Page 1 PageID
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
Tampa Division
TRUMP MEDIA & TECHNOLOGY
GROUP CORP.,
Plaintiff,
Case No. 8:23-cv-
v.
WP COMPANY LLC,
Defendants.
Uniform Case Management Report
The goal of this case management report is to “secure the just, speedy, and
inexpensive determination of” the action. See Fed. R. Civ. P. 1. Under Local Rule
3.02(a)(2), this case management report should be used in all civil cases except those
described in Local Rule 3.02(d). Individual judges may have additional case
management preferences that can be found under each judge’s name on the Court’s
website, flmd.uscourts.gov/judges/all.
1. Date and Attendees
The parties may conduct the planning conference “in person, by telephone, or by
comparable means[.]” See Local Rule 3.02(a)(1).
The parties conducted the planning conference on 10/9/2023. Shawn Flynn, Jared
Roberts, and Jesse Binnall attended the conference for Plaintiff Trump Media &
Technology Group Corp., and Nick Gamse, Carol LoCicero, Linda Norbut,
Monica Sharma, and Tom Hentoff attended the conference for Defendant WP
Company LLC.
2. Deadlines and Dates
The parties request these deadlines and dates:
Action or Event
Date
Deadline for providing mandatory initial disclosures. See Fed. R. Civ.
P. 26(a)(1).
11/20/2023Page 2 PageID
Deadline for moving to join a party, see Fed. R. Civ. P. 14, 19, and 20,
or amend the pleadings, see Fed. R. Civ. P. 15(a).
Deadline for serving expert disclosures under Rule 26(a)(2),
including any report required by Rule 26(a)(2)(B).
12/23/
Plaintiff
7/23/
Defendant
8/23/
Rebuttal
9/23/
Deadline for completing discovery and filing any motion to compel
discovery. See Fed. R. Civ. P. 37; Middle District Discovery (2021).
10/23/
Deadline for moving for class certification, if applicable. See Fed. R.
Civ. P. 23(c).
Deadline for filing any dispositive and Daubert motion. See Fed. R. Civ.
P. 56. (Must be at least five months before requested trial date.)
Deadline for participating in mediation. See Local Rules, ch. 4.
Enter mediator’s name, address, and phone number.
Enter a date.
11/20/
10/23/
Date of the final pretrial meeting. See Local Rule 3.06(a).
4/28/
Deadline for filing the joint final pretrial statement, any motion in
limine, proposed jury instructions, and verdict form. See Local Rule
3.06(b). (Must be at least seven days before the final pretrial conference.)
5/5/
Date of the final pretrial conference. See Fed. R. Civ. P. 16(e); Local
Rule 3.06(b).
5/12/
Month and year of the trial term.
June
The trial will last approximately eight (8) days and be
☒ jury.
☐ non-jury.
3. Description of the Action
This is an action brought by Trump Media & Technology Group Corp. seeking
recovery for alleged defamatory statements published by Defendant WP Company
LLC. Page 3 PageID
4. Disclosure Statement
☒ The parties have filed their disclosure statement as required by Federal Rule of
Civil Procedure 7.1 and Local Rule 3.03.
5. Related Action
☒ The parties acknowledge their continuing duty under Local Rule 1.07(c) to
notify the judge of a related action pending in the Middle District or elsewhere by
filing a “Notice of a Related Action.” No notice need be filed if there are no related
actions as defined by the rule.
Plaintiff will simultaneously file a Notice of a Related Action.
6. Consent to a Magistrate Judge
“A United States magistrate judge in the Middle District can exercise the maximum
authority and perform any duty permitted by the Constitution and other laws of the United
States.” Local Rule 1.02(a). With the parties’ consent, a district judge can refer any civil
matter to a magistrate judge for any or all proceedings, including a non-jury or jury trial.
28 U.S.C. § 636(c).
The Court asks the parties and counsel to consider the benefits to the parties and the Court
of consenting to proceed before a magistrate judge. Consent can provide the parties
certainty and flexibility in scheduling. Consent is voluntary, and a party for any reason
can decide not to consent and continue before the district judge without adverse
consequences. See Fed. R. Civ. P. 73(b)(2).
☐ The parties do consent and file with this case management report a completed
Form AO 85 “Notice, Consent, and Reference of a Civil Action to a Magistrate
Judge,” which is available on the Court’s website under “Forms.”
☒ The parties do not consent.
7. Preliminary Pretrial Conference
☒ The parties do not request a preliminary pretrial conference before the Court
enters a scheduling order.
☐ The parties do request a preliminary pretrial conference, and the parties want to
discuss enter discussion points.
8. Discovery Practice Page 4 PageID
The parties should read the Middle District Discovery Handbook, available on the Court’s
website at flmd.uscourts.gov/civil-discovery-handbook, to understand discovery practice
in this District.
☒ The parties confirm they will comply with their duty to confer with the opposing
party in a good faith effort to resolve any discovery dispute before filing a motion.
