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 44 Filed 04/17/24 Page 1 of 5 PageID #: 1742
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 Pursuant to Local Civil Rule 7(k), the government respectfully requests leave to file a 12-page 

reply brief in support of Defendants’ Motion to Dismiss, two pages in excess of the page limit that 

applies to reply briefs for dispositive motions. Good cause supports this request: 

1. The government filed its Motion to Dismiss on March 25, 2024. ECF No. 33. Plaintiffs 

filed their Opposition on April 10, 2024. ECF No. 41. The government’s Reply is due on 

April 17, 2024. 

2. Plaintiffs attached 52 exhibits to their opposition brief, totaling over 500 pages. 

3. In order to adequately address the issues raised in Plaintiffs’ Opposition and the attached 

exhibits, the government respectfully requests leave to file a 12-page reply brief, which is 

2 pages more than the 10 pages allowed under Local Rule 7(a)(1). 

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

request. Both parties have consented to all prior requests for extra pages in this litigation. 

Dated: April 17, 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 

Case 6:23-cv-00609-JDK Document 44 Filed 04/17/24 Page 2 of 5 PageID #: 1743
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1100 L Street, N.W. 

Washington, D.C. 20005 

Tel: (202) 451-772 

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 April 17, 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 

Case 6:23-cv-00609-JDK Document 44 Filed 04/17/24 Page 5 of 5 PageID #: 1746