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

Filing 33

NOTICE of Filing Exhibits to Stipulation. Document filed by Daniel Scavino, Sean M Spicer, Donald J. Trump. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I)(Baer, Michael)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK

KNIGHT FIRST AMENDMENT INSTITUTE
AT COLUMBIA UNIVERSITY, et al.,
Plaintiffs,
No. 17-cv-5205 (NRB)
v.
DONALD J. TRUMP, President of the United
States, et al.,
Defendants.

NOTICE OF FILING
On September 28, 2017, Plaintiffs and Defendants in the above-captioned matter jointly
filed a Stipulation covering agreed facts for purposes of this litigation. Stipulation, ECF No. 301. The Stipulation incorporated by reference several exhibits to be filed with Defendants’ opening
brief. See id. ¶¶ 33-34, 63. The parties hereby jointly file the attached exhibits to the Stipulation,
as follows:
Exhibit A. Exhibit A contains @realDonaldTrump tweets and replies. This exhibit was
collected by Plaintiffs and represents all such tweets and replies that Plaintiffs are aware of, with
the exception of any deleted tweets, between January 20, 2017 and September 24, 2017.
Exhibit B. Exhibit B contains the @realDonaldTrump profile image and header images.
This exhibit was collected by Plaintiffs and represents all such images that Plaintiffs are aware of
having been used on the @realDonaldTrump account between January 20, 2017 and September
24, 2017. The header images are listed underneath the approximate date they were first used.

Exhibit C. Exhibit C contains @rpbp tweets and replies. This exhibit was collected by
Plaintiffs and represents all such tweets and replies that Plaintiffs are aware of, with the exception
of any deleted tweets, from June 5 to 11, 2017, and from August 12 to 18, 2017.
Exhibit D. Exhibit D contains @familyunequal tweets and replies. This exhibit was
collected by Plaintiffs and represents all such tweets and replies that Plaintiffs are aware of, with
the exception of any deleted tweets, between June 5 to 11, 2017, and September 13 to 19, 2017.
Exhibit E. Exhibit E contains @AynRandPaulRyan tweets and replies. This exhibit was
collected by Plaintiffs and represents all such tweets and replies that Plaintiffs are aware of, with
the exception of any deleted tweets, between May 27 to June 2, 2017, and August 18 to 24, 2017.
Exhibit F. Exhibit F contains @eugenegu tweets and replies. This exhibit was collected
by Plaintiffs and represents all such tweets and replies that Plaintiffs are aware of, with the
exception of any deleted tweets, between June 17 to 23, 2017, and September 18 to 24, 2017.
Exhibit G. Exhibit G contains @BrandonTXNeely tweets and replies. This exhibit was
collected by Plaintiffs and represents all such tweets and replies that Plaintiffs are aware of, with
the exception of any deleted tweets, between June 11 to 17, 2017, and June 26 to July 2, 2017.
Exhibit H. Exhibit H contains @joepabike tweets and replies. This exhibit was collected
by Plaintiffs and represents all such tweets and replies that Plaintiffs are aware of, with the
exception of any deleted tweets, between June 2 to 8, 2017, and June 17 to 23, 2017.
Exhibit I. Exhibit I contains @Pappiness tweets and replies. This exhibit was collected
by Plaintiffs and represents all such tweets and replies that Plaintiffs are aware of, with the
exception of any deleted tweets, between June 4 to 10, 2017, and July 22 to 28, 2017.
With respect to Exhibits C through I, Plaintiffs have collected all tweets and replies that
they are aware of from the earliest date in each exhibit, respectively, through September 24, 2017.

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The parties jointly agreed to file two representative weeks of tweets and replies as exhibits to the
Stipulation, but the full collections are available for filing should the Court so require.
Defendants have no reason to doubt the accuracy of the tweets, replies, and header and
profile images collected by Plaintiffs for the purposes of this exhibit, and jointly stipulate to these
exhibits for the purposes of this litigation.
The parties have agreed that they may include as separate exhibits to their briefs images of
tweets or replies from the parties’ Twitter accounts.

Date: October 13, 2017

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

Respectfully submitted,
/s/ Jameel Jaffer
Jameel Jaffer (JJ-4653)
Katherine Fallow (KF-2535)
Alex Abdo (AA-0527)
Knight First Amendment Institute
at Columbia University
314 Low Library
535 West 116th Street
New York, NY 10027
[phone]
[e-mail]
Counsel for Plaintiffs

CHAD A. READLER
Acting Assistant Attorney General
JOON H. KIM
Acting United States Attorney
BRETT A. SHUMATE
Deputy Assistant Attorney General
ERIC R. WOMACK
Assistant Branch Director

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/s/ Michael H. Baer
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

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