Unopposed MOTION for Extension of Time to File Response/Reply to the Special Counsel's Classified CIPA Sec. 5 Motion to Strike by DONALD J. TRUMP. (Blanche, Todd)
Page 1 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v.
Case No. 1:23-cr-00257-TSC
DONALD J. TRUMP,
Defendant.
PRESIDENT TRUMP’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
OPPOSITION TO THE SPECIAL COUNSEL’S
CLASSIFIED CIPA § 5 MOTION TO STRIKE
On November 10, 2023, the Special Counsel’s Office filed a classified Motion to Strike
President Trump’s notice pursuant to CIPA § 5 (“Motion to Strike”). President Trump’s opposition
is currently due Friday, November 24, 2023.1 President Trump respectfully requests that the Court
grant an extension of time of one business day, to November 27, 2023, to file said opposition. The
reason for this request is that counsel is traveling during the Thanksgiving holiday weekend, and,
although counsel has spent several days in the secure facility in Washington, D.C. recently, we are
not able to return to Washington, D.C. until after the Friday, November 24, 2023 due date.
Separately, as the Court is aware, President Trump is filing motions to compel on Monday,
On November 20, counsel sought and received consent from the Special Counsel’s Office for
the relief requested herein. The Special Counsel’s Office asked that the following representation
be made regarding its position:
Counsel for the government consents to this request given the unique logistical challenge
of defense counsel traveling to Washington, D.C. on the Friday after Thanksgiving to use
the SCIF and make a classified filing with the CISO. If the Court denies the motion,
however, the government will be in the SCIF on Friday as planned to receive the
defendant’s filing.Page 2 November 27, 2023, and certain portions of our opposition to the Motion to Strike necessarily
reference and rely on our motions to compel.
For these reasons, President Trump respectfully requests an extension of time of one
business day within which to file his opposition to the Motion to Strike.
Respectfully submitted,
Dated: November 21,
/s/ Todd Blanche
Todd Blanche, Esq. (PHV)
ToddBlanche@blanchelaw.com
Emil Bove, Esq. (PHV)
Emil.Bove@blanchelaw.com
BLANCHE LAW PLLC
99 Wall St., Suite New York, NY (212) 716-
John F. Lauro, Esq.
D.C. Bar No. jlauro@laurosinger.com
Gregory M. Singer, Esq. (PHV)
gsinger@laurosinger.com
LAURO & SINGER
400 N. Tampa St., 15th Floor
Tampa, FL (813) 222-Counsel for President Donald J. Trump
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Case 1:23-cr-00257-TSC Document 159 Filed 11/21/23 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v.
Case No. 1:23-cr-00257-TSC
DONALD J. TRUMP,
Defendant.
PRESIDENT TRUMP’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
OPPOSITION TO THE SPECIAL COUNSEL’S
CLASSIFIED CIPA § 5 MOTION TO STRIKE
On November 10, 2023, the Special Counsel’s Office filed a classified Motion to Strike
President Trump’s notice pursuant to CIPA § 5 (“Motion to Strike”). President Trump’s opposition
is currently due Friday, November 24, 2023.1 President Trump respectfully requests that the Court
grant an extension of time of one business day, to November 27, 2023, to file said opposition. The
reason for this request is that counsel is traveling during the Thanksgiving holiday weekend, and,
although counsel has spent several days in the secure facility in Washington, D.C. recently, we are
not able to return to Washington, D.C. until after the Friday, November 24, 2023 due date.
Separately, as the Court is aware, President Trump is filing motions to compel on Monday,
1
On November 20, counsel sought and received consent from the Special Counsel’s Office for
the relief requested herein. The Special Counsel’s Office asked that the following representation
be made regarding its position:
Counsel for the government consents to this request given the unique logistical challenge
of defense counsel traveling to Washington, D.C. on the Friday after Thanksgiving to use
the SCIF and make a classified filing with the CISO. If the Court denies the motion,
however, the government will be in the SCIF on Friday as planned to receive the
defendant’s filing.
PDF Page 3
Case 1:23-cr-00257-TSC Document 159 Filed 11/21/23 Page 2 of 2
November 27, 2023, and certain portions of our opposition to the Motion to Strike necessarily
reference and rely on our motions to compel.
For these reasons, President Trump respectfully requests an extension of time of one
business day within which to file his opposition to the Motion to Strike.
Respectfully submitted,
Dated: November 21, 2023
/s/ Todd Blanche
Todd Blanche, Esq. (PHV)
ToddBlanche@blanchelaw.com
Emil Bove, Esq. (PHV)
Emil.Bove@blanchelaw.com
BLANCHE LAW PLLC
99 Wall St., Suite 4460
New York, NY 10005
(212) 716-1250
John F. Lauro, Esq.
D.C. Bar No. 392830
jlauro@laurosinger.com
Gregory M. Singer, Esq. (PHV)
gsinger@laurosinger.com
LAURO & SINGER
400 N. Tampa St., 15th Floor
Tampa, FL 33602
(813) 222-8990
Counsel for President Donald J. Trump
2
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