UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

CASE NO.: 0:22-CV-61842

DONALD J. TRUMP,

Plaintiff,

v.

CABLE NEWS NETWORK, INC.,

Defendant.

______________________________/

JOINT MOTION FOR EXTENSION OF TIME TO RESPOND TO 

COMPLAINT AND FOR BRIEFING SCHEDULE

Defendant CABLE NEWS NETWORK, INC. (“CNN”), jointly with Plaintiff DONALD 

J. TRUMP (“Trump”), by and through their respective undersigned counsel, and pursuant to Fed. 

R. Civ. P. 6(b) and S.D. Fla. L.R. 7.1, respectfully move to establish a briefing schedule to address 

CNN’s anticipated motion to dismiss Plaintiff’s Complaint [D.E. 1] under Fed. R. Civ. P. 12(b)(6), 

and to extend the parties’ filing deadlines for same, stating as follows:

1. Trump filed his Complaint [D.E. 1] on October 3, 2022 and served CNN’s Registered 

Agent on October 11, 2022 [D.E. 10]. CNN currently has until November 1, 2022 to respond to the 

Complaint.

2. Given the nature of the Complaint, the claims made therein and CNN’s anticipated 

grounds for dismissal, CNN’s counsel raised the issue with Trump’s counsel of extending the 

briefing schedule for a response to the Complaint and stated that they also anticipated that Trump’s 

counsel would also seek leave to extend the deadline for filing his opposition to CNN’s anticipated 

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motion to dismiss from the 14 days provided for under the Local Rules for the Southern District of 

Florida.

3. The parties met and conferred and agreed that in the interest of judicial economy and 

professional courtesy as well as to reduce further extensions and motion practice, an extension of the 

schedule to respond to the Complaint would be appropriate in light of its scope and the need to fully 

address the issues raised therein. See Compere v. Nusret Miami, LLC, 2020 WL 2844888, *1 (S.D. 

Fla. May 7, 2020) (unopposed motion to extend the dispositive motion deadline by thirty days was 

granted by the Court).

4. Specifically, the parties agreed to the following schedule:

a. Response to Complaint due: November 22, 2022

b. Response to Rule 12 Motion due: December 30, 2022

c. Reply to Rule 12 Motion due: January 18, 2022

5. This request for an extension of time is made timely, in good faith, for good cause 

and not for any improper purpose or undue delay. Neither party will be prejudiced by the Court 

extending their respective deadlines, as set forth above.

6. In accordance with S.D. Fla. L.R. 7.1.A.3, the undersigned certify that counsel for 

the parties have conferred regarding the relief requested herein, and both agree to and jointly move 

for the same.

WHEREFORE, Defendant CABLE NEWS NETWORK, INC., jointly with Plaintiff 

DONALD J. TRUMP, respectfully request that this Court enter an order granting their Joint Motion 

for Briefing Schedule by extending CNN’s deadline in which to respond to the Complaint through 

and including November 22, 2022, Plaintiff’s deadline in which to respond to CNN’s anticipated 

Rule 12 motion through and including December 30, 2022, and CNN’s deadline in which to file a 

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reply through and including January 18, 2022, and grant any additional relief as is just, equitable and 

proper.

Dated: October 21, 2022

GUNSTER, YOAKLEY & STEWART, P.A. Lindsey Halligan, Esq.

450 East Las Olas Boulevard, Suite 1400 511 S.E. 5th Avenue

Fort Lauderdale, Florida 33301 Fort Lauderdale, Florida 33301

Telephone: 954-462-2000 Telephone: 720-435-2870

By: /s/ Eric C. Edison, Esq. By:_/s/ Lindsey Halligan, Esq.

George S. LeMieux, Esq. Lindsey Halligan, Esq.

Florida Bar No. 16403 Florida Bar No. 109481

Email: glemieux@gunster.com Email: lindseyhalligan@outlook.com

Eric C. Edison, Esq. 

Florida Bar No. 010379 IFRAH LAW, PLLC

Email: eedison@gunster.com James M. Trusty, Esq.

(pro hac vice admitted)

BRYAN CAVE LEIGHTON PAISNER 1717 Pennsylvania Avenue, N.W.

Eric P. Schroeder, Esq. Washington, D.C. 20006

(pro hac vice pending) Telephone: 202-852-5669

Email: eric.schroeder@bclplaw.com Email: jtrusty@ifrahlaw.com

Brian M. Underwood, Jr., Esq.

(pro hac vice pending)

Email: brian.underwood@bclplaw.com

1201 W. Peachtree St., NW

Atlanta, GA 30301

Telephone: 404-572-6894

Counsel for Defendant Cable News Network, Inc. Counsel for Donald J. Trump

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