Knight First Amendment Institute at Columbia University et al v. Trump et al

Filing 25

JOINT LETTER addressed to Judge Naomi Reice Buchwald from Daniel Halainen dated 09/08/2017 re: Knight First Amendment Institute, et al. v. Trump, et al., Case No. 17-cv-5205 (NRB). Document filed by Daniel Scavino, Sean M Spicer, Donald J. Trump.(Halainen, Daniel)

Case 1:17-cv-05205-NRB Document 25 Filed 09/08/17 Page 1 of 2

U.S. Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Ave., NW
Washington, DC 20530
Daniel Halainen
Trial Attorney

Tel.: [phone]
Fax: [phone]
[e-mail]

September 8, 2017
Via ECF and by Fax
The Hon. Naomi Reice Buchwald
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: Knight First Amendment Institute at Columbia University, et al. v. Trump, et al.,
No. 17-cv-5205 (NRB)
Dear Judge Buchwald,
The parties in the above-referenced matter write to update the Court on the status of their
negotiations regarding a joint stipulation of facts. The parties have exchanged drafts of a proposed
joint stipulation of facts and continue to believe that this approach is broadly workable, although
they are still negotiating certain details. The parties will endeavor to file a joint stipulation and
propose a briefing schedule by next Friday. If the parties are unable to do so by next Friday, they
will propose a schedule for further proceedings.
In addition, in light of these ongoing negotiations, Defendants respectfully request that the
deadline for Defendants to file a responsive pleading to the Complaint be extended from
September 15, 2017, to September 29, 2017. There have been no previous requests for an
extension of this deadline. Plaintiffs do not object to this request.
Respectfully submitted,

Jessica Ring Amunson (pro hac vice)
Tassity S. Johnson (pro hac vice)
Jenner & Block LLP
1099 New York Avenue, NW, Suite 900
Washington, DC 20001

/s/ Jameel Jaffer
Jameel Jaffer (JJ-4653)
Katherine Fallow (application for admission
pending)
Alex Abdo (AA-0527)
Knight First Amendment Institute
at Columbia University

Case 1:17-cv-05205-NRB Document 25 Filed 09/08/17 Page 2 of 2
2
314 Low Library
535 West 116th Street
New York, NY 10027
[phone]
[e-mail]
Counsel for Plaintiffs
CHAD A. READLER
Acting Assistant Attorney General
ERIC R. WOMACK
Assistant Branch Director
/s/ Daniel Halainen
MICHAEL H. BAER
DANIEL HALAINEN
Trial Attorneys
U.S. Department of Justice,
Civil Division, Federal Programs Branch
20 Massachusetts Avenue, NW
Washington, DC 20530
Telephone:
[phone]
Facsimile:
[phone]
E-mail: [e-mail]
Counsel for Defendants