Gov Uscourts DCD 258149 273 0

Case 1:23-cr-00257-TSC Document 273 Filed 10/25/24 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v. Case No. 1:23-cr-00257-TSC
DONALD J. TRUMP,
Defendant.
PRESIDENT DONALD J. TRUMP’S

MOTION TO CONTINUE FILING DEADLINES
President Donald J. Trump respectfully requests that the Court continue the deadlines to
file his forthcoming: (1) Response and Renewed Motion to Dismiss Based on Presidential
Immunity (“Response”), (2) Motion to Compel Immunity-Related Discovery (“Motion to
Compel”), and (3) Reply in Support of Motion to File a Motion to Dismiss Based on the
Appointments and Appropriations Clauses (the “A-A Reply”), to November 21, 2024. In support,
President Trump states as follows:
BACKGROUND
On September 26, 2024, the Special Counsel filed a 165-page immunity motion, together
with a nearly 2,000-page appendix. Docs. 254, 266. Thereafter, on October 2, 2024, President
Trump moved, inter alia, for leave to file an oversized brief and to extend the filing deadline for
his Response. Doc. 253. The Court granted President Trump’s motion in part and denied in part,
setting a new deadline of November 7, 2024.
The following week, Hurricane Milton made landfall in Florida, displacing and severely
disrupting Florida defense counsel from both undersigned firms.1 Counsel nonetheless endeavored
1
At the Court’s request, defense counsel will provide specific descriptions of the nature and extent
of the hardships imposed by the hurricane. To the extent the Court requests such detail, counsel
1
to comply with the Court’s deadlines, submitting multiple substantive filings on October 10, 2024
(Doc. 260), October 17, 2024 (Doc. 264), and October 24, 2024 (Doc. 270).
On October 16, 2024, the Court entered a 50-page order, together with a classified
supplement, granting in part and denying in part President Trump’s prior discovery motions, and
setting additional deadlines of October 26, 2024 (for the Special Counsel to comply with additional
discovery obligations) and October 30, 2024 (for President Trump to move to compel immunity-
related discovery). Doc. 263. This motion follows.
DISCUSSION
The Court may extend deadlines that have not yet elapsed for good cause shown. Fed. R.
Crim. P. 45(b)(1)(A). Here, President Trump seeks brief continuances of his filing deadlines.
Although counsel is working diligently to complete the Response and Motion to Compel on the
current schedule, the disruptions caused by Hurricane Milton have frustrated that goal.
Specifically, the impacts of the hurricane, which remain ongoing for certain counsel, have
substantially slowed progress on the Response. This, in turn, has limited counsel’s ability to
thoroughly consider the Court’s extensive classified and unclassified discovery order and prepare
an appropriate Motion to Compel.
The requested extension will resolve these issues, and allow counsel reasonable time to
complete work on both filings. Additionally, an extension will enable counsel to more fully
consider the Court’s discovery order, as well as any additional discovery produced by the Special
Counsel, and incorporate such information into the filings, as appropriate. For example, the Special
respectfully requests that the Court permit a sealed filing in light of the extraordinary press
coverage of this case, see In Re Press Application for Access to the Government's Motion for
Immunity Determinations in Case No. 23-Cr-357, United States of America v. Donald J. Trump,
No. 1:24-mc-00122 (D.D.C.), and the irrelevance of counsel’s personal details to the merits.
2
Counsel made another classified discovery production today. As defense counsel must travel to
review these materials and consider whether to incorporate any of them into the Response and
Motion to Compel, this presents a significant obstacle to filing on the current schedule.
Needless to say, questions of Presidential immunity, and immunity-related discovery, are
complex and require substantial resources to consider and brief, as the Special Counsel’s own
enormous submission demonstrates. Despite difficulties, defense counsel have made multiple
filings this month in good faith, including a lengthy proposed motion to dismiss concerning a
complex and evolving area of the law, Doc. 270, all while continuing to draft the Response and
Motion to Compel as quickly as able. The requested extensions will ensure counsel have sufficient
and reasonable time to finish this important work, while not causing any significant delay to the
overall progress of this case.
Finally, as President Trump’s A-A Reply is currently due the same day as his immunity
Response (November 7, 2024), President Trump respectfully requests that the Court continue that
deadline by the same amount, to ensure the dates continue to match. Doing so will also ensure that
defense counsel’s limited resources are not unnecessarily diverted during the final stages of
immunity drafting.
Accordingly, President Trump respectfully requests that the Court continue the filing
deadlines for the Response, Motion to Compel, and A-A Reply to November 21, 2024. Accounting
for this extension, President Trump further requests that the deadlines for the Special Counsel’s
combined immunity reply and opposition, and President Trump’s combined reply and sur-reply,
be re-set to December 5, 2024, and December 19, 2024, respectively.
3
The Special Counsel indicates that it “does not oppose a brief continuance based on
counsel’s personal circumstances, but defers to the Court’s judgment as to the appropriate length
of any extension.”
Dated: October 25, 2024 Respectfully submitted,
/s/ Todd Blanche / Emil Bove /s/ John F. Lauro / Gregory Singer
Todd Blanche, Esq. (PHV) John F. Lauro, Esq.
[email protected] D.C. Bar No. 392830
Emil Bove, Esq. (PHV) [email protected]
[email protected] Gregory M. Singer, Esq. (PHV)
BLANCHE LAW PLLC [email protected]
99 Wall St., Suite 4460 LAURO & SINGER
New York, NY 10005 400 N. Tampa St., 15th Floor
(212) 716-1250 Tampa, FL 33602
(813) 222-8990
Counsel for President Donald J. Trump

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Case 1:23-cr-00257-TSC Document 273 Filed 10/25/24 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA

v. Case No. 1:23-cr-00257-TSC

PRESIDENT DONALD J. TRUMP’S

Immunity (“Response”), (2) Motion to Compel Immunity-Related Discovery (“Motion to

President Trump states as follows:

setting a new deadline of November 7, 2024.

related discovery). Doc. 263. This motion follows.

an appropriate Motion to Compel.

Needless to say, questions of Presidential immunity, and immunity-related discovery, are

overall progress of this case.

be re-set to December 5, 2024, and December 19, 2024, respectively.

Dated: October 25, 2024 Respectfully submitted,

Counsel for President Donald J. Trump

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