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

Filing 33

MOTION for Leave to File Brief of Amicus Curiae by MARK SALTER, BEN LABOLT,HOWARD OPINKSKY, MINDY FINN,HARI SEVUGAN (Attachments: # 1 Exhibit Exhibit A: Brief of Amici Curiae)(Atkinson, Katherine) Modified on 12/11/2017 to correct filer(s)(jf).

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

ROY COCKRUM, et al.,
Plaintiffs,

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

v.
DONALD J. TRUMP FOR PRESIDENT, INC.,
& ROGER J. STONE,
Defendants.

MOTION FOR LEAVE TO FILE AMICUS CURIAE BRIEF ON BEHALF OF
CERTAIN BIPARTISAN CAMPAIGN OFFICIALS
By this motion Mark Salter, Ben LaBolt, Howard Opinsky, Mindy Finn, and Hari
Sevugan (collectively, “Bipartisan Campaign Officials”) seek leave to file an amicus brief
in opposition to Defendants’ Motion to Dismiss. The motion is assented to by Plaintiffs.
It likewise has the assent of Defendants, conditioned upon the allowance of their
unopposed Motion for Extension of Time to File Reply Briefs (Docket No. 27).
In their proposed amicus brief, attached as Exhibit A, Bipartisan Campaign
Officials assert that entry into the political arena — by working on, volunteering for, or
donating to a campaign — cannot come at the price of a wholesale forfeiture of privacy.
Otherwise political speech, which lies at the heart of the First Amendment and our
system of government, will be chilled and the free exchange of ideas will be inhibited.
These matters are pertinent to the motion before the Court because the Defendants have
claimed, instead, that the First Amendment affords them absolute right to publish (or

coordinate with others to publish) the private emails of individuals involved in a
campaign. That anomalous claim would have significant consequences, which
Bipartisan Campaign Officials set forth for the Court on the basis of their respective
experience.

RESPECTFULLY SUBMITTED,
MARK SALTER
BEN LABOLT
HOWARD OPINSKY
MINDY FINN
HARI SEVUGAN
By their attorney,
/s/M. Patrick Moore Jr.
M. Patrick Moore Jr.
Pro Hac Vice (motion pending)
Massachusetts BBO #670323
[e-mail]
HEMENWAY & BARNES LLP
75 State Street
Boston, MA 02109
[phone]

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

ROY COCKRUM, et al.,
Plaintiffs,

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

v.
DONALD J. TRUMP FOR PRESIDENT, INC.,
& ROGER J. STONE,
Defendants.

ORDER
Amici Mark Salter, Ben LaBolt, Howard Opinsky, Mindy Finn, and Hari Sevugan
are hereby granted leave to file an amicus brief subject to the provisions of Local Civil
Rule 7(o).

The Hon. Ellen Segal Huvelle
United States District Court Judge
Dated: