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Filed

D.C. Superior Court


09/29/2016 18:28PM
Clerk of the Court

SUPERIOR COURT OF THE DISTRICT OF COLUMBIA


CIVIL DIVISION
TRUMP OLD POST OFFICE LLC,
Plaintiff,
v.
CZ-NATIONAL, LLC, et al.,
Defendants.

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Case No. 2015 CA 5890 B


Calendar 12
Judge Brian F. Holeman

OMNIBUS ORDER
This matter comes before the Court upon consideration of the following: (1) the Motion
for Leave to Intervene and to Oppose Plaintiff Trump Old Post Office LLCs Motion for
Redactions, filed by BuzzFeed, Inc. (BuzzFeed) on August 15, 2016; (2) the Motion for Leave
to Intervene to Seek Copies of Unsealed Video Filings, filed by BuzzFeed on August 16, 2016;
and (3) the Motion to Intervene, for Access to Judicial Records, and for Expedited
Consideration, filed by the Cable News Network, Inc., WP Company, LLC (The Washington
Post), NBCUniversal Media, LLC (NBC News), MSNBC and the NBC Owned Television
Stations, American Broadcasting Companies, Inc. (ABC), CBS Corporation (CBS News and
CBS Interactive, including CBSN and cbsnews.com), and Los Angeles Times Communications,
LLC (the Los Angeles Times) (collectively the News Media) on August 17, 2016.
I.

PROCEDURAL HISTORY
On August 3, 2015, Plaintiff filed the Complaint. Plaintiff, the landlord, alleges that

Defendant CZ-National, the tenant (hereafter referred to as Tenant), breached obligations


under a sublease (the Sublease) to use certain restaurant space at the Trump International
Hotel, The Old Post Office, Washington, D.C. (Compl. at 1.) Defendant BVS Acquisition Co.
allegedly entered into an agreement with Plaintiff to guarantee all obligations (the Guarantee)

assumed by Tenant under the Sublease. (Compl. at 9.) Tenant is a corporate entity affiliated
with renowned chef Geoffrey Zakarian. (Id. at 8.) Plaintiff alleges that Tenant defaulted and
abandoned its obligations under the Sublease allegedly based on personal offense to statements
by Mr. Trump with respect to illegal immigration during his June 16, 2015 presidential campaign
announcement speech. (Id. at 28.) Mr. Trumps statements at issue are as follows:
When Mexico (meaning the Mexican Government) sends its
people, theyre not sending their best. Theyre not sending you
(pointing to the audience). Theyre not sending you (pointing
again). Theyre sending people that have lots of problems, and
theyre bringing those problems to us. Theyre bringing drugs.
Theyre bringing crime. Theyre rapists. And some, I assume, are
good people! But I speak to border guards and they tell us what
were getting. And it only makes common sense. Theyre sending
us not the right people. Its coming from more than Mexico. Its
coming from all over South and Latin America, and its coming
probably from the Middle East. But we dont know. Because we
have no protection and we have no competence, we dont know
whats happening. And its got to stop and its got to stop fast.
(Defendants Mot. for Partial Summary Judgment Ex. 161 at 1-2.) Plaintiff asserts a claim for
breach of the Sublease against Defendant CZ-National, breach of the Guarantee against
Defendant BVS Acquisition, and claims for attorneys fees against all Defendants. (Compl. at 911.)
On September 16, 2015, Defendants filed the Answer and Counterclaims. Defendants
assert that the Sublease includes, as a matter of law, an implied obligation of good faith and fair
dealing and that Mr. Trumps remarks during his speech on June 16, 2015 were inflammatory
and made it impossible for Tenant to move forward with opening a restaurant [at the Old Post
Office site]. (Ans. and Counterclaims at 60-64.) Defendants allege that the Tenant provided
Plaintiff with a letter of credit in the amount of $461,000.00 (the Letter of Credit) and cash
security in the amount of $29,167.00 as collateral for Tenants performance under the Sublease.

