.com>; Jeffrey Neiman

<jneiman@mnrlawfirm.com>;

Case 1:22-cv-23753-KMM Document 87-2 Entered on FLSD Docket 03/09/2023 Page 2 of 7
Adam,

We agree with all of Jessica’s points laid out below.

At a minimum, all parties should have input during any scheduling conference. Because all parties do not have counsel yet – and, in fact, not all

parties have been served – any scheduling conference is premature. We hope you will consent to a brief extension.

Regards,

Jeff

Jeffrey	A.	Neiman

Marcus	Neiman	Rashbaum	&	Pineiro	LLP

100	Southeast	Third	Avenue

Suite	805

Fort	Lauderdale,	Florida	33394

Telephone:		954-462-1200

jneiman@mnrlawfirm.com

This	e-mail	message	is	from	Marcus	Neiman	&	Rashbaum	LLP,	a	law	firm,	and	may	contain	legally	privileged		and/or	confiden]al	informa]on.	If	the	reader	of

this	message	is	not	the	intended	recipient,	or	the	employee	or	agent	responsible	for	delivering	the	message	to	the	intended	recipient,	you	are	hereby

no]fied	that	any	dissemina]on,	distribu]on	or	copying	of	this	e-mail	message	is	strictly	prohibited.		If	you	have	received	this	message	in	error,	please	no]fy

the	sender	immediately	and	delete	this	e-mail	message	and	any	aPachments	from	your	computer	without	retaining	a	copy.

On Mar 9, 2023, at 8:40 AM, Jessica.StebbinsBina@lw.com wrote:

Adam,

Respeciully,	we’ve	been	trying	to	confer	with	respect	to	the	Court’s	order	and	our	collec]ve	response.		As	Zach	noted,	it	appears	that	an	extension	of

]me	is	necessary	so	that	all	defendants	can	be	involved.		Your	email	states	that	17	of	18	defendants	have	been	served,	meaning	that	even	by	your	count	a

defendant	hasn’t	been	served.		And	at	least	one	of	those	17	defendants	you	claim	had	been	properly	seemed	appears	to	have	contested	that	already.	

And	your	email	that	unilaterally	aPempted	to	set	a	]me	for	a	conference	today	appears	to	have	only	included	12	or	13	of	the	defendants’	counsel.	

(Note:		we	do	not	know	all	of	the	defense	counsel	–	it	would	be	helpful	if	you	could	iden]fy	those	who	you	say	you’ve	served	but	who	have	not	entered

an	appearance).		In	addi]on,	the	proofs	of	service	you’ve	filed	reflect	that	about	half	the	defendants	were	served	within	the	past	two	weeks.		Those

newly-served	defendants	no	doubt	need	]me	to	retain	counsel	and	consult	with	those	counsel	with	respect	to	their	posi]ons.	

Meanwhile,	you’ve	filed	a	mo]on	for	consolida]on	of	all	pretrial	proceedings	into	an	MDL,	which	would	add	another	40	or	so	defendants	and	require

coordina]on	with	about	ten	other	ac]ons.		All	of	this	counsels	for	a	short	delay	of	the	Rule	16	conference	and	the	Rule	26	statement	so	that	all	par]es

may	meaningfully	par]cipate.

We	understand	from	the	correspondence	that	several	of	the	defendants’	counsel	you	did	email	are	unavailable	at	1	ET	today,	and	we	obviously	cannot

conduct	a	meaningful	conference,	as	required	by	the	Rules,	with	only	some	of	the	par]es.			All	of	this	can	be	solved,	however,	if	you	(a)	complete	service

on	the	defendants	and	(b)	work	coopera]vely	with	all	the	par]es	to	set	a	]me	for	a	meaningful	conference	(with	at	least	more	than	a	day’s	no]ce)	a

reasonable	]me	aper	all	par]es	have	been	served.

As	a	result	of	all	of	this,	we	think	the	only	viable	op]on	at	this	point	is	to	ask	the	Court	for	a	brief	extension	of	the	schedule	for	the	Rule	16	Conference.		I

ask	that	everybody	consent	to	this	by	email	or	if	anybody	disagrees,	let’s	jump	on	a	short	call	as	soon	as	possible	this	morning	(we’re	available	from	now

un]l	about	11:00	AM,	but	we	don’t	believe	we	can	delay	filing	past	then).		Please	let	us	know	if	you’re	available	this	morning.		I’m	not	available	at	1	ET

but	can	speak	between	now	and	12	(I’m	out	of	the	country	at	the	moment).			If	we	can’t	get	a	call	shortly,	we	intend	to	file	our	mo]on	and	note	your

opposi]on.

