Filing 55

Unopposed MOTION to Reschedule Hearing by ROY COCKRUM, SCOTT COMER, ERIC SCHOENBERG (Attachments: # 1 Text of Proposed Order)(Berwick, Benjamin)

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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. ) ) ) ) ) ) ) Civil Action No. 1:17-cv-1370-ESH ) ) ) ) ) ) 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. 1 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. 1 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 (909) 326-2911 IAN BASSIN (NY Attorney Registration No. 4683439) United to Protect Democracy 222 Broadway, 19th Floor New York, NY 10038 JUSTIN FLORENCE (D.C. Bar No. 988953) ANNE TINDALL (D.C. Bar. No. 494607) United to Protect Democracy 2020 Pennsylvania Ave. NW, #163 Washington, DC 20006 (202) 856-9191 NANCY GERTNER (MA Bar No. 190140) Fick & Marx 100 Franklin Street, 7th floor Boston, MA 02110 (857) 321-8360 RICHARD PRIMUS (D.C. Bar No. 472223) The University of Michigan Law School* 625 S. State Street Ann Arbor, MI 48109 (734) 647-5543 STEVEN A. HIRSCH (CA Bar No. 171825) Keker, Van Nest & Peters LLP 633 Battery Street San Francisco, CA 94111-1809 (415) 391-5400 * For identification purposes. 2

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