UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

Docket No. 9:22-CV-81780-DMM-WM

DONALD J. TRUMP, 

Plaintiff, 

v.

LETITIA JAMES, individually,

 Defendant. 

 / 

PLAINTIFF’S UNOPPOSED MOTION TO CONFORM AMENDED

COMPLAINT TO LOCAL RULES AND SUBSTITUTE EXHIBIT

 Plaintiff, President DONALD J. TRUMP (“Plaintiff”), by and through his 

undersigned counsel and pursuant to Southern District of Florida Local Rule 

5.1(b) and 7.1(a)(1)(I) files this Unopposed Motion to Conform Amended 

Complaint to Local Rules and Substitute Exhibit, and would show: 

1. Southern District of Florida Local Rule 5.1(b) requires all 

documents to be served in a case to be filed in compliance with the Southern 

District’s CM/ECF NextGen Administrative Procedures (the “Local CM/ECF 

Procedures”). 

2. Local CM/ECF Procedures Rule 3G(5) requires filings to be text 

searchable. 

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3. All or part of Composite Exhibit A to Defendant’s Notice of 

Removal (“NOR”) (Doc. 1-1), which contains the state court file, is not text 

searchable. 

4. Although portions of the state court file may be convertible into a 

searchable format, several pages of Exhibit A to the Amended Complaint seem 

to have been corrupted when originally filed in state court. Significant sections 

of the text found in Exhibit A to the Amended Complaint overlap, making the 

document illegible to the reader and making it unlikely that OCR/text layering 

software could successfully convert the current version to a text-searchable 

format. 

5. To streamline the Court’s review of the current briefs, simplify 

briefing for both sides moving forward, and make the operative complaint in 

this action both compliant with the Local Rules and accessible to the visionimpaired, Plaintiff requests leave to file a copy of the operative Amended 

Complaint (including exhibits) separately with the Court that is text 

searchable and substitutes existing Exhibit A with a non-corrupted file. The 

proposed filing will make no changes to the text of the Amended Complaint or 

to any of the exhibits to the Amended Complaint beyond addressing the 

overlapping text issue. 

WHEREFORE, Plaintiff requests leave of the Court to file copy of the 

Amended Complaint that is text searchable and conforms with Local Rules and 

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Local CM/ECF Procedures, and substitutes a non-corrupted version of Exhibit 

A to the Amended Complaint for the existing Exhibit A. 

Local Rule 7.1 (a)(3) Certification

On December 15, 2022, the undersigned conferred with Defendant’s 

counsel pursuant to Local Rule 7.1(a)(3), who stated that Defendant does not 

object to the relief requested herein.

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was filed 

with the Court’s CM/ECF system this 20th day of December, 2022, which will 

electronically serve all registered electronic filing users. See Local Rule 5.1(e).

WEBER, CRABB & WEIN, P.A.

/s/ Timothy W. Weber 

Timothy W. Weber, Esq.

FBN: 86789

timothy.weber@webercrabb.com

lisa.willis@webercrabb.com

Jeremy D. Bailie, Esq.

FBN: 118558

jeremy.bailie@webercrabb.com

carol.sweeney@webercrabb.com

R. Quincy Bird, Esq.

FBN: 105746

Quincy.Bird@webercrabb.com

honey.rechtin@webercrabb.com

5453 Central Avenue

St. Petersburg, Florida 33710

(t): 727-828-9919

(f): 727-828-9924 

Attorneys for Plaintiff President Trump

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