Thanks,

Jessica Stebbins Bina

LATHAM & WATKINS LLP

10250 Constellation Blvd. Suite 1100

Los Angeles, CA 90067

Direct Dial: +1.424.653.5525

Email: jessica.stebbinsbina@lw.com

https://www.lw.com

From:	Adam	Moskowitz	<Adam@moskowitz-law.com>

Case 1:22-cv-23753-KMM Document 87-2 Entered on FLSD Docket 03/09/2023 Page 3 of 7
Sent:	Wednesday,	March	8,	2023	8:06	PM

To:	Lipshultz,	Zach	<zach@colson.com>

Cc:	Joseph	Kaye	<joseph@moskowitz-law.com>;	jneiman@mnrlawfirm.com;	mphillip@mnrlawfirm.com;	bfloch@mnrlawfirm.com;

mordenes@mnrlawfirm.com;	jmarcus@mnrlawfirm.com;	mpineiro@mnrlawfirm.com;	abrePler@berkbrePler.com;	Engel,	Susan	(DC)

<Susan.Engel@lw.com>;	Stebbins	Bina,	Jessica	(CC)	<Jessica.StebbinsBina@lw.com>;	Clubok,	Andrew	(DC)	<Andrew.Clubok@lw.com>;	Record,	BriPany

(DC)	<BriPany.Record@lw.com>;	Greenman,	Elizabeth	(CC)	<Elizabeth.Greenman@lw.com>;	Putnam,	Marvin	(CC)	<Marvin.Putnam@lw.com>;	Johnson,

Michele	(OC)	<michele.johnson@lw.com>;	Mar]nez,	Roberto	<Bob@colson.com>;	Casey,	Stephanie	<scasey@colson.com>;	tlydon@mgclaw.com;

Eshaba@dkrpa.com;	aperaza@dkrpa.com;	DRothstein@dkrpa.com;	eric.fitzgerald@mgclaw.com;	hillary.ladov@mgclaw.com;	Lorenza	B.	Ospina

<lorie@moskowitz-law.com>;	MKahn@gibsondunn.com;	christopher.carver@akerman.com;	jason.oletsky@akerman.com;	ka]e.johnson@akerman.com;

jmishkin@mmwr.com;	danielsco^riedberg@gmail.com;	defink@venable.com;	stephanie.avakian@wilmerhale.com;	agoldstein@cooley.com;

aboies@bsfllp.com;	David	Boies2	<xboies@gmail.com>;	Stuart	Grossman	<SZG@grossmanroth.com>;	Stephen	N.	Zack	<szack@bsfllp.com>;	Brooke

Alexander	<balexander@bsfllp.com>;	tulrich@bsfllp.com;	José	Ferrer	<jose@markmigdal.com>;	Michelle	Genet	Bernstein	<Michelle@markmigdal.com>;

Rejane	Passos	<rejane@moskowitz-law.com>

Subject:	Re:	Ac]vity	in	Case	1:22-cv-23753-KMM	Garrison	v.	Bankman-Fried	et	al	(Joint	Scheduling	Report)

Thank	you	Zach	and	we	are	very	glad	that	you	have	been	approved	to	speak	for	the	defendants,	it	will	certainly	make	these	types	of	issues	and	tasks	more

efficient	to	resolve.	

As	we	stated,	all	Defendants	have	been	served	(except	Mr.	O’Neal,	whom	we	have	proof	has	been	evading	process	for	almost	4	weeks)	and	the	Court	has

already	allowed	all	responses	to	be	filed	by	April	14th.	

In	the	abundance	of	cau]on,	and	to	adhere	to	Judge	Moore’s	recent	order,	we	see	no	reason	(now	that	everyone	has	been	served)	not	to	conduct	our

scheduled	Zoom	Conference	tomorrow	at	1pm	as	planned.	

We	have	all	completed	hundreds	of	Joint	Scheduling	Reports	and	we	already	circulate	a	drap	with	Plain]ffs’	sugges]ons,	so	please	all	plan	to	aPend.	

We	filed	this	proposed	class	case	many	months	ago	and	we	respeciully	suggest	that	we	need	to	finally	move	this	case	along.	

Our	main	goal	is	of	course	to	strictly	follow	all	of	the	Orders	by	the	Court.	It	has	been	surprising	the	great	lengths	that	many	of	the	Defendant	celebri]es

have	gone	to	evade	service	of	the	complaint	(we	have	3	different	companies	working	daily,	since	we	first	filed	this	case).	