See Local Rule 3.01(g); Middle District Discovery (2021) at § I.A.2.
9. Discovery Plan
The parties submit the following discovery plan under Rule 26(f)(2):
A.
The parties agree to the timing, form, or requirement for disclosures under
Rule 26(a):
☐ Yes.
☒ No; instead, the parties agree to these changes: contained in the table
above.
B.
Discovery may be needed on these subjects: truth or falsity of the article;
fault; damages and reputation of the plaintiff.
C.
Discovery should be conducted in phases:
☒ No.
☐ Yes; describe the suggested phases.
D. Are there issues about disclosure, discovery, or preservation of
electronically stored information?
☒ No.
☐ Yes; describe the issue(s).
E.
☒ The parties have considered privilege and work-product issues,
including whether to ask the Court to include any agreement in an order
under Federal Rule of Evidence 502(d).
F.
The parties stipulate to changes to the limitations on discovery imposed
under the Federal Rules of Civil Procedure and Local Rule 3.04 or other
limitations: Page 5 PageID
☒ No.
☐ Yes; describe the stipulation.
10. Request for Special Handling
☒ The parties do not request special handling.
☐ The parties request special handling. Specifically, describe requested special
handling.
☐ Enter party’s name unilaterally requests special handling. Specifically, describe
requested special handling.
11. Certification of familiarity with the Local Rules
☒ The parties certify that they have read and are familiar with the Court’s Local
Rules.
12. Signatures
/s/Jesse Binnall
/s/Thomas G. Hentoff
Jesse R. Binnall (pro hac vice)
Shawn Flynn, Fla Bar No Jared J. Roberts, Fla Bar No BINNALL LAW GROUP, PLLC
Dated: 11/20/
Thomas G. Hentoff (pro hac vice)
Nicholas G. Gamse (pro hac vice)
WILLIAMS & CONNOLLY LLP
Jason R. Kobal
KOBAL LAW, P.A.
Linda Riedemann Norbut
Carol J. Locicero
THOMAS & LOCICERO, PL
Counsel for Plaintiff
Counsel for Defendant
Dated: 11/20/
Trump Media & Technology Group Corp.
WP Company LLC
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 8:23-cv-01535-TPB-AAS Document 40 Filed 11/20/23 Page 1 of 5 PageID 386
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
Tampa Division
TRUMP MEDIA & TECHNOLOGY
GROUP CORP.,
Plaintiff,
Case No. 8:23-cv-01535
v.
WP COMPANY LLC,
Defendants.
Uniform Case Management Report
The goal of this case management report is to “secure the just, speedy, and
inexpensive determination of” the action. See Fed. R. Civ. P. 1. Under Local Rule
3.02(a)(2), this case management report should be used in all civil cases except those
described in Local Rule 3.02(d). Individual judges may have additional case
management preferences that can be found under each judge’s name on the Court’s
website, flmd.uscourts.gov/judges/all.
1. Date and Attendees
The parties may conduct the planning conference “in person, by telephone, or by
comparable means[.]” See Local Rule 3.02(a)(1).
The parties conducted the planning conference on 10/9/2023. Shawn Flynn, Jared
Roberts, and Jesse Binnall attended the conference for Plaintiff Trump Media &
Technology Group Corp., and Nick Gamse, Carol LoCicero, Linda Norbut,
Monica Sharma, and Tom Hentoff attended the conference for Defendant WP
Company LLC.
2. Deadlines and Dates
The parties request these deadlines and dates:
Action or Event
Date
Deadline for providing mandatory initial disclosures. See Fed. R. Civ.
P. 26(a)(1).
11/20/2023
PDF Page 3
Case 8:23-cv-01535-TPB-AAS Document 40 Filed 11/20/23 Page 2 of 5 PageID 387
Deadline for moving to join a party, see Fed. R. Civ. P. 14, 19, and 20,
or amend the pleadings, see Fed. R. Civ. P. 15(a).
Deadline for serving expert disclosures under Rule 26(a)(2),
including any report required by Rule 26(a)(2)(B).
12/23/2023
Plaintiff
7/23/2024
Defendant
8/23/2024
Rebuttal
9/23/2024
Deadline for completing discovery and filing any motion to compel
discovery. See Fed. R. Civ. P. 37; Middle District Discovery (2021).
10/23/2024
Deadline for moving for class certification, if applicable. See Fed. R.
Civ. P. 23(c).
Deadline for filing any dispositive and Daubert motion. See Fed. R. Civ.
P. 56. (Must be at least five months before requested trial date.)
Deadline for participating in mediation. See Local Rules, ch. 4.
Enter mediator’s name, address, and phone number.
Enter a date.
11/20/2024
10/23/2024
Date of the final pretrial meeting. See Local Rule 3.06(a).
4/28/2025
Deadline for filing the joint final pretrial statement, any motion in
limine, proposed jury instructions, and verdict form. See Local Rule
3.06(b). (Must be at least seven days before the final pretrial conference.)
