Liz Dye

@lizdye

Host of the Law&Chaos podcast and newsletter at lawandchaospod.com Make words do yoga Above the Law, Public Notice, Legal Eagle Charm City forever She/Her

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Liz Dye@lizdye· 10d

Good morning to Judge Brinkema and Judge Williams

Liz Dye@lizdye· 16d

I took it to mean that they knew they were going to lose on the argument that combining two of the five major movie studios would not decrease consumer choice because, uh, maybe Amazon and Netflix will pick up the slack.

The strategy behind the delay
Friday’s agreement means there will no longer be an August 3 hearing on the states’ request for a preliminary injunction, and it withdraws the Writers Guild’s similar motion.

Why? Because lawyers for Paramount reached the conclusion that the plaintiffs would likely prevail at the preliminary injunction stage, an executive involved in the matter told CNN. If that happened, the judge would implement a months-long delay anyway, and the court’s findings would weigh heavily at trial.

Thus, the source said, Paramount believes it’s better for the company to skip the injunction stage and seek a speedy trial. (At one point yesterday, I wrote “jury trial,” but this will actually be a bench trial before Judge Araceli Martínez-Olguín. My apologies for the misstep.)

The lawyers now have to work out timing for a trial. Schedule proposals are due next Friday.

Paramount chief legal officer Makan Delrahim told Deadline’s Ted Johnson that the company will seek a November trial date. California AG Rob Bonta told CNN’s Jake Tapper that “we are likely to make a request to have trial in 2027, which is very appropriate based on the expert discovery that needs to happen… before a trial can and should go forward.”

Either way, as a practical matter, the delay means that Paramount will not take control of CNN before the US midterm elections.

And it means that the “ticking fee” — about $7 million per day — will take effect, starting in October, making the Warner deal even more expensive. If the merger is eventually allowed to happen, the layoffs and other cost-cutting measures will be even more extensive as a result.

“Paramount also faces a $7-billion breakup penalty if the blockbuster deal ultimately falls apart,” the LAT’s Meg James noted.

Liz Dye@lizdye· 27d

Yes, it is I, Stalin. Back from the dead to starve the comment section. (Or not? I have no idea what this is in reference to.)

Substack comment: Informative that you locked off comments. That kind of makes you “stalinist” Don’t you think, or don’t you think?

Liz Dye@lizdye· 27d

Epshteyn is supposedly the one who negotiated the law firm surrender deals. ABA subpoenaed him. DOJ says that ABA can't depose Epshteyn, they have to depose the law firms.

Here, Plaintiff seeks information directly related to presidential action, Executive Orders, and
settlement discussions. One of its requests to the third party relates to communications he may have
had with certain law firms. See RFP 1 (seeking records of the third party’s communications with 14
law firms). Plaintiff has not deposed these law firms or requested documents from them, even though
the ABA characterizes itself as the “largest voluntary association of legal professionals.” Compl. ¶ 23.
If these 14 firms are members of the ABA, which they do appear to be, the Association can simply
ask them for these records, and if they are not, the ABA can send subpoenas to the law firms. That
is not only preferable to attempting to violate both the presidential communications privilege and the
attorney-client privilege as a close presidential adviser and attorney, but also is a required step before
even attempting such action. The ABA’s preference to take the third party’s deposition early in this
case, going so far as to send subpoenas before the district court had even entered a scheduling order,
cannot overcome its obligation to seek discovery from persons other than those whom Plaintiffs
believe to be a presidential adviser. Upon exhausting alternative sources of information, the ABA
would then need to demonstrate the third party possessed non-privileged, relevant information that it
could not obtain anywhere else, which they cannot do.

