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

Filing 27

Unopposed MOTION for Extension of Time to File Response/Reply as to 20 MOTION to Dismiss , 23 MOTION to Dismiss under the D.C. Anti-SLAPP Act, 22 MOTION to Dismiss Amended Complaint, 21 MOTION to Dismiss under the D.C. Anti-SLAPP Act , Consent MOTION for Leave to File Excess Pages by DONALD J. TRUMP FOR PRESIDENT, INC., ROGER STONE (Attachments: # 1 Text of Proposed Order)(Carvin, Michael)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

ROY COCKRUM, ET AL.,
Plaintiffs,
v.

Case No. 1:17-cv-1370-ESH

DONALD J. TRUMP FOR PRESIDENT, INC.
ET AL.,
Defendants.

DEFENDANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO
FILE REPLY BRIEFS AND FOR LEAVE TO FILE EXCESS PAGES
Defendants Donald J. Trump for President, Inc. and Roger Stone respectfully
submit this joint motion.
First, we move to extend the time to file the reply briefs in support of the motions
to dismiss and anti-SLAPP motions from December 18 to December 29. This week,
three separate groups—two supporting plaintiffs, one supporting neither party—
informed us that they would like to file amicus curiae briefs by December 8. These
briefs would thus be filed a week into our reply period. We therefore request that
the Court extend the deadline for the replies to December 29, in order to ensure
that we have adequate time to address both Plaintiffs’ and amici’s points. We conditionally consent to the filing of the amicus briefs on the assumption that the Court
grants this extension. Plaintiffs’ counsel have informed us that Plaintiffs do not oppose our requested extension.

Second, we move to file replies in support of our motions to dismiss that exceed
the 25-page limit established by Local Civil Rule 7(e). Specifically, we ask that each
defendant be allowed to file a reply of up to 30 pages. The Court previously granted
Plaintiffs permission to file a 70-page instead of a 45-page opposition to the motion
to dismiss; we believe that additional pages are warranted so that we can fully respond to Plaintiffs’ arguments. Plaintiffs’ counsel have informed us (and indicated
in their own motion for excess pages) that Plaintiffs consent to the requested pagelimit extension. (Dkt. 24.)

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Dated: December 7, 2017

Respectfully submitted,

/s/ Robert Buschel
Robert C. Buschel (FL Bar No. 0063436)
Counsel of Record
BUSCHEL GIBBONS, P.A.
One Financial Plaza, Suite 1300
100 SE Third Avenue
Fort Lauderdale, FL 33394
[phone]
[e-mail]

/s/ Michael A. Carvin
Michael A. Carvin (DC Bar No. 366784)
Counsel of Record
Vivek Suri (DC Bar No. 1033613)
JONES DAY
51 Louisiana Avenue, NW
Washington, DC 20001
[phone]
[e-mail]
[e-mail]

L. Peter Farkas (DC Bar No. 52944)
HALLORAN FARKAS & KITTLA, LLP
1101 30th Street NW
Washington, DC 20007
[phone]
[e-mail]

Jeffrey Baltruzak (PA Bar No. 318156)
JONES DAY
500 Grant Street, Suite 4500
Pittsburgh, PA 15219
[phone]
[e-mail]

Grant J. Smith (FL Bar No. 935212)
STRATEGYSMITH, P.A.
401 East Las Olas Boulevard
Suite 130-120
Fort Lauderdale, FL 33301
[phone]
[e-mail]

Counsel for Donald J. Trump for President,
Inc.

Counsel for Roger Stone

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CERTIFICATE OF SERVICE
I certify that on December 7, 2017, I electronically filed the foregoing with the
Clerk of Court using the CM/ECF system, which will send a notice of electronic filing to all registered parties.

Dated: December 7, 2017

/s/ Michael A. Carvin
Michael A. Carvin
Counsel for Donald J. Trump for President,
Inc.