5/5/2025
Date of the final pretrial conference. See Fed. R. Civ. P. 16(e); Local
Rule 3.06(b).
5/12/2025
Month and year of the trial term.
June 2025
The trial will last approximately eight (8) days and be
☒ jury.
☐ non-jury.
3. Description of the Action
This is an action brought by Trump Media & Technology Group Corp. seeking
recovery for alleged defamatory statements published by Defendant WP Company
LLC.
2
PDF Page 4
Case 8:23-cv-01535-TPB-AAS Document 40 Filed 11/20/23 Page 3 of 5 PageID 388
4. Disclosure Statement
☒ The parties have filed their disclosure statement as required by Federal Rule of
Civil Procedure 7.1 and Local Rule 3.03.
5. Related Action
☒ The parties acknowledge their continuing duty under Local Rule 1.07(c) to
notify the judge of a related action pending in the Middle District or elsewhere by
filing a “Notice of a Related Action.” No notice need be filed if there are no related
actions as defined by the rule.
Plaintiff will simultaneously file a Notice of a Related Action.
6. Consent to a Magistrate Judge
“A United States magistrate judge in the Middle District can exercise the maximum
authority and perform any duty permitted by the Constitution and other laws of the United
States.” Local Rule 1.02(a). With the parties’ consent, a district judge can refer any civil
matter to a magistrate judge for any or all proceedings, including a non-jury or jury trial.
28 U.S.C. § 636(c).
The Court asks the parties and counsel to consider the benefits to the parties and the Court
of consenting to proceed before a magistrate judge. Consent can provide the parties
certainty and flexibility in scheduling. Consent is voluntary, and a party for any reason
can decide not to consent and continue before the district judge without adverse
consequences. See Fed. R. Civ. P. 73(b)(2).
☐ The parties do consent and file with this case management report a completed
Form AO 85 “Notice, Consent, and Reference of a Civil Action to a Magistrate
Judge,” which is available on the Court’s website under “Forms.”
☒ The parties do not consent.
7. Preliminary Pretrial Conference
☒ The parties do not request a preliminary pretrial conference before the Court
enters a scheduling order.
☐ The parties do request a preliminary pretrial conference, and the parties want to
discuss enter discussion points.
8. Discovery Practice
3
PDF Page 5
Case 8:23-cv-01535-TPB-AAS Document 40 Filed 11/20/23 Page 4 of 5 PageID 389
The parties should read the Middle District Discovery Handbook, available on the Court’s
website at flmd.uscourts.gov/civil-discovery-handbook, to understand discovery practice
in this District.
☒ The parties confirm they will comply with their duty to confer with the opposing
party in a good faith effort to resolve any discovery dispute before filing a motion.
See Local Rule 3.01(g); Middle District Discovery (2021) at § I.A.2.
9. Discovery Plan
The parties submit the following discovery plan under Rule 26(f)(2):
A.
The parties agree to the timing, form, or requirement for disclosures under
Rule 26(a):
☐ Yes.
☒ No; instead, the parties agree to these changes: contained in the table
above.
B.
Discovery may be needed on these subjects: truth or falsity of the article;
fault; damages and reputation of the plaintiff.
C.
Discovery should be conducted in phases:
☒ No.
☐ Yes; describe the suggested phases.
D. Are there issues about disclosure, discovery, or preservation of
electronically stored information?
☒ No.
☐ Yes; describe the issue(s).
E.
☒ The parties have considered privilege and work-product issues,
including whether to ask the Court to include any agreement in an order
under Federal Rule of Evidence 502(d).
F.
The parties stipulate to changes to the limitations on discovery imposed
under the Federal Rules of Civil Procedure and Local Rule 3.04 or other
limitations:
4
PDF Page 6
Case 8:23-cv-01535-TPB-AAS Document 40 Filed 11/20/23 Page 5 of 5 PageID 390
☒ No.
☐ Yes; describe the stipulation.
10. Request for Special Handling
☒ The parties do not request special handling.
☐ The parties request special handling. Specifically, describe requested special
handling.
☐ Enter party’s name unilaterally requests special handling. Specifically, describe
requested special handling.
11. Certification of familiarity with the Local Rules
☒ The parties certify that they have read and are familiar with the Court’s Local
Rules.
12. Signatures
/s/Jesse Binnall
/s/Thomas G. Hentoff
Jesse R. Binnall (pro hac vice)
Shawn Flynn, Fla Bar No 1040911
Jared J. Roberts, Fla Bar No 1036550
BINNALL LAW GROUP, PLLC
Dated: 11/20/2023
Thomas G. Hentoff (pro hac vice)
Nicholas G. Gamse (pro hac vice)
WILLIAMS & CONNOLLY LLP
Jason R. Kobal
KOBAL LAW, P.A.
Linda Riedemann Norbut
Carol J. Locicero
THOMAS & LOCICERO, PL
Counsel for Plaintiff
Counsel for Defendant
Dated: 11/20/2023
Trump Media & Technology Group Corp.
WP Company LLC
5
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