Liz Dye@lizdye· 27d

DAMMIT. I looked at the ABA docket. This is going to end up being a redux of some of the dumbest arguments about presidential privilege from Trump 1. storage.courtlistener.com/recap/gov.us...

invade the privileges afforded to the President of the United States.1
On June 16, 2025, Plaintiff the
American Bar Association (“ABA”) brought suit against EOP, the United States, and 29 agencies and
their agency heads, improperly seeking to prospectively prevent the issuance or implementation of
future Executive Orders against ABA members. See Am. Bar Ass’n v. Exec. Off. of the President, Civ. A.
No. 25-1888 (AHA) (D.D.C.). Before the district court even entered a discovery scheduling order,
Plaintiff rushed to issue subpoenas to a third party who Plaintiff believes and knows provided the
President with privileged and confidential advice in connection with the Executive Orders at issue.
Plaintiff cannot be permitted to end-run around sacrosanct privileges by seeking the same type of
documents and testimony from a third party that it would be barred from seeking directly from the
President and the EOP.
2
The President cannot be compelled to divulge even the identity of any individual from whom
he receives confidential advice. Accordingly, for purposes of this Motion, Defendants can neither
confirm nor deny whether the President even received advice from any third party regarding the
Executive Orders. Even without making that disclosure, it is clear from the face of the subpoenas
that Plaintiff is seeking documents and information that would necessarily implicate the presidential
communications privilege to the extent such documents and information exist. Further, if there were

Liz Dye@lizdye· Jul 9

The people's pro shop

Truth Social Post from Donald Trump: The newly revamped West Wing of the White House, including signage and renovated walls, maple trees, and plantings! President DONALD J. TRUMP
Image of West Wing door with tacky gold sign saying "The West Wing"

Liz Dye@lizdye· Jul 9

No admin stay for you! Pay up, asshole. storage.courtlistener.com/recap/gov.us...

UNITED STATES COURT OF APPEALS
FOR THE
SECOND CIRCUIT
At a Stated Term of the United States Court of Appeals for the Second Circuit, held at the
Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the
8th day of July, two thousand twenty-six.
Before: Eunice C. Lee,
Circuit Judge.
________________________________
E. Jean Carroll,
Plaintiff - Appellee,
v.
Donald Trump,
Defendant - Appellant.
ORDER
Docket No. 26-1840
________________________________
Appellant moves for an immediate administrative stay of the district court’s July 8, 2026
order authorizing disbursement of deposited funds held in the court’s registry, while the Court
considers Appellant’s forthcoming motion for a stay pending appeal.
IT IS HEREBY ORDERED that the motion for an administrative stay is DENIED. See
Nken v. Holder, 556 U.S. 418, 433–36 (2009) (discussing stay factors).
For the Court:
Catherine O’Hagan Wolfe,
Clerk of Court

Liz Dye@lizdye· Jul 9

Wow that was fast

Fundraising text at 9:39pm: I’m all in to defeat Susan Collins in Maine.

Troy Jackson here — fifth-generation logger and former Maine Senate President. Flipping Maine’s U.S. Senate seat is non-negotiable this November, and I’m the right person to get it done.

There is a powerful movement of working class people in the state of Maine, and millions more across America who are ready to send a progressive fighter to the Senate. I’ve been fighting for that movement my whole life — and I’m sure as hell not backing down now, when this fight is needed most.

We can still take our progressive vision to Washington. We can pass Medicare for All, we can take on greedy corporations, we can hold the powerful accountable, and we can unseat Susan Collins once and for all — together.

If you’re with me, I need your support right now. Please rush a contribution today: https://secure.actblue.com/donate/tj-sms-ga?refcode=tj-txt-20260708-v1-b3&refcode2w=qHkFl8

Thank you, from the bottom of my heart.

Stop to Quit

Liz Dye@lizdye· Jul 8

Appealing a disbursement order ... man, have some self respect! This is the kind of amazing lawyering you'd expect from Alina Habba's junior partner. storage.courtlistener.com/recap/gov.us...

NOTICE OF APPEAL
Defendant President Donald J. Trump hereby appeals to the United States Court of Appeals
for the Second Circuit from the Order entered in this action on July 8, 2026 (Doc. 241) by the
Honorable Lewis A. Kaplan, granting disbursement of funds held in the Court’s Registry
Investment System (“CRIS”), and from all adverse orders and rulings that merge with the abovereferenced Order.
Dated: July 8, 2026 Respectfully submitted,
New York, New York

Liz Dye@lizdye· Jul 8

Pay the lady! E Jean Carroll gets the $5 million plus interest from her first courtroom win against Trump in 2023 storage.courtlistener.com/recap/gov.us...

