CABLE NEWS NETWORK, INC. et al v. TRUMP et al
MOTION for Leave to File AMICUS CURIAE OPPOSING PLAINTIFFS MOTIONS FOR A TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION by One America News Network (Fein, Bruce) (Additional attachment(s) added on 11/18/2018: # 1 Proposed Amicus Brief) (znmw).
Case 1:18-cv-02610-TJK Document 18 Filed 11/15/18 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
CABLE NEWS NETWORK, INC. and ABILIO
DONALD J. TRUMP, in his official capacity as
President of the United States; JOHN F. KELLY, in
his official capacity as Chief of Staff to the President :
of the United States; WILLIAM SHINE, in his
official capacity as Deputy Chief of Staff to the
President of the United States; SARAH
HUCKABEE SANDERS, in her official capacity as
Press Secretary to the President of the United States; :
the UNITED STATES SECRET SERVICE;
RANDOLPH ALLES, in his official capacity as
Director of the United States Secret Service; and
JOHN DOE, Secret Service Agent, in his official
MOTION FOR LEAVE TO FILE AMICUS CURIAE BRIEF OF ONE AMERICA
NEWS NETWORK IN OPPOSITION TO PLAINTIFFS’ MOTIONS FOR A
TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION
Proposed amicus curiae, One America News Network (“OAN”), respectfully moves this
Court under Local Civil Rule 7(o) for leave to file its Amicus Curiae Brief in Opposition of Plaintiffs’
Motions for a Temporary Restraining Order and Preliminary Injunction. The proposed brief is filed
simultaneously with this Motion.
This Court “has broad discretion to permit . . . participat[ion] [of] amici curiae,” and amicus
participation is appropriate where amici have “relevant expertise and a stated concern for the issues
at stake in [the] case.” Dist. of Columbia v. Potomac Elec. Power Co., 826 F. Supp. 2d 227, 237
(D.D.C. 2011). An amicus brief should “’be allowed when . . . the amicus has unique information or
perspective that can help the court beyond the help that the lawyers for the parties are able to
provide.’” Cobell v. Norton, 246 F. Supp. 2d 59, 62 (D.D.C. 2003) (quoting Ryan v. Commodity
Futures Trading Comm’n, 125 F.3d 1062, 1063 (7th Cir. 1997)).
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Case 1:18-cv-02610-TJK Document 18 Filed 11/15/18 Page 2 of 2
OAN is a 24/7 national cable network with reporters and videographers covering the White
House daily. One America News Network provides live coverage daily and its Chief White House
Correspondent covers briefings on a regular basis.
OAN’s amicus curiae brief is filed in support of Defendants and in opposition to Plaintiffs’
Motions for Temporary Restraining Order and Preliminary Injunction.
The amicus curiae brief sub judice is intended to, inter alia, highlight the unreasonable and
disruptive behavior of CNN’s Chief White House Correspondent, Plaintiff ABILIO JAMES ACOSTA,
and how his specific conduct hinders other reporters from gaining access to Administration leadership to
ask questions. OAN, with staff reporting each day from the White House is uniquely qualified to provide
this Court with information and insight based on its experience and mission in covering the White
OAN is filing now under this expedited time frame because the Court has announced that it
intends to rule on the pending temporary restraining order motion in the immediate future.
Respectfully submitted his 15th day of November 2018.
s/ W. Bruce DelValle
W. Bruce DelValle, Esquire
Bruce Fein, Esquire
Fein & DelValle PLLC
300 New Jersey Avenue NW, Suite 900
Washington, D.C. 20001
Counsel for Amicus Curiae One America News
CERTIFICATE OF SERVICE
I hereby certify that on November 15, 2018, I electronically filed the foregoing Motion for
Leave to File Amicus Curiae Brief of One America News Network in Opposition to Plaintiffs’
Motions for a Temporary Restraining Order and Preliminary Injunction in Case No: 18-CV-02610TJK, with the Clerk of the U.S. District Court for the District of Columbia by using the CM/ECF
system, which will serve all registered CM/ECF users.
/s/ W. Bruce DelValle
W. Bruce DelValle, Bar No: 1520906
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