(Id. at 66.) Defendants assert that as a result of Tenants cessation of performance under the
Sublease, Plaintiff withdrew both the Letter of Credit and cash security in violation of the terms
of the Sublease that permitted Plaintiff to draw down on all or part of the Letter of Credit or the
cash security[.] (Id. at 68.) Defendants assert counterclaims for the breach of covenant of
good faith and fair dealing and breach of the letter of credit provisions of the Sublease. (Id. at
71-77.)
On January 21, 2016, the parties filed the proposed Stipulated Protective Order. On
February 10, 2016, the Court entered the Protective Order. The Protective Order protects any
document, testimony, information, or material produced solely concerning trade secrets or
other confidential research, development, or commercial information[.] (Protective Order Feb.
10, 2016 at 1.)
Meanwhile, On January 15, 2016, Plaintiff filed the Motion for Protective Order. The
protective order proposed by Plaintiff, and separate and distinct from the Protective Order
covering trade secret and other proprietary information, requests that the Court quash the Notice
of Deposition1 served upon Donald J. Trump, the President of the corporate Plaintiff.2 On
February 11, 2016, the Court entered the Order denying Plaintiffs Motion for Protective Order
and ruled that Plaintiff SHALL PRODUCE Donald J. Trump, Donald Trump, Jr., and Ivanka

A deposition is the recording of testimony articulated by a witness either (1) upon written questions or (2)
through oral examination, i.e. verbally asking and answering questions. See the Superior Court Rules of Civil
Procedure, Rules 30 and 31. During a deposition, the witness is required to testify under oath and under the penalty
of perjury. Further, the witness may be asked questions by counsel for each party as if that witness is testifying at
trial. See Super. Ct. R. Civ. P. R. 30(c). Deposition testimony must be recorded in writing through a stenographic
record and may also be recorded by video. See id. A deposition may be introduced at trial for the purpose of
contradicting or impeaching a witness, or as substantive evidence, so far as permissible under the Rules of Evidence.
See Super. Ct. R. Civ. P. R. 32(a), (c).
2

At the time of filing of Plaintiffs Motion for Protective Order, Mr. Trump had not yet secured the
nomination of the Republican Party for President of the United States.

Trump for deposition, subject to mutual agreement between the parties as to the order of
witnesses and scheduling. (Order Feb. 11, 2016 at 8 (emphasis in original)).
On May 13, 2016, the parties filed the Joint Motion for Amended Stipulated Protective
Order, which was granted on May 30, 2016. The Amended Protective Order only protects trade
secret and other proprietary information, i.e. confidential or proprietary information regarding
the partys business affairs, finances, technology, processes, plans or installations, product
information, or know-how. (Am. Protective Order May 30, 2016 at 1.)
On July 14, 2016, the parties filed the Consent Motion for Leave to Lengthen Page Limit
and to File Under Seal, which was denied on July 15, 2016. Significantly, that Consent Motion
requests, inter alia, that the Court permit the parties to file their respective dispositive motions
and accompanying exhibits under seal. (Cons. Mot. July 14, 2016 at 1.) The Court ruled, inter
alia, that the parties request to file under seal is denied on grounds of the First Amendment of
the Constitution, finding that [t]he blanket sealing of all motions for summary judgment and
accompanying memoranda of points and authorities filed in a civil action is unprecedented and
impermissible[.] (Order July 15, 2016 at 3 (citing Press-Enterprise Co. v. Superior Court, 478
U.S. 1, 15 (1986) (The First Amendment right of access cannot be overcome by the conclusory
assertion that publicity might deprive the defendant of the [right to a fair trial].))
On July 19, 2016, Plaintiff filed the Motion for Partial Summary Judgment. On that same
day, Defendants filed the Motion for Partial Summary Judgment. On July 26, 2016, the Court
entered the Omnibus Order denying, without prejudice, all pending Motions for Partial Summary
Judgment on grounds of undue withholding and substantially incomplete presentation of
evidence. (See Order July 26, 2016 at 1-6.)

On August 8, 2016, Plaintiff filed the Motion for Redactions. Plaintiff requests, inter
alia, that the Court issue yet another protective order for the purpose of sealing the video
recordings of the depositions of Donald J. Trump and Donald J. Trump, Jr. (See generally Ps
Mot. for Redactions.) On August 11, 2016, the Court entered the Order denying Plaintiffs
Motion for Redactions and request for a protective order sealing the video recordings of the
depositions of Mr. Trump and Mr. Trump, Jr. (See generally Order Aug. 11, 2016.) The Order
of August 11, 2016 rendered moot BuzzFeeds Motion for Leave to Intervene and to Oppose
Plaintiff Trump Old Post Office LLCs Motion for Redactions. On August 12, 2016, the parties
filed their respective Motions for Partial Summary Judgment. In addition, Defendants filed the
Praecipe indicating that disc copies of video recordings were mailed to the Court. (Praecipe
Aug. 12, 2016 at 1.)3
On August 12, 2016, Plaintiff filed the Emergency Motion for Reconsideration and
Renewed Motion for Redactions. That Emergency Motion, however, does not request relief
from this Courts ruling on the discrete issue of sealing video recordings. Instead, that
Emergency Motion requests that this Court redact certain portions of the deposition transcript of
expert witnesses. (See Ps Emergency Mot. at 2 (Plaintiff requests limited redactions of Ray
Flores, Roger Cline, and David Berins.)) The Court denied that Emergency Motion. (See
Order Sept. 27, 2016.)

