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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)

JOINT MOTION TO STAY PROCEEDINGS

All parties to this case jointly and respectfully move this Court for a 60-day stay of the 

above-captioned case until February 18, 2025. Absent Congressional action, the Global 

Engagement Center (“GEC”) will terminate on December 23, 2024—in three days. See Defs. 

Notice of Case Development at 1, ECF No. 91. As of this filing, Congress has not extended the 

termination of GEC, and it remains Defendants’ understanding that reauthorization is unlikely to 

occur. If the GEC—the focus of a significant portion of Plaintiffs’ Complaints—is disbanded, it 

is unclear what the implications for this case will be, including with respect to reallocation of 

GEC’s funding and activities. Further, the parties reasonably anticipate that the upcoming change 

in Administration may affect the plans for future activities of the Defendants and the nature and 

scope of any resolution to this case. Because of the lack of clarity surrounding these crucial issues, 

the parties agree that a stay of proceedings is in order.

The parties agree to the following conditions:

1. Defendants represent that, at this time and consistent with currently applicable law, 

Defendants intend to make funds available for programs to counter foreign propaganda and 

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disinformation only for the purpose of countering such efforts by foreign state and non-state actors 

abroad. See Section 7074(a) of the Department of State, Foreign Operations, and Related 

Programs Appropriations Act, 2024 (Div. F, P.L. 118-47), as carried forward by the Continuing 

Appropriations Act, 2025 (Div. A, P.L. 118-83).

2. During the stay, Media Plaintiffs will be able to grant extensions to and continue to 

confer with third parties regarding their responses to subpoenas and be able to accept documents 

from third parties pursuant to the subpoenas that have already been served.

3. Media Plaintiffs reserve the right to move the Court to lift the stay if they believe

that a stay is no longer appropriate, including if Defendants engage in conduct similar to that set 

forth in the Complaint and harmful to Media Plaintiffs. Defendants in turn reserve the right to 

oppose any such motion and do not agree that any of the conduct alleged in the Complaint has 

harmed Media Plaintiffs. The parties will meet and confer before any such motion to lift the stay 

is filed, in accordance with this Court’s local rules. 

4. At the end of the stay period, the parties agree to confer and, by February 25, 2025,

advise the Court of their position on appropriate next steps. If Plaintiffs determine that expedited 

discovery and a preliminary injunction briefing schedule are still needed at the end of the stay 

period, the parties agree to present a proposed schedule. Any such schedule would allow for at 

least two weeks to complete the expedited discovery activities that are outstanding under the 

current schedule, and would also allow adequate time for the parties to confer regarding any 

disputes concerning outstanding expedited depositions.

For the forgoing reasons and in the interest of judicial and party economy, the parties 

request that the Court enter a stay until February 18, 2025 subject to the terms above.

Case 6:23-cv-00609-JDK Document 98 Filed 12/20/24 Page 2 of 5 PageID #: 2365
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DATED: December 20, 2024 Respectfully submitted,

Jenin Younes

New York Bar No. 5020847

NEW CIVIL LIBERTIES ALLIANCE

4250 N. Fairfax Drive, Suite 300

Arlington, VA 22203

Telephone: (202) 869-5210

Facsimile: (202) 869-5238

Jenin.Younes@ncla.legal

Margot J. Cleveland

Michigan Bar No. P83564

NEW CIVIL LIBERTIES ALLIANCE

4250 N. Fairfax Drive, Suite 300

Arlington, VA 22203

Telephone: (202) 869-5210

Facsimile: (202) 869-5238

Margot.Cleveland@ncla.legal

/s/ Zhonette M. Brown

Zhonette M. Brown

Virginia Bar No. 97507

NEW CIVIL LIBERTIES ALLIANCE

4250 N. Fairfax Drive, Suite 300

Arlington, VA 22203

Telephone: (202) 869-5210

Facsimile: (202) 869-5238

Zhonette.Brown@ncla.legal

Counsel for The Daily Wire Entertainment

LLC and FDRLST Media LLC

Ken Paxton

Attorney General

Brent Webster

First Assistant Attorney General

Ralph Molina

Deputy First Assistant Attorney General 

Austin Kinghorn

Deputy Attorney General for Legal Strategy

Charles K. Eldred

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Chief, Legal Strategy

Ryan D. Walters

Chief, Special Litigation Division 

/s/ David Bryant

David Bryant

Senior Special Counsel

Texas Bar No. 03281500

Munera Al-Fuhaid

Special Counsel

Texas Bar No. 24094501

Office of the Attorney General of Texas

Special Litigation Division

P.O. Box 12548, Capitol Station

Austin, Texas 78711-2548

Tel.: (512) 463-2100

David.bryant@oag.texas.gov

Munera.al-fuhaid@oag.texas.gov

Counsel for the State of Texas

BRIAN M. BOYNTON

Principal Deputy Assistant Attorney General

JOSHUA E. GARDNER

Special Counsel

Federal Programs Branch

JOSEPH E. BORSON

Assistant Director

Federal Programs Branch

/s/Cristen C. Handley 

JOSHUA M. KOLSKY (DC #993430)

Senior Trial Counsel

DOROTHY M. CANEVARI (NY #5989694)

CRISTEN C. HANDLEY (MO #69114)

ARJUN MODY (DC #90013383)

Trial Attorneys

United States Department of Justice

Civil Division, Federal Programs Branch

1100 L Street, N.W.

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Washington, D.C. 20005

Tel: (202) 305-2677

Email: cristen.handley@usdoj.gov

Counsel for Defendants 

CERTIFICATE OF CONFERRAL

Counsel for all Plaintiffs and counsel for Defendants held a telephonic conferral regarding 

this motion on December 19, 2024 and further conferred by email on December 20, 2024 to reach 

agreement on this Joint Motion. 

/s/Zhonette Brown

Zhonette Brown

CERTIFICATE OF SERVICE

I hereby certify that, on December 20, 2024, I caused a true and correct copy of the 

foregoing to be filed by the Court’s electronic filing system, to be served by operation of the 

Court’s electronic filing system on counsel for all parties who have entered in the case.

/s/Zhonette Brown

Zhonette Brown

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