Ini]ally,	the	Jus]ce	Department	requested	that	we	inform	the	Court	that	they	had	an	interest	in	our	case	and	wanted	to	respeciully	request	a	stay	as	to	a

few	of	the	sePling	FTX	defendants	in	their	criminal	manner.	The	Court	instructed	us	not	to	inform	the	Court	of	the	Jus]ce	Department’s	posi]on,	and	that

they	needed	to	do	so	directly.	

Second,	we	tried	to	reach	a	consensus	from	Defendants,	so	we	could	represent	to	the	Court	that	we	finally	had	an	agreement	on	a	Status	Conference,	but

we	never	heard	back	from	many	defendants.	

Finally,	the	Court	just	made	clear	that	we	all	needed	to	complete	the	Joint	Scheduling	Report	and/or	have	a	good	basis	to	seek	an	extension	of	]me.	

Now	that	all	of	the	Defendants	have	been	served,	most	have	filed	pro	hoc	requests	and	your	group	has	filed	extensive	Mo]on	to	Remand	papers,	we	will

err	on	the	safe	side	of	following	the	Court’s	instruc]ons	and	meet	and	confer,	so	we	can	all	complete	the	Joint	Scheduling	Report,	and	can	finally	move

this	case	along.	We	are	confident	that	we	will	all	be	able	to	complete	the	JSR	and	discuss	any	and	all	issues	on	our	planned	Zoom	at	1pm.	There	is	a

sec]on	for	any	and	all	defendants	to	state	any	posi]ons	in	the	drap	JSR.	

Of	course,	you	have	every	right	to	file	any	requests	for	extension	of	]me,	and	the	Court	may	agree	with	your	posi]on.	We	respeciully	request	that	you	at

least,	simply	aPach	a	copy	of	this	email,	so	the	Court	is	fully	apprised	of	our	posi]on.	

Respeciully,	Adam	

Sent	from	my	iPhone

On	Mar	8,	2023,	at	7:14	PM,	Lipshultz,	Zach	<zach@colson.com>	wrote:

Good	evening,

Thank	you	for	reaching	out	regarding	the	scheduling	conference.	Given	that	numerous	defendants	have	yet	to	be	served	and	the	Plain]ffs’	mo]on	to

transfer,	we	believe	that	a	scheduling	conference	would	be	premature.	We	will	be	filing	a	mo]on	to	con]nue	the	scheduling	conference	deadline	un]l	30

days	aper	all	the	defendants	have	been	served,	with	a	scheduling	report	due	10	days	thereaper.	We	intend	to	file	this	mo]on	by	10	AM	tomorrow	and

would	appreciate	receiving	your	posi]on	before	then.

Thank	you,

Zach

Case 1:22-cv-23753-KMM Document 87-2 Entered on FLSD Docket 03/09/2023 Page 4 of 7
On	Mar	8,	2023,	at	1:44	PM,	Joseph	Kaye	<joseph@moskowitz-law.com>	wrote:

CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or

clicking links, especially from unknown senders.

Good afternoon all,

For any who may have missed the calendar invite (we have not received responses from all), below is the Zoom

information for tomorrow’s 1:00pm EST Joint Scheduling Conference. Thanks.

Join Zoom Meeting

hIps://us02web.zoom.us/j/88960649722?pwd=VndYbW5tS3pCTEx4MzJ5YVplYjI0Zz09

Meeting ID: 889 6064 9722

Passcode: 412048

One tap mobile

+13052241968,,88960649722#,,,,*412048# US

+16465588656,,88960649722#,,,,*412048# US (New York)

Dial by your location

 +1 305 224 1968 US

 +1 646 558 8656 US (New York)

 +1 646 931 3860 US

 +1 301 715 8592 US (Washington DC)

 +1 309 205 3325 US

 +1 312 626 6799 US (Chicago)

 +1 253 215 8782 US (Tacoma)

 +1 346 248 7799 US (Houston)

 +1 360 209 5623 US

 +1 386 347 5053 US

 +1 507 473 4847 US

 +1 564 217 2000 US

 +1 669 444 9171 US

 +1 669 900 9128 US (San Jose)

 +1 689 278 1000 US

 +1 719 359 4580 US

 +1 253 205 0468 US

Meeting ID: 889 6064 9722

Passcode: 412048

Find your local number: hIps://us02web.zoom.us/u/kbjZ3l5vDP

Best,

Joseph M. Kaye, P.A.

Partner

The Moskowi+ Law Firm, PLLC

P.O. Box 141609

Coral Gables, FL 33114

For Hand Deliveries Use:

251 Valencia Ave #141609

Coral Gables, FL 33114

Office: (305) 740-1423

Direct: (786) 309-9585

Note: The information in this email is confidential and intended to be legally privileged. If you are not the intended

recipient, you must not read, use or disseminate the information contained herein; please advise the sender

immediately by reply email and delete this message and any aIachments without retaining a copy. Although this

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no responsibility is accepted by The Moskowin Law Firm or the sender of this email for any loss or damage arising

Case 1:22-cv-23753-KMM Document 87-2 Entered on FLSD Docket 03/09/2023 Page 5 of 7
in any way from its use.