The two (2) discs submitted to Chambers are identified as follows: Exhibit N CONFIDENTIAL, FULL
SIZE/CONDENSED/PTX, LIVENOTE LEF, EXHIBITS, MPEG VIDEO, Donald J. Trump, June 16, 2016,
Trump Old Post Office, LLC v- National, LLC, et al.; and Exhibit O CONFIDENTIAL, FULL
SIZE/CONDENSED/PTX, LIVENOTE LEF, EXHIBITS, MPEG VIDEO, Donald J. Trump, Jr., June 1, 2016,
Trump Old Post Office, LLC v- National, LLC, et al. Chambers has no video recording of the deposition of
Ivanka Trump.

II.

ANALYSIS
A.

The Medias Standing to Intervene

BuzzFeed and the News Media request leave to intervene in the instant action for the
limited purpose of seeking copies of deposition videos filed with the Court. (BuzzFeeds Mot.
at 1; News Media Mot. at 1.) Under the Superior Court Rules of Civil Procedure, Rule 24(b),
[u]pon timely application anyone may be permitted to intervene in an action: (1) When
applicable law confers a conditional right to intervene[.] This jurisdiction has recognized that
the media has standing to intervene for the limited purpose of seeking access to court records:
[t]he filing of a motion to intervene is simply recognized as an appropriate means of raising
assertions of public rights of access to information regarding matters in litigation. Mokhiber v.
Davis, 537 A.2d 1100, 1104 (D.C. 1988). Here, the instant Motions only concern access to
information in the current record of active civil litigation. (BuzzFeeds Mot. at 1; News Medias
Mot. at 1.) Consequently, the moving media outlets have standing to intervene for the articulated
limited purpose. Mokhiber, 537 A.2d at 1104; Super. Ct. R. Civ. P. R. 24(b).
B.

The Presumptive Right of Access to Judicial Records

The Supreme Court has declared [i]t is clear that the courts of this country recognize a
general right to inspect and copy public records and documents, including judicial records and
documents. Nixon v. Warner Communications, Inc., 435 U.S. 589, 597 (1978) (footnotes
omitted.) This jurisdiction recognizes federal authority affirm[ing] a presumptive right of
access to a broad range of court records in civil cases. Mokhiber, 537 A.2d at 1107 (citing, e.g.,
Publicker Industries, Inc. v. Cohen, 733 F.2d 1059, 1066-71 (3d Cir. 1984); In re Continental
Illinois Securities Litigation, 732 F.2d 1302, 1308-09 (7th Cir. 1984)) (citations omitted).

Although the items at issue, video recordings, were not filed into the current record in a
form accessible to the public, these video recordings are judicial records. See Mokhiber, 537
A.2d at 1111; see also Valley Broadcasting Co. v. United States Dist. Court, 798 F.2d 1289,
1295 (9th Cir. 1986) (discussing audio and video tapes); United States v. Graham, 257 F.3d 143,
151 (2d Cir. 2001) (treating video tapes played during a hearing, but not entered into evidence,
as judicial records). While the media may have a presumptive right of access to judicial
records, this right is not absolute: the District of Columbia Court of Appeals has determined that
the presumptive public right of access to pretrial court records in civil litigation is derived
from the common law rather than the Constitution.4 Mokhiber, 537 A.2d at 1108; Compare In re
Washington Post Co., 807 F.2d 383, 390 (4th Cir. 1986) (holding that the right to access records
in a criminal proceeding is derived from the First Amendment). Consequently, [t]he major
difference [in] viewing the right of access as a common law, not constitutional, guarantee
appears to be that a common law right is more easily overcome by reasons favoring secrecy.
Mokhiber, 537 A.2d at 1108 (footnote and citations omitted).

