IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

TYLER DIVISION 

THE DAILY WIRE, LLC et al., 

 Plaintiffs, 

v. 

UNITED STATES DEPARTMENT 

OF STATE et al., 

 Defendants. 

 Civil Action No. 6:23-cv-00609 (JDK) 

DEFENDANTS’ UNOPPOSED MOTION FOR LEAVE TO FILE EXCESS PAGES 

BRIAN M. BOYNTON 

 Principal Deputy Assistant Attorney General 

 JAMES J. GILLIGAN 

Special Litigation Counsel, 

Federal Programs Branch 

JOSHUA E. GARDNER 

Special Counsel, 

Federal Programs Branch 

 DOROTHY M. CANEVARI 

CRISTEN C. HANDLEY 

 CODY T. KNAPP 

 ARJUN MODY 

 Trial Attorneys 

 U.S. Department of Justice 

 Civil Division, Federal Programs Branch 

Case 6:23-cv-00609-JDK Document 31 Filed 03/22/24 Page 1 of 5 PageID #: 886
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 Pursuant to Local Civil Rule 7(k), the government respectfully requests leave to file a 49-page 

response brief in opposition to Plaintiffs’ Motion for Preliminary Injunction, in excess of the page 

limit that applies to response briefs for non-dispositive motions. Good cause supports this request: 

1. Pursuant to the Court’s Order dated March 18, 2024, the government’s deadline to 

respond to Plaintiffs’ Motion for Preliminary Injunction is March 22, 2024. ECF No. 29. 

2. Plaintiffs’ brief in support of their Motion for Preliminary Injunction is 36 pages long and 

has 40 exhibits. Plaintiffs’ Complaint is 66 pages long and contains 313 paragraphs and 5 

counts. 

3. In order to adequately address the issues raised in Plaintiffs’ Motion, and also to accurately 

describe the relevant factual background pertaining to Plaintiffs’ voluminous exhibits and 

the numerous allegations in the Complaint, the government respectfully requests leave to 

file a 49-page brief. 

4. Moreover, under the Eastern District of Texas’s Local Rule 7(a)(2), the government would 

ordinarily be permitted 15 pages for its opposition to Plaintiffs’ Motion for Preliminary 

Injunction. The Court granted Plaintiffs leave however, without objection from 

Defendants, to file a 36-page brief in support of their motion. Given the length of that 

brief, Plaintiffs’ 40 exhibits, and the length of the Complaint, the government seeks a 

reasonable 13-page extension beyond that which Plaintiffs sought for their motion and 

this Court granted. 

5. Undersigned counsel has conferred with counsel for Plaintiffs, who do not oppose this 

request, so long as Defendants consent to Plaintiffs’ forthcoming request for leave to file 

a 20-page reply brief in support of their Motion for Preliminary Injunction, as well as a 7-

day extension of time to file that brief, making it due on April 12, 2024. See ECF No. 17 

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(current deadline for Plaintiffs’ reply brief is April 5, 2024). Defendants do not oppose 

that forthcoming request. 

Dated: March 22, 2024 Respectfully submitted, 

BRIAN M. BOYNTON 

Principal Deputy Assistant Attorney General 

JAMES J. GILLIGAN 

Special Litigation Counsel, 

Federal Programs Branch 

JOSHUA E. GARDNER 

Special Counsel, 

Federal Programs Branch 

/s/ Arjun Mody 

DOROTHY M. CANEVARI (NY # 5989694) 

CRISTEN C. HANDLEY (MO # 69114) 

CODY T. KNAPP (NY # 5715438) 

ARJUN MODY (DC # 90013383) 

Trial Attorneys 

United States Department of Justice 

Civil Division 

Federal Programs Branch 

1100 L Street, N.W. 

Washington, D.C. 20005 

Tel: (202) 451-7723 

Email: arjun.a.mody@usdoj.gov 

Counsel for Defendants

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CERTIFICATE OF CONFERENCE 

Pursuant to Local Rule 7(i), counsel for Defendants conferred with counsel for Plaintiffs 

regarding the relief requested in this motion. Plaintiffs do not oppose the motion. 

/s/ Arjun Mody 

ARJUN MODY

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CERTIFICATE OF SERVICE 

On March 22, 2024, I electronically submitted this document to the clerk of court of the U.S. 

District Court for the Eastern District of Texas using the court’s electronic case filing system. I certify 

that I have served all parties electronically or by another manner authorized by Federal Rule of Civil 

Procedure 5(b)(2). 

/s/ Arjun Mody 

ARJUN MODY 

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