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

Filing 55

Unopposed MOTION to Reschedule Hearing 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 RESCHEDULE HEARING
Yesterday, the Court scheduled a hearing on the pending motions to dismiss for April 23,
2018. Plaintiffs respectfully request that the Court reschedule that hearing for the week of April
30, or any time thereafter that is convenient for the Court. Plaintiffs seek this short
postponement of the hearing because their undersigned lead counsel, Benjamin L. Berwick, who
will speak for Plaintiffs at the hearing,1 has a long-planned family vacation scheduled for the
week of April 16.
Pursuant to Rule 7(m), the undersigned counsel conferred with counsel for Defendants.
Counsel for Defendant Roger Stone represented that Mr. Stone consents to the requested
postponement, with the caveat that counsel has a conflict on May 4. Counsel for Defendant
Donald J. Trump for President, Inc. (the “Trump Campaign”) represented that the Trump
Campaign consents to the request if the Court can hold the hearing during the week of April 30
or on May 11. Otherwise, the Trump Campaign opposes the request.

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To be specific, Mr. Berwick will handle the entire hearing except for the portion pertaining to 42 U.S.C. § 1985(3)
and the anti-SLAPP motions, which will be handled by Professor Richard Primus.

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Date: April 5, 2018

/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
222 Broadway, 19th Floor
New York, NY 10038
[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)
[e-mail]
Keker, Van Nest & Peters LLP
633 Battery Street
San Francisco, CA 94111-1809
[phone]
* For identification purposes.

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