UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

CASE NO. 22-81294-CIV-CANNON

DONALD J. TRUMP, 

Plaintiff, 

v. 

UNITED STATES OF AMERICA, 

Defendant. 

____________________________________/

PLAINTIFF’S SUPPLEMENTAL PLEADING

REGARDING SPECIAL MASTER NOMINATIONS

On September 9, 2022, the above-captioned parties filed a joint 

submission to the Court regarding potential Special Master candidates 

proposed by each party. [ECF No. 83]. That submission indicated to the Court 

that our position on each other’s candidates would be provided by September 

12, 2022. 

Plaintiff objects to the proposed nominees of the Department of Justice. 

Plaintiff believes there are specific reasons why those nominees are not 

preferred for service as Special Master in this case.

As the Court’s Order [ECF No. 64] required a list of proposed Special 

Master candidates but did not specify whether that is to include specific 

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advocacy as to why certain nominees are or are not suitable to serve as Special 

Master, Plaintiff has construed that Order in a limited fashion.

Plaintiff also submits it is more respectful to the candidates from either 

party to withhold the bases for opposition from a public, and likely to be widely

circulated, pleading. Therefore, Plaintiff asks this Court for permission to 

specifically express our objections to the Government’s nominees only at such 

time that the Court specifies a desire to obtain and consider that information. 

Such information could then be provided in camera or pursuant to whatever 

procedure the Court deems most efficient and appropriate. Consistent with 

that approach, Plaintiff is willing to provide our specific rationale for 

supporting our nominees if and when the Court so orders.

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Dated: September 12, 2022 Respectfully submitted,

Lindsey Halligan

Florida Bar No. 109481

511 S.E. 5th Avenue

Suite 1008

Fort Lauderdale, FL 33301

Lindseyhalligan@gmail.com

M. Evan Corcoran

SILVERMAN|THOMPSON|

SLUTKIN|WHITE, LLC

400 East Pratt Street – Suite 900

Baltimore, MD 21202

Telephone: (410) 385-2225

Email: ecorcoran@silvermanthompson.com

(pro hac vice)

By: /s/ Christopher M. Kise 

Christopher M. Kise

Florida Bar No. 855545

Chris Kise & Associates, P.A.

201 East Park Avenue

5th Floor

Tallahassee, FL 32301

Telephone: (850) 270-0566

Email: chris@ckise.net

James M. Trusty

Ifrah Law PLLC

1717 Pennsylvania Avenue N.W.

Suite 650

Washington, DC 20006

Telephone: (202) 524-4176

Email: jtrusty@ifrahlaw.com

(pro hac vice)

Counsel for Plaintiff

Donald J. Trump

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on September 12, 2022, I electronically filed the 

foregoing document with the Clerk of the Court using CM/ECF. I also certify that 

the foregoing document is being served this day on all counsel of record via 

transmission of Notices of Electronic Filing generated by CM/ECF.

 /s/ Christopher M. Kise

Christopher M. Kise

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