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)

Download PDF
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. 2 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 (212) 854-9600 Jameel.Jaffer@knightcolumbia.org 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 3 /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: (202) 305-8573 Facsimile: (202) 616-8460 E-mail: Michael.H.Baer@usdoj.gov Counsel for Defendants 4

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?