MOTION for Extension of Time of Reply Deadlines by Donald J. Trump as to Donald J. Trump, Waltine Nauta, Carlos De Oliveira. Responses due by 3/25/2024. (Kise, Christopher)
Page 1 Case 9:23-cr-80101-AMC Document 386 Entered on FLSD Docket 03/11/2024 Page 1 of
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
WEST PALM BEACH DIVISION
UNITED STATES OF AMERICA,
vs.
Case No. 23-80101-CR
CANNON/REINHART
DONALD J. TRUMP,
WALTINE NAUTA, and
CARLOS DE OLIVEIRA,
Defendants.
DEFENDANTS’ MOTION FOR AN EXTENSION OF REPLY DEADLINES
President Donald J. Trump respectfully submits this motion, on behalf of all of the
Defendants, for an extension of the deadlines for filing certain reply submissions in support of
pending pretrial motions. The Special Counsel’s Office opposes this request.
The current deadline for submitting replies is March 14, 2024. In anticipation of the March
14 hearing, President Trump will file replies in support of the pending motions relating to the
Presidential Records Act, ECF No. 327, and the Espionage Act, ECF No. 325, on the afternoon of
March 13. The Defendants respectfully request permission to file replies relating to the other
pending motions by March 24.
The reasons for this request are that (1) the Defendants and counsel need to travel to Fort
Pierce prior to March 14 in order to participate in the hearing, which is time we would otherwise
use to prepare the other reply submissions; (2) President Trump and counsel need to spend time
preparing for the oral argument, which is time we would otherwise use to prepare the other reply
submissions; (3) President Trump and counsel are currently preparing for a trial in New York,
New York that is scheduled to begin on March 25, 2024, and the need to simultaneously devote
attention to that case and this matter has been necessitated in part by the discovery violations and
strategic scheduling demands of the Special Counsel’s Office that have prejudiced President
-1-Page 2 Case 9:23-cr-80101-AMC Document 386 Entered on FLSD Docket 03/11/2024 Page 2 of
Trump in multiple respects; (4) on March 12, counsel for Defendants Nauta and De Oliveira are
reviewing physical evidence possessed by the Office that is potentially relevant to their reply
submissions; and (5) Defendant Nauta is in the process of conferring with the Office regarding
access to materials relating to grand jury practices in the District of Columbia that are relevant to
his reply in support of pending selective and vindictive prosecution motion.
The Defendants have no intention of causing unnecessary delay in these proceedings.
Allowing additional time to file reply submissions that meaningfully address the opposition filings
by the Special Counsel’s Office will contribute to the orderly resolution of the pending motions.
Moreover, the pending motions for an order regarding the scope of the prosecution team and to
compel discovery, ECF No. 262, are relevant to several of the pretrial motions for which additional
time is being sought. The resolution of the discovery motions is very likely to require supplemental
briefing regarding the pretrial motions. Therefore, we respectfully submit that no actual delay or
prejudice to the Office would result from the extensions we are seeking. Accordingly, the
Defendants respectfully request an extension, until March 24, 2024, to file reply submissions in
support of pretrial motions other than those relating to the Presidential Records Act and the
Espionage Act.
Dated: March 11,
Respectfully submitted,
/s/ Todd Blanche
Todd Blanche (PHV)
ToddBlanche@blanchelaw.com
Emil Bove (PHV)
Emil.Bove@blanchelaw.com
BLANCHE LAW PLLC
99 Wall Street, Suite New York, New York (212) 716-/s/ Christopher M. Kise
Christopher M. Kise
-2-Page 3 Case 9:23-cr-80101-AMC Document 386 Entered on FLSD Docket 03/11/2024 Page 3 of
Florida Bar No. ckise@continentalpllc.com
CONTINENTAL PLLC
255 Alhambra Circle, Suite Coral Gables, Florida (305) 677-Counsel for President Donald J. Trump
-3-Page 4 Case 9:23-cr-80101-AMC Document 386 Entered on FLSD Docket 03/11/2024 Page 4 of
CERTIFICATE OF SERVICE
I, Christopher M. Kise, certify that on March 11, 2024, I electronically filed the foregoing
document with the Clerk of Court using CM/ECF.