The Court of Appeals explained the rationale for choosing the common law as the source of authority:
In most cases, there may be little difference between a common law and
constitutional right of access. Both ensure a presumption of access and permit a
court to bar disclosure only when the specific interests favoring secrecy
outweigh the general and specific interests favoring disclosure. However, the
constitutional standard invokes the traditional first amendment test: that the
reasons militating against disclosure must amount to compelling state interests
before they may outweigh the right of access, and, further, that courts must
resort to the means least restrictive of access. A constitutional analysis thus tilts
the scale strongly in favor of the single interest of public access as against
opposing interests that are also important in their own right. Furthermore, the
constitutionalization of the right to pretrial records could freeze the law in this
area of only recent first amendment development beyond the reach of
modification by either legislative act or court rule.

Mokhiber, 537 A.2d at 1108.

The dispositive consideration articulated by the Court of Appeals is whether the judicial
records at issue were made part of the public record. See id. at 1109 (There is no
independent right of access by nonparties to materials produced in discovery and not made part
of the public record.) (citations omitted.) Applying this consideration in Mokhiber, the Court
of Appeals denied the medias request for access to documents produced in discovery that were
(1) never submitted to the court in connection with pleadings, (2) filed under seal, and (3) filed
in a closed civil action where the litigants agreed upon settlement several years prior to the
medias request for access. Id. at 1104, 1117.
Here, Mokhiber is factually distinguishable. The video recordings at issue are filed (1)
into the current record in connection with dispositive motions, (2) without seal, and (3) in an
active civil case. Compare id. Consequently, the question remains whether this Court has any
obligation to provide the media access to judicial records made public, but not in a readily
accessible form.5
C.

Access to Video Recordings


1.

The Applicable Standard

One of the leading cases addressing the discrete issue presented comes from the United
States Court of Appeals for the Ninth Circuit (the Ninth Circuit). In Valley Broadcasting Co.,

The discrete issue presented distinguishes the matters before this Court from the matters adjudicated by the
United States District Court for the Southern District of California in Low, et al. v. Trump University, LLC, et al.,
No. 3:10-cv-0940 (S.D. Cal. 2016). In Low, the court denied the medias request to release video recordings on
grounds that the defense demonstrated good cause to maintain the video recordings under seal. See Order, Low, No.
3:10-cv-0940 at 15 (S.D. Cal. Aug. 2, 2016). Here, this Court denied Plaintiffs request to maintain the video
recordings under seal on grounds of absence of good cause. (Order Aug. 11, 2016 at 11-23.) The question of
sealing the video recordings is a threshold matter previously addressed by this Court, and is consequently not at
issue for the purpose of adjudicating the instant Motions. (See id.)
In any event, precedent from any federal district court or court of appeals is persuasive, not controlling,
authority. See M.A.P. v. Ryan, 285 A.2d 310, 312 (D.C. 1971) (stating as of February 1, 1971, [the] highest court
of the District of Columbia is the District of Columbia Court of Appeals and the courts of this jurisdiction are not
bound by the decisions of the United States Court of Appeals rendered after that date nor decisions rendered by the
United States District Court).

the Ninth Circuit analyzed whether the publics common law right to copy and inspect public
records and documents includes the right to copy audio and videotape exhibits[.] Id., supra,
798 F.2d at 1290. The Ninth Circuit discussed the viewpoints of various federal courts on this
discrete issue, noting that [t]wo circuits have adopted tests that contain built-in biases for or
against disclosure. See id. at 1293 (citing United States v. Myers (In re National Broadcasting
Co.), 635 F.2d 945, 952 (2d Cir. 1980) (only the most compelling circumstances should
prevent contemporaneous public access to [reproducible evidentiary materials introduced in a
criminal trial]) (footnote omitted); Belo Broadcasting Corp. v. Clark, 654 F.2d 423, 431 (5th
Cir. 1981) (adopting a general balancing test that characterizes the public's right of access as
typically subordinate to a defendant's competing fair trial rights.))
The Ninth Circuit adopted the middle-ground stance -- preferred by three of the circuits
that have ruled on applications to reproduce taped evidence for subsequent broadcast, which
requires that the trial court start with a strong presumption in favor of access, to be overcome
only on the basis of articulable facts known to the court, not on the basis of unsupported
hypothesis or conjecture. Valley Broadcasting Co., 798 F.2d at 1293 (citing United States v.
Edwards (In re Video-Indiana, Inc.), 672 F.2d 1289, 1294 (7th Cir. 1982); In re National
Broadcasting Co., 653 F.2d 609, 613 (D.C. Cir. 1981) (courts should deny access only if justice
so requires); United States v. Criden (In re National Broadcasting Co.), 648 F.2d 814, 823 (3d
Cir. 1981)) (quotation omitted). 6

This trilogy of case authority cited by the Ninth Circuit involves video recordings entered into the record of
criminal proceedings with the same factual scenario: an elected official charged on counts of corruption and bribery.
See Edwards, 672 F.2d at 1290 (state legislative official indicted on charges relating to unlawful payments of
money in exchange for influence legislation); In re National Broadcasting Co., 653 F.2d at 610-11 (members of
Congress charged with corruption arising from the notorious ABSCAM sting operation initiated by the Federal
Bureau of Investigation); Criden, 648 A.2d at 816 (another criminal proceeding arising from the ABSCAM sting
operation).