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IRS.

From:	Adam	Moskowitz

Sent:	Tuesday,	March	7,	2023	4:18	PM

To:	jneiman@mnrlawfirm.com;	mphillip@mnrlawfirm.com;	bfloch@mnrlawfirm.com;	mordenes@mnrlawfirm.com;

jmarcus@mnrlawfirm.com;	mordenes@mnrlawfirm.com;	mpineiro@mnrlawfirm.com;	mordenes@mnrlawfirm.com;

abrePler@berkbrePler.com;	Susan.Engel@lw.com;	Jessica.StebbinsBina@lw.com;	Andrew.Clubok@lw.com;

BriPany.Record@lw.com;	Elizabeth.Greenman@lw.com;	Marvin.Putnam@lw.com;	michele.johnson@lw.com;

Bob@colson.com;	scasey@colson.com;	zach@colson.com;	tlydon@mgclaw.com;	Eshaba@dkrpa.com;	APeraza@dkrpa.com;

DRothstein@dkrpa.com;	eric.fitzgerald@mgclaw.com;	hillary.ladov@mgclaw.com;	Lorenza	B.	Ospina;

MKahn@gibsondunn.com;	christopher.carver@akerman.com;	jason.oletsky@akerman.com;	ka]e.johnson@akerman.com;

jmishkin@mmwr.com;	danielsco^riedberg@gmail.com;	defink@Venable.com;	stephanie.avakian@wilmerhale.com;

agoldstein@cooley.com

Cc:	aboies@bsfllp.com;	David	Boies2;	Stuart	Grossman;	Stephen	N.	Zack;	Brooke	Alexander;	tulrich@BSFLLP.com;	José	Ferrer;

Michelle	Genet	Bernstein

Subject:	Ac]vity	in	Case	1:22-cv-23753-KMM	Garrison	v.	Bankman-Fried	et	al	(Joint	Scheduling	Report)

To all FTX Defendants and their Counsel:

All of you should have reviewed the recent Order by Judge Moore, which requires the Parties to comply with the

prior Order and file the Joint Scheduling Order by this Friday. AIached is a fully drafted JSO and we certainly look

forward to reviewing your revisions, suggestions and/or edits this week. Please let us know if you have selected

one (or more) counsel to serve as Liaison Counsel, but in the abundance of caution, we have copied all counsel (and

pro se) of record. 

We have spent great efforts (4 different service companies) trying to get all of you served with our Complaint. Since

we filed this action many weeks ago, we appreciate that many of you have been cooperative, have proactively

accepted service of the complaint, and have entered your appearances. Others have been more difficult to serve and

are now joining these proceedings, either pro se or through counsel. Only one, however, has chosen instead to evade

service, in order to draw out these proceedings, or to otherwise aIempt to avoid answering for these allegations.

In any event, Defendants have now been served and are before the Court (or will soon be). The sole remaining

Defendant to accept service of the complaint is Defendant Mr. Shaquille O’Neal, who we know has discussed the

existence of this case, but is apparently still actively evading service, refusing to answer his home door when

approached by our process servers. We have reached out to his last known litigation counsel, and if any defense

counsel are aware of who will represent Mr. O’Neal in this action (or are in contact with Mr, O’Neal), please

forward this email to them, so we can ensure all Defendants are served and join in this Meet and Confer. 

In furtherance of this goal, and in accordance with the Court’s Order, aIached for Defendants’ review and input is a

draft proposed Joint Conference Report and proposed Scheduling Order. We have included Plaintiffs’ position and

designated areas for Defendants to include their respective positions, to the extent they differ from Plaintiffs’. Please

advise when there are points that are not in dispute so we can revise those points to be made jointly.

We will hold the Joint Scheduling Conference to discuss the report via Zoom on Thursday at 1:00pm EST, so we

can all discuss any and all points in dispute and finalize the report for filing by Friday afternoon, as Ordered by the

Court. We will send a calendar invite with Zoom information to each of you, so please forward the instructions to

anyone and everyone that you know will be involved in this maIer, but are not copied on this email. 

Thank you,

Adam Moskowin and David Boies

Case 1:22-cv-23753-KMM Document 87-2 Entered on FLSD Docket 03/09/2023 Page 6 of 7
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Case 1:22-cv-23753-KMM Document 87-2 Entered on FLSD Docket 03/09/2023 Page 7 of 7