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)

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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.) 2 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 (954) 530-5301 /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 (202) 879-3939 L. Peter Farkas (DC Bar No. 52944) HALLORAN FARKAS & KITTLA, LLP 1101 30th Street NW Washington, DC 20007 (202) 559-1700 Jeffrey Baltruzak (PA Bar No. 318156) JONES DAY 500 Grant Street, Suite 4500 Pittsburgh, PA 15219 (412) 391-3939 Grant J. Smith (FL Bar No. 935212) STRATEGYSMITH, P.A. 401 East Las Olas Boulevard Suite 130-120 Fort Lauderdale, FL 33301 (954) 328-9064 Counsel for Donald J. Trump for President, Inc. Counsel for Roger Stone 3 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.

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