This Court finds the approach adopted by the Ninth Circuit and the majority of the
federal circuits persuasive. The Ninth Circuit, recognizing that a majority of federal circuits
strike[] a balance that accommodates both the presumption to which the common law right of
access is entitled and the limitations that may properly be placed upon it, states that the trial
court must weigh the interests advanced by the parties in light of the public interest and the
duty of the courts. Valley Broadcasting Co., 798 F.2d at 1294 (citing Warner
Communications, 435 U.S. at 602). The Ninth Circuit identifies numerous factors to be
considered, including the need to promot[e] the publics understanding of the judicial process
and of significant public events that justify creating a strong presumption in favor of copying
access weighed against the likelihood of an improper use, including publication of
scandalous, libelous, pornographic, or trade secret materials[.] Id. at 1294 (citing Criden, 648
F.2d at 830 (Weis, J., concurring)) (footnote omitted).
2.

The Presumption of Access

This Court must weigh the interests of the public, represented by BuzzFeed and the News
Media and in favor of access, against the interests of Plaintiff, representing the interests of Mr.
Trump and against public access.
The possibility that excerpts of the video recordings may be used in so-called negative
attack ads in an election campaign is inherently speculative. If the video recordings actually
contained scandalous [or] libelous material, testimony concerning indiscreet personal conduct,
or material unduly prejudicing the privacy interests of a third party, that content might justify
denial of media access. See Valley Broadcasting Co., 798 F.2d at 1293; see also In re
Application of KTSP Television, 504 F. Supp. 360, 364 (D. Minn. 1980) (denying the medias
request for access to video recordings of a sexual assault on grounds of the privacy interests of

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the victim). However, as evidenced by Plaintiffs own arguments in the Motion for Redactions,
the only testimony provided by Mr. Trump that was of concern to Plaintiff was a statement
regarding a settlement with Univision that is confidential. (Ps Mot. for Redactions Ex. A at
2.) During his deposition, Mr. Trump testified that [w]ith Univision, I had a signed contract
and they went to court, and they [Univision] paid a substantial amount of money to me.
(Donald J. Trump Tr., June 16, 2016 at 58:2-4.)
Any testimony regarding a purported settlement in a separate and unrelated case is
neither relevant nor unduly prejudicial as applied to the instant action. Further, this Court is not
aware of, and there has not been any reason for this Court to inquire into, any settlement in prior
litigation involving Mr. Trump and Univision. Still further, any asserted privilege based upon
agreed confidentiality of a settlement is arguably waived where a party volunteers the
purportedly privileged information, which is the factual scenario that occurred at Mr. Trumps
deposition. (See Donald J. Trump Tr. at 57:20-58:4 (a partially non-responsive answer
discussing, inter alia, Mr. Trumps relationship with Macys)); see also Tsintolas Realty Co. v.
Mendez, 984 A.2d 181, 186 (D.C. 2009) (finding that a tenant did not violate the confidentiality
provision of a settlement agreement with a landlord because the landlord tacitly consented to
waiver of confidentiality: for several months, so far as the record shows, [the landlord] took no
action to prevent the agreement from becoming, and remaining, a part of the case jacket.)
In any event, this Court finds that Plaintiff has not demonstrated that any subject video
deposition contains scandalous, libelous, or other unduly prejudicial material warranting denial
of media access. Notably, Plaintiff represents that it seeks no redactions of any portions of the
deposition of Donald Trump, Jr., which is the second of three (3) video depositions comprising
the current record. (Ps Mot. for Redactions at 1 (emphasis added.)) The public shall not be held

