IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

DONALD J. TRUMP,

 PLAINTIFF,

 v.

CABLE NEWS NETWORK, INC.

 DEFENDANT.

 CASE NO. _0:22-cv-61842_____

 MOTION TO APPEAR PRO HAC VICE

MOTION TO APPEAR PRO HAC VICE,

CONSENT TO DESIGNATION, AND REQUEST TO

ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING

In accordance with Local Rules 4(b) of the Rules Governing the Admission, Practice, Peer 

Review, and Discipline of Attorneys of the United States District Court for the Southern District 

of Florida, the undersigned respectfully moves for the admission pro hac vice of James M. Trusty

of the law firm of IFRAH LAW, PLLC, 1717 Pennsylvania Avenue, NW, Suite 650, Washington, 

DC 20006, 202-852-5669, for purposes of appearance as co-counsel on behalf of Plaintiff Donald 

J. Trump in the above-styled case only, and pursuant to Rule 2B of the CM/ECF Administrative 

Procedures, to permit James M. Trusty to receive electronic filings in this case, and in support 

thereof states as follows:

1. James M. Trusty is not admitted to practice in the Southern District of Florida and 

is a member in good standing of the State Bar of Maryland and the Bar of the District of Columbia.

2. Movant, Lindsey Halligan, Esquire, 511 SE 5th Avenue, Fort Lauderdale, Florida 

33301, is a member in good standing of the Florida Bar and the United States District Court for 

the Southern District of Florida and is authorized to file through the Court’s electronic filing 

Case 0:22-cv-61842-AHS Document 4 Entered on FLSD Docket 10/03/2022 Page 1 of 3
system. Movant consents to be designated as a member of the Bar of this Court with whom the 

Court and opposing counsel may readily communicate regarding the conduct of the case, upon 

whom filings shall be served, who shall be required to electronically file and serve all documents 

and things that may be filed and served electronically, and who shall be responsible for filing and 

serving documents in compliance with the CM/ECF Administrative Procedures. See Section 2B 

of the CM/ECF Administrative Procedures.

3. In accordance with the local rules of this Court, James M. Trusty has made payment 

of this Court’s $200 admission fee. A certification in accordance with Rule 4(b) is attached hereto.

4. James M. Trusty, by and through designated counsel and pursuant to Section 2B 

CM/ECF Administrative Procedures, hereby requests the Court to provide Notice of Electronic 

Filings to James M. Trusty at email address: jtrusty@ifrahlaw.com. 

WHEREFORE, Movant, Lindsey Halligan, moves this Court to enter an Order admitting 

James M. Trusty, to appear before this Court on behalf of Plaintiff Donald J. Trump, for all purposes 

relating to the proceedings in the above-styled matter and directing the Clerk to provide notice of 

electronic filings to James M. Trusty. 

Date: October 3, 2022 Respectfully submitted,

/s/ Lindsey Halligan

Lindsey Halligan

Florida Bar No. 109481

511 SE 5th Avenue

Fort Lauderdale, FL 33301

Telephone: (720) 435-2870

Email: lindseyhalligan@outlook.com

Counsel for Donald J. Trump

Case 0:22-cv-61842-AHS Document 4 Entered on FLSD Docket 10/03/2022 Page 2 of 3
IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

DONALD J. TRUMP,

 PLAINTIFF,

 v.

CABLE NEWS NETWORK, INC.

 DEFENDANT.

 CASE NO. __0:22-cv-61842_______

CERTIFICATION OF JAMES M. TRUSTY

James M. Trusty, Esquire, pursuant to Rule 4(b) of the Rules Governing the Admission, 

Practice, Peer Review, and Discipline of Attorneys, hereby certifies that: (1) I have studied the 

Local Rules of the United States District Court for the Southern District of Florida; (2) I am a 

member in good standing of the State Bar of Maryland and the Bar of the District of Columbia; and 

(3) I have not filed three or more motions for pro hac vice admission in this District within the last 

365 days.

/s/ James M. Trusty 

 James M. Trusty 

Case 0:22-cv-61842-AHS Document 4 Entered on FLSD Docket 10/03/2022 Page 3 of 3