/s/ Christopher M. Kise
Christopher M. Kise
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Case 9:23-cr-80101-AMC Document 386 Entered on FLSD Docket 03/11/2024 Page 1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
WEST PALM BEACH DIVISION
UNITED STATES OF AMERICA,
vs.
Case No. 23-80101-CR
CANNON/REINHART
DONALD J. TRUMP,
WALTINE NAUTA, and
CARLOS DE OLIVEIRA,
Defendants.
DEFENDANTS’ MOTION FOR AN EXTENSION OF REPLY DEADLINES
President Donald J. Trump respectfully submits this motion, on behalf of all of the
Defendants, for an extension of the deadlines for filing certain reply submissions in support of
pending pretrial motions. The Special Counsel’s Office opposes this request.
The current deadline for submitting replies is March 14, 2024. In anticipation of the March
14 hearing, President Trump will file replies in support of the pending motions relating to the
Presidential Records Act, ECF No. 327, and the Espionage Act, ECF No. 325, on the afternoon of
March 13. The Defendants respectfully request permission to file replies relating to the other
pending motions by March 24.
The reasons for this request are that (1) the Defendants and counsel need to travel to Fort
Pierce prior to March 14 in order to participate in the hearing, which is time we would otherwise
use to prepare the other reply submissions; (2) President Trump and counsel need to spend time
preparing for the oral argument, which is time we would otherwise use to prepare the other reply
submissions; (3) President Trump and counsel are currently preparing for a trial in New York,
New York that is scheduled to begin on March 25, 2024, and the need to simultaneously devote
attention to that case and this matter has been necessitated in part by the discovery violations and
strategic scheduling demands of the Special Counsel’s Office that have prejudiced President
-1-
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Case 9:23-cr-80101-AMC Document 386 Entered on FLSD Docket 03/11/2024 Page 2 of 4
Trump in multiple respects; (4) on March 12, counsel for Defendants Nauta and De Oliveira are
reviewing physical evidence possessed by the Office that is potentially relevant to their reply
submissions; and (5) Defendant Nauta is in the process of conferring with the Office regarding
access to materials relating to grand jury practices in the District of Columbia that are relevant to
his reply in support of pending selective and vindictive prosecution motion.
The Defendants have no intention of causing unnecessary delay in these proceedings.
Allowing additional time to file reply submissions that meaningfully address the opposition filings
by the Special Counsel’s Office will contribute to the orderly resolution of the pending motions.
Moreover, the pending motions for an order regarding the scope of the prosecution team and to
compel discovery, ECF No. 262, are relevant to several of the pretrial motions for which additional
time is being sought. The resolution of the discovery motions is very likely to require supplemental
briefing regarding the pretrial motions. Therefore, we respectfully submit that no actual delay or
prejudice to the Office would result from the extensions we are seeking. Accordingly, the
Defendants respectfully request an extension, until March 24, 2024, to file reply submissions in
support of pretrial motions other than those relating to the Presidential Records Act and the
Espionage Act.
Dated: March 11, 2024
Respectfully submitted,
/s/ Todd Blanche
Todd Blanche (PHV)
ToddBlanche@blanchelaw.com
Emil Bove (PHV)
Emil.Bove@blanchelaw.com
BLANCHE LAW PLLC
99 Wall Street, Suite 4460
New York, New York 10005
(212) 716-1250
/s/ Christopher M. Kise
Christopher M. Kise
-2-
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Case 9:23-cr-80101-AMC Document 386 Entered on FLSD Docket 03/11/2024 Page 3 of 4
Florida Bar No. 855545
ckise@continentalpllc.com
CONTINENTAL PLLC
255 Alhambra Circle, Suite 640
Coral Gables, Florida 33134
(305) 677-2707
Counsel for President Donald J. Trump
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Case 9:23-cr-80101-AMC Document 386 Entered on FLSD Docket 03/11/2024 Page 4 of 4
CERTIFICATE OF SERVICE
I, Christopher M. Kise, certify that on March 11, 2024, I electronically filed the foregoing
document with the Clerk of Court using CM/ECF.
/s/ Christopher M. Kise
Christopher M. Kise
-4-
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