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captive by the suggested eventuality of partisan editing in a manner unfavorable to Plaintiff or


the deponents. See Vasquez v. City of New York, 2014 U.S. Dist. LEXIS 61451 3-4 (S.D.N.Y.
2014) (finding that the mere fact that the media may edit [the] tape . . . does not warrant a
protective order barring all public dissemination) (citing Condit v. Dunne, 225 F.R.D. 113, 118
(S.D.N.Y. 2004)). At this juncture, Plaintiff and the deponents are only able to imply future
harm, based on hypothesis or conjecture, insufficient to defeat the strong presumption in
favor of access[.] Valley Broadcasting Co., 798 F.2d at 1293 (citations omitted).
Finally, the fact that this case is set for a bench trial, instead of a jury trial, distinguishes
the instant action from those where courts denied media access to video records on grounds of
potential juror taint. In Clark, the United States Court of Appeals for the Fifth Circuit affirmed
the trial courts denial of the medias request for access to videotapes on grounds that release
would severely prejudice [the defendants] right to a fair trial and would severely hamper [the
court] in selecting a fair and impartial jury in the forthcoming trial. Clark, supra, 654 F.2d at
425 (emphasis added). Similarly, in Low, the court denied the medias request because a
realistic appraisal of the context of the case necessitates the conclusion that releasing the
deposition videos would impair judicial efficiency by increasing the likelihood that prospective
jurors would be exposed to information about the case[.] Low, supra note 4, at 8, Order, Aug.
2, 2016, at 16 (emphasis added). Here, in the absence of a jury trial, any concerns of undue
prejudice arising from selection of jurors are baseless. See also Valley Broadcasting Co., 798
F.2d at 1295 ([w]hile we [the Ninth Circuit] recognize that the added danger of jury taint arising
from the transmission of the tapes themselves may vary from case to case, we reemphasize that
the district court must articulate the factual basis for the danger without relying on hypothesis or
conjecture.)

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3.

Administrative Process

In exercising its discretion, this Court shall impose certain procedures to ensure the
orderly distribution of the video recordings at issue. See Valley Broadcasting Co., 798 F.2d at
1295 (stating that administrative considerations rest in the sound discretion of the [trial] court)
(citing Warner Communications, 435 U.S. at 599). In addition, the News Medias request for
access to any future video recording is premature and speculative; such request must be made
upon the existence of a ripe controversy that may be adjudicated by this Court. (See News
Media Mot. at 7.)
WHEREFORE, it is this 29th day of September 2016, hereby
ORDERED, that the Motion for Leave to Intervene and to Oppose Plaintiff Trump Old
Post Office LLCs Motion for Redactions, filed by BuzzFeed, Inc., is DENIED AS MOOT; and
it is further
ORDERED, that the Motion for Leave to Intervene to Seek Copies of Unsealed Video
Filings, filed by BuzzFeed, Inc., is GRANTED; and it is further
ORDERED, that the Motion to Intervene, for Access to Judicial Records, and for
Expedited Consideration, filed by the Cable News Network, Inc., WP Company, LLC (The
Washington Post), NBCUniversal Media, LLC (NBC News), MSNBC and the NBC Owned
Television Stations, American Broadcasting Companies, Inc. (ABC), CBS Corporation (CBS
News and CBS Interactive, including CBSN and cbsnews.com), and Los Angeles Times
Communications, LLC (the Los Angeles Times) is GRANTED; and it is further
ORDERED, that only the parties and the Intervenors shall contact Chambers for further
instruction on distribution of the subject video recordings. All parties shall communicate with

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the Court solely through counsel of record; the Court shall not respond to any
communication from any other individuals.

_______________________________
BRIAN F. HOLEMAN
JUDGE
Copies e-served to:
Rebecca Woods, Esquire
Seyfarth Shaw LLP
975 F Street, N.W.
Washington, D.C. 20004
Counsel for Plaintiff
Deborah B. Baum, Esquire
Alvin Dunn, Esquire
Adya S. Baker, Esquire
Pillsbury Winthrop Shaw Pittman LLP
1200 17th Street, N.W.
Washington, D.C. 20036
Counsel for Defendants
Chad R. Bowman, Esquire
Shaina Jones Ward, Esquire
Levine Sullivan Koch & Schulz LLP
1899 L Street, NW, Suite 200
Washington, DC 20036
Counsel for Intervenor BuzzFeed, Inc.
Charles D. Tobin, Esquire
Christine N. Walz, Esquire
Holland & Knight LLP
800 17th Street, NW, Suite 1100
Washington, DC 20006
Counsel for Intervenors Cable News Network, Inc.,
WP Company, LLC (The Washington Post),
NBCUniversal Media, LLC (NBC News),
MSNBC and the NBC Owned Television Stations,
American Broadcasting Companies, Inc. (ABC),
CBS Corporation (CBS News and CBS Interactive,
including CBSN and cbsnews.com), and Los Angeles
Times Communications, LLC (the Los Angeles Times)

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