ORDER DIRECTING DISBURSEMENT OF DEPOSITED FUNDS FROM THE REGISTRY OF THE COURT
WHEREAS, on May 11, 2023, the Court entered a Judgment against Donald J. Trump in the total
amount of $5,000,000.00 in favor of Plaintiff E. Jean Carroll (the "Judgment").
WHEREAS, on June 23, 2023, the Court so ordered a Stipulation and Order Regarding the Use
of a Cash Deposit in Court as a Security in Lieu of a Supersedeas Bond, which authorized Tacopina, Seigel
& DeOreo ("TSD"), on behalf of Defendant, to make a cash deposit into the registry of the Court in the
sum of $5,550,000.00 pursuant to Federal Rule of Civil Procedure 67(a). ECF No. 210 (the "Stipulation
and Order")
WHEREAS, the Stipulation and Order provided that "[t]he Clerk shall deduct from the income
on the investment a fee consistent with that authorized by the Judicial Conference of the United States and
set by the Director of the Administrative Office, see Local Civil Rule 67.1(b)(2)." ECF No. 210 9 7.
WHEREAS, the Stipulation and Order provided that "[a]fter the latest of (a) the mandate issued
by the Second Circuit in connection with the Appeal; (b) a denial of a timely filed petition for writ of
certiorari to the Supreme Court (if any) in connection with the Appeal; or (c) upon the Supreme Court's
granting of certiorari, an order of the Supreme Court in connection with the Appeal, Plaintiff may collect
any moneys owed by Defendant to Plaintiff under the terms of the Judgment, as may be modified on appeal

Liz Dye@lizdye· Jul 8

Always so funny to see Trump talk about whichever judge gave him a minor win in glowing terms. When he initially filed this dumb defamation suit against the NYT, Judge Merryday yeeted it into the sun sua sponte for standing “unmistakably and inexcusably athwart the requirements of Rule 8.”

Trump Truth Social Post 7/7/26: BREAKING NEWS: A very fair and highly respected Judge in the Middle District of Florida just denied The Failing New York Times’ desperate attempt, together with other defendants we are suing, to move our powerhouse Defamation Lawsuit against them to another jurisdiction. We will now have an oral argument in Florida, where our lawyers will present, in great detail, all the ways in which The Times publishes, promotes, and deals in Fake News. Thank you for your attention to this matter! President DONALD J. TRUMP

Liz Dye@lizdye· Jul 1

These pasty wankers are out here trying to incite a riot in Baltimore

Tweet from official white house account showing Ben Franklin, John Adams, and Thomas jefferson with the caption "what so proudly we hailed at the twilight's last gleaming"

Liz Dye@lizdye· Jun 30

"No longer retains vitality." Stare decisis is cool, bro, but have you tried VIBES? www.supremecourt.gov/opinions/25p...

is no longer good law (or should be overruled). They point
to: the significant changes in this Court’s First Amendment
campaign finance jurisprudence since 2001; the
enhancements in the other tools available to the
Government to prevent circumvention of the contribution
limits, especially earmarking and disclosure laws; and the
diminished relative power of political parties as compared
to outside groups over the last 25 years, which has
undermined a key premise of Colorado II. See McCutcheon
v. Federal Election Comm’n, 572 U. S. 185 (2014); Federal
Election Comm’n v. Ted Cruz for Senate, 596 U. S. 289
(2022); see also SpeechNow.org v. Federal Election Comm’n,
599 F. 3d 686 (CADC 2010) (en banc).
In light of the doctrinal and factual changes since 2001,
the United States agrees with plaintiffs that Colorado II no
longer retains vitality. So the Government does not defend
the constitutionality of the political-party coordinated-

Liz Dye@lizdye· Jun 29

Oh no! Here is the hotel pool next door that is totally normal during the day.

Liz Dye@lizdye· Jun 23

It's a damn shame Democrats can't get hunky sexpots like, uh, Ken Paxton and Mike Collins on our ticket. Ladies, control yourselves!

