COCKRUM et al v. DONALD J. TRUMP FOR PRESIDENT, INC. et al

Filing 24

Consent MOTION for Leave to File Excess Pages by ROY COCKRUM, SCOTT COMER, ERIC SCHOENBERG (Attachments: # 1 Text of Proposed Order)(Berwick, Benjamin)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
ROY COCKRUM, SCOTT COMER, and
ERIC SCHOENBERG,
Plaintiffs,
v.
DONALD J. TRUMP FOR PRESIDENT,
INC., and ROGER STONE,
Defendants.

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) Civil Action No. 1:17-cv-1370-ESH
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PLAINTIFFS’ UNOPPOSED MOTION TO FILE EXCESS PAGES IN RESPONSE TO
DEFENDANTS’ MOTIONS TO DISMISS
Plaintiffs respectfully request permission to file a memorandum of point and authorities
in opposition to Defendants’ motions to dismiss, ECF Nos. 20, 22, that is longer than the 45-page
limit provided under Local Rule of Civil Procedure 7(e). Specifically, Defendants ask that they
be allowed to file a brief of up to seventy pages. Pursuant to Rule 7(m), the undersigned counsel
conferred with counsel for Defendants, who represented that Defendants consent to the requested
extension of the page limit if Plaintiffs consent to a five-page extension of the page limit for
Defendants’ reply briefs. Plaintiffs do indeed consent to such an extension.
In further support of this motion, Plaintiffs note that they intend to file a single
consolidated brief in response to Defendants’ motions to dismiss.1 Defendants’ briefs in support
of their motions total approximately eighty pages, and seek dismissal on several grounds,
including subject matter jurisdiction, personal jurisdiction, venue, and failure to state a claim. As
such, the requested page-limit extension is warranted.
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Plaintiffs will file a separate consolidated brief in opposition to Defendants’ anti-SLAPP
motions, ECF Nos. 21, 23, but do not seek a page-limit extension for that brief at this time.
1

Date: November 20, 2017

/s/ Benjamin L. Berwick
BENJAMIN L. BERWICK (D.D.C. Bar No. MA0004)
United to Protect Democracy
10 Ware St.
Cambridge, MA 02138
[phone]
[e-mail]
IAN BASSIN (NY Attorney Registration No.
4683439)
United to Protect Democracy
147 Prince St.
Brooklyn, NY 11201
[phone]
[e-mail]
JUSTIN FLORENCE (D.C. Bar No. 988953)
[e-mail]
ANNE TINDALL (D.C. Bar. No. 494607)
[e-mail]
United to Protect Democracy
2020 Pennsylvania Ave. NW, #163
Washington, DC 20006
[phone]
NANCY GERTNER (MA Bar No. 190140)
Fick & Marx
100 Franklin Street, 7th floor
Boston, MA 02110
[phone]
[e-mail]
RICHARD PRIMUS (D.C. Bar No. 472223)
The University of Michigan Law School*
625 S. State Street
Ann Arbor, MI 48109
[phone]
[e-mail]
STEVEN A. HIRSCH (CA Bar No. 171825)
Keker, Van Nest & Peters LLP
633 Battery Street
San Francisco, CA 94111-1809
[phone]
[e-mail]

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* For identification purposes.
Counsel for Plaintiffs

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