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. 

 / 

 

MOTION FOR LEAVE TO FILE BRIEF AS AMICI CURIAE IN 

OPPOSITION TO FORMER PRESIDENT TRUMP’S MOTION FOR 

JUDICIAL OVERSIGHT AND ADDITIONAL RELIEF 

Former government officials Donald B. Ayer, Gregory A. Brower, John J. Farmer 

Jr., Stuart M. Gerson, Peter D. Keisler, William F. Weld, and Christine Todd Whitman 

respectfully move for leave to file the attached brief (Ex. 1) as amici curiae in opposition 

to former President Donald J. Trump’s Motion for Judicial Oversight and Additional 

Relief. In support of their motion, Amici state the following: 

This Court has the “inherent authority” to appoint amici curiae to assist the Court 

in a proceeding. Resort Timeshare Resales, Inc. v. Stuart, 764 F. Supp. 1495, 1500–01 

(S.D. Fla. 1991). Amici participate in a litigation only for the benefit of the court, and it is 

in the court’s sole discretion to “determine the fact, extent, and manner of participation by 

the amicus.” City of S. Miami v. DeSantis, 2019 WL 9514566, at *1 (S.D. Fla. Dec. 10, 

2019). Courts have recognized that appointment of amici curiae is appropriate when the 

amici have a “special interest” or can provide assistance to the court. Id. 

Case 9:22-cv-81294-AMC Document 41 Entered on FLSD Docket 08/30/2022 Page 1 of 4
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Amici respectfully submit that they have a special interest in this matter and can 

provide assistance to the Court. Amici, whose backgrounds are described more fully in the 

attached Appendix (Ex. 2), are former federal prosecutors and state and federal 

governmental officials who served in Republican administrations, and who collectively 

have decades of experience advising on matters involving the proper scope of executive 

power and executive privilege or prosecuting cases involving sensitive materials. Amici 

include those well-versed in the U.S. Department of Justice’s investigatory procedures, 

both in connection with matters of great public interest and in cases involving the proper 

treatment of highly sensitive government documents. Finally, Amici, as demonstrated by 

their lengthy periods of government service, are committed to ensuring that the rule of law 

and legal processes are respected and safeguarded in this country. 

CONCLUSION 

For the foregoing reasons, Amici respectfully request that this Court grant them 

leave to file the attached brief. A proposed order is attached hereto (Ex. 3). 

LOCAL RULE 7.1(a)(3) CERTIFICATION 

In accordance with Local Rule 7.1(a)(3), counsel for Amici conferred by phone on 

August 30, 2022 with all parties to this case in a good faith effort to obtain consent to 

Amici’s Motion. Defendant consents to the Motion and Plaintiff opposes the Motion. 

 

Case 9:22-cv-81294-AMC Document 41 Entered on FLSD Docket 08/30/2022 Page 2 of 4
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Dated: August 30, 2022 

/s/ Jay B. Shapiro 

Jay B. Shapiro 

STEARNS WEAVER MILLER 

WEISSLER ALHADEFF &

SITTERSON, P.A. 

150 West Flagler Street, 

Suite 2200 

Miami, FL 33130 

Tel: (305) 789-3229 

jshapiro@stearnsweaver.com 

Norman L. Eisen* 

NORMAN EISEN PLLC 

2000 Massachusetts Avenue NW 

Washington, DC 20036 

Tel: (202) 709-4945 

nleisen@normaneisenllc.com 

Fred Wertheimer* 

DEMOCRACY 21 

2000 Massachusetts Avenue NW 

Washington, DC 20036 

Tel: (202) 355-9600 

fwertheimer@democracy21.org 

Respectfully submitted, 

/s/ Brad S. Karp 

Brad S. Karp* 

Roberto Finzi* 

Harris Fischman* 

David K. Kessler* 

PAUL, WEISS, RIFKIND,

WHARTON & GARRISON LLP 

1285 Avenue of the Americas 

New York, NY 10019-6064 

Tel: (212) 373-3000 

bkarp@paulweiss.com 

rfinzi@paulweiss.com 

hfischman@paulweiss.com 

dkessler@paulweiss.com 

Counsel for Amici Curiae 

* Pro hac vice application forthcoming 

 

Case 9:22-cv-81294-AMC Document 41 Entered on FLSD Docket 08/30/2022 Page 3 of 4
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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on August 30, 2022, a true and correct copy of the 

foregoing document was filed with the Clerk of the Court using the CM/ECF system. I 

also certify that copies of the foregoing document are being served on all counsel of record 

identified on the attached Service List via transmission of the Notice of Electronic Filing 

generated by CM/ECF. 

/s/ Jay B. Shapiro 

Jay B. Shapiro 

SERVICE LIST 

James M. Trusty 

IFRAH, PLLC 

1717 Pennsylvania Avenue, NW, Suite 

650 

Washington, DC 20006 

202-852-5669 

Email: jtrusty@ifrahlaw.com 

Lindsey Halligan 

511 SE 5th Avenue 

Suite 1008 

Fort Lauderdale, FL 33301 

720-435-2870 

Email: lindseyhalligan@outlook.com 

M. Evan Corcoran 

Silverman, Thompson, Slutkin, & White, 

LLC 

400 East Pratt Street, Suite 900 

Baltimore, MD 21230 

410-385-2225 

Email: 

ecorcoran@silvermanthompson.com 

Counsel for Plaintiff Donald J. Trump

Juan Antonio Gonzalez , Jr. 

United States Attorney’s Office - 

H.I.D.T.A. 

11200 NW 20th Street 

Suite 101 

Miami, FL 33172 

305-715-7640 

Fax: 305-715-7639 

Email: juan.antonio.gonzalez@usdoj.gov 

Counsel for Defendant United States of 

America

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