F.3d 24, 27 (1st Cir. 1997). See also Curley v. Brignoli Curley & Roberts, Assocs., 128 F.R.D. 613, 616 (S.D.N.Y. 1989) (“The contention . . . that Rule 11 should apply to any paper sent to the court, such as a letter, is not supportable.”). When, however, a letter is sent to a judge with the intent that it influence the judge to take some action, federal courts have considered the letter to be in effect a motion subject to Rule 11. See Klein v. Wilson, Elser, Moskowitz, Edelman & Dicker (In re Highgate Equities, Ltd.), 279 F.3d 148, 154 (2d Cir. 2002) (“Courts have generally [applied Rule 11 to letters] only where the letter in question was in effect a motion in disguise, recognizing that failure to sanction in such cases would elevate form over substance.”); Legault, 105 F.3d at 27 (<HOLDING>); Lopez v. Constantine, 94 Civ. 5921, 95 Civ.
holding to that effect with respect to rule 64 holding that one letter sent a year prior to the filing of a motion to compel was insufficient to satisfy the requirement to confer holding that a letter to an opposing party was a paper for purposes of frcp rule 11 where the attorney writing the letter sent a copy to the presiding judge in the case holding that rule 11 applied to a letter sent with the intent to influence the court with respect to injunctive relief holding that the clayton acts provisions on injunctive relief applied to pending cases