CABLE NEWS NETWORK, INC. et al v. TRUMP et al

Filing 2

MOTION for Temporary Restraining Order by ABILIO JAMES ACOSTA, CABLE NEWS NETWORK, INC. (Attachments: # 1 Memorandum in Support, # 2 65.1 Statement, # 3 Declaration of Sam Donaldson, # 4 Declaration of Same Feist, # 5 Declaration of Todd Joseph Gillman, # 6 Declaration of Jim Acosta, # 7 Declaration of Theodore J. Boutrous, # 8 Exhibit 1, # 9 Exhibit 2, # 10 Exhibit 3, # 11 Exhibit 4, # 12 Exhibit 5, # 13 Text of Proposed Order) (jf)

Case 1:18-cv-02610-TJK Document 2-2 Filed 11/13/18 Page 1 of 2

THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
CABLE NEWS NETWORK, INC. and ABILIO
JAMES ACOSTA,
Plaintiffs,
v.
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 capacity,

Case No.

Defendants.
CERTIFICATE OF NOTICE PURSUANT TO LOCAL RULE 65.1(a)
I, Theodore J. Boutrous, Jr., counsel for Plaintiffs Cable News Network, Inc. and Abilio
James Acosta, hereby certify that counsel for the Plaintiffs made the following efforts to give
notice of the time of making the application for a temporary restraining order, and copies of all
pleadings and papers filed in this action:
(a) emailed Daniel Van Horn, Chief of the Civil Division of the U.S. Attorney’s Office
for the District of Columbia, at the email address [e-mail], and provided the
pleadings and papers filed in the action to date or to be presented to the Court at the hearing;

Case 1:18-cv-02610-TJK Document 2-2 Filed 11/13/18 Page 2 of 2

(b) emailed Emmet Flood, White House Counsel, at [e-mail] and provided
the pleadings and papers filed in the action to date or to be presented to the Court at the hearing;
and
(c) emailed Donna Cahill, Chief Counsel for the United States Secret Service, at
[e-mail] and provided the pleadings and papers filed in this action to date or to be
presented to the Court at the hearing.
Dated: November 13, 2018

Respectfully submitted,
________________________________
Theodore J. Boutrous, Jr., (D.C. Bar No.
420440)
GIBSON, DUNN & CRUTCHER LLP
333 South Grand Ave.,
Los Angeles, California 90071
Tel: [phone]
[e-mail]
Theodore B. Olson (D.C. Bar No. 367456)
Joshua S. Lipshutz (D.C. Bar No. 1033391)
GIBSON, DUNN & CRUTCHER LLP
1050 Connecticut Avenue, N.W.
Washington, D.C. 20036
Tel: [phone]
[e-mail]
[e-mail]
Anne Champion (pro hac vice forthcoming)
GIBSON, DUNN & CRUTCHER LLP
200 Park Avenue
New York, New York 10166-0193
Tel: [phone]
[e-mail]
Counsel for Plaintiffs Cable News Network,
Inc., and Abilio James Acosta

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