(explaining that Habeas Counsel was “finally ... able to retrieve [the] materials from prior counsel”; that “[t]he boxes were a mess”; and that Habeas Counsel was “on trial for several weeks and could not devote needed attention to this project” (emphases added)).) And after retrieving and reorganizing the materials, Habeas Counsel allowed another forty-seven days to elapse before he sent the Coram Nobis Petition on October 16, 2006-notwithstanding when it was actually stamped filed. Cf. Lee v. Portuondo, No. 02-CV-3990, 2008 WL 22173078, at *2 (E.D.N.Y. Aug. 29, 2003) (concluding that the petitioner’s three attempts to obtain files in the one-year limitations period did not constitute a diligent effort); Lewis v. Walsh, No. 03-CV-1932, 2003 WL 21729840, at *3 (S.D.N.Y. July 25, 2003) (<HOLDING>). But even assuming that Petitioner’s and
holding that agency demand letters are not suits holding demand letter written prior to and during litigation absolutely privileged holding that petitioners sending sporadic letters requesting documents written with lengthy delays between each letter was not a sufficiently diligent effort holding that documents did not substantially comply where copies of letter of credit and promissory note were submitted and letter of credit required originals holding defendants were entitled to a decision on the merits on rule 11 sanctions where they substantially complied with rule 11c1a by sending a letter rather than serving a motion