Isn’t it strange, the Dumocrats are running a man in Texas who looks virtually identical to Alfred E. Neuman, of MAD Magazine fame and, in Georgia, they’re running someone who looks like a twin to the Late, Great, Pee-wee Herman. With these two horrible Political Candidates, I don’t know if there’s a genetic tree, but it certainly is close! What do you think? In any event, Mike Collins, of Georgia, should easily beat Pee-wee, and Ken Paxton, of Texas, should easily beat Alfred E. Vote Republican and, MAKE AMERICA GREAT AGAIN! President DONALD J. TRUMP
Image: Alfred E Neuman next to Talarico with blacked out tooth, Pee-wee Herman next to John Ossoff

Liz Dye@lizdye· Jun 22

Meanwhile on the sewer site ...

Official White House tweet:
The White House
@WhiteHouse
︎︎White House will be Q posting today…

Liz Dye@lizdye· Jun 16

You can tell the prosecutors are real proud of their work, since they redacted their own signature line

OUNT EIGHT Assault on a Federal Officer (Violation of 18 U.S.C. § 111()(1)
276) On or about May 18. 2026, in the District of Minnesota and elsewhere, the
defendant, NATASHA RAKOTZ, forcibly assaulted, resisted, opposed. impeded.
intimidated, and interfered with an officer or employee of the United States or of an
agency in a branch of the United States Government, designated in 18 US.C. § 1114,
who was engaged in the performance of official duties, and caused physical contact and
inflicted bodily injury, and used a dangerous weapon, specifically, a vehicle, in violation
of Title 18, United States Code. Section 111(a)(1) and (b).
A TRUE BILL
UNITED STATES ATTORNEY FOREPERSON

Liz Dye@lizdye· Jun 16

LOL, this fucking guy is trying to make the ICE and CBP thugs into sympathetic victims.

bald white dude with trim white mustache and beard, navy suit, white shirt, giant flag pin, caption Michael McCarthy Homeland Security investigations special agent in charge

Liz Dye@lizdye· Jun 12

In her opposition, Rep. Beatty notes that "These forfeited arguments, which are meritless, are obviously no basis for a stay pending appeal." storage.courtlistener.com/recap/gov.us...

Appellee notes that the introduction to the stay motion—which is three pages long,
without any paragraph breaks—appears to contain arguments never before raised in
the district court, for example regarding the “Bylaws of The Trump Kennedy Center
for the Performing Arts Foundation.” Mot. at 2. These forfeited arguments, which
are meritless, are obviously no basis for a stay pending appeal. To the extent the
motion raises any preserved arguments, they are meritless, as our forthcoming
response will detail.

Liz Dye@lizdye· Jun 12

The Board asks that the DC Circuit rule by 7pm, which is pretty ballsy for a filing at 4pm on a Friday. Particularly when the order you want stayed was issued FOURTEEN days ago.

resolution of this motion, and ask the Court to rule on that request no later than
7 PM. Without the name, “Trump” on the Building, our fundraising will not
only come to a halt, but any and all monies raised or committed would be
obligated to be returned, refunded, or terminated. The Bylaws of The Trump
Kennedy Center for the Performing Arts Foundation state, unequivocally: “The
Corporation may make donations to the Center in support of its educational,
artistic, cultural, and performing arts functions; provided, however, that in so
doing, the Board of Directors shall condition such donations to the Center upon

Liz Dye@lizdye· Jun 12

They call Rep. Beatty "a troublemaking appointment, from the beginning of her tenure!" Guess they persuaded Trump they couldn't go with "low IQ individual" in a legal filing.

In December 2025, the Center’s Board voted overwhelmingly to add
President Trump’s name to the Center in recognition of his personal
commitment to rebuild and revitalize the Center—which had fallen into a sad
state of dangerous disrepair—so it can once again serve as a world-class
performing arts center. In this action, however, one of the Board’s ex officio
trustees, Rep. Joyce Beatty (D-OH, a troublemaking appointment, from the
beginning of her tenure!), sued her fellow trustees of the Board alleging, among
other things, that this resolution and its implementation constituted a breach of
fiduciary duty under the Center’s organic legislation. In actuality, it represented
a saving of The Kennedy Center which, if this doesn’t happen, would go into
financial and structural collapse, something the Board recognized in approving
the name change. Despite all of this, the district court, however, ruled against
the Board, and granted a permanent injunction, requiring the Center to revert to
its prior name—and make all necessary adjustments to its physical signage,
website, and more—by today, June 12, 2026. Again, millions of dollars is
necessary to be raised, and this movement would come to a halt.

Liz Dye@lizdye· Jun 12

The Kennedy Center board has filed an emergency motion to stay at the DC Circuit and it is bonkity-bonkers. For the first time, they say they amended the bylaws to strip all funding from the center if it removes Trump's name. No Trump KC, no money. storage.courtlistener.com/recap/gov.us...

Liz Dye@lizdye· Jun 12

And there it is. Judge Cooper denies the Kennedy Center's request to stay his order taking Trump's name off the building. Let the chiseling begin! www.courtlistener.com/docket/72069...

MINUTE ORDER: Defendants' 55 Motion for a Stay of Permanent Injunction Pending Appeal is hereby DENIED. "A stay pending appeal is an extraordinary remedy" and may only be granted if the traditional stay factors are satisfied. KalshiEX LLC v. CFTC, 119 F.4th 58, 63 (D.C. Cir. 2024) (cleaned up). Defendants have not carried their burden to establish that a stay of the Court's May 29, 2026 permanent injunction concerning the Kennedy Center's renaming is warranted pending an appeal of the underlying ruling to the D.C. Circuit. Most notably, for the detailed reasons laid out in the Court's ruling, Defendants have not "made a strong showing that [they] are likely to succeed on the merits" of any appeal. Nken v. Holder, 556 U.S. 418, 426 (2009) (quoting Hilton v. Braunskill, 481 U.S. 770, 776 (1987)). Nor have Defendants demonstrated that they "will be irreparably injured absent a stay," id. (quoting Hilton, 481 U.S. at 776), given both the de minimis resources that would be required to restore the Center's current name in the event of a successful appeal and the lack of record evidence linking increased donations to the current name. Further, Defendants have apparently taken substantial steps toward complying with the Court's May 29 permanent injunction order on renaming. See Mot. for Misc. Relief, ECF No. 51, Ex. A (June 4, 2026 memorandum from the Kennedy Center's Office of General Counsel directing staff to comply with the Court's permanent injunction on renaming). These efforts undermine the notion that Defendants face irreparable harm in complying with the order in full. The failure to demonstrate irreparable harm is "fatal" to a movant's stay request, KalshiEx, 119 F.4th at 64, as is the failure to show a likelihood of success on the merits. What's more, issuance of a stay pending appeal would not be in the public interest, which is rarely served by the "perpetuation" of "unlawful" governmental action. League of Women Voters of the U.S. v. Newby, 838 F.3d 1, 12 (D.C…

Liz Dye@lizdye· Jun 12

Tried to steal a bequest

71. Finally, the Kennedy Center’s conduct threatens lasting reputational and
institutional harm to WNO. Before the disaffiliation in January 2026, the Kennedy Center
controlled WNO’s gift-processing operations, and its inadequate staffing and administrative lapses
damaged donor trust. For example, one donor’s intended $50,000 credit-card contribution was
never processed by the Kennedy Center’s staff responsible for such gift processing. Expecting a
substantial charitable gift to be handled promptly and professionally, the donor withdrew the gift,
and WNO lost both the contribution and the valuable donor relationship. After the January 2026
separation, the strain on donor trust took a different form. WNO can now process and acknowledge
new gifts made directly to WNO, but donors have raised questions about whether past
contributions and bequests entrusted to the Kennedy Center for WNO will continue to support
WNO’s mission. WNO’s ability to raise future funds hinges on its ability to assure donors that
funds given for WNO will be honored, protected, and used for WNO’s benefit. The Kennedy

Liz Dye@lizdye· Jun 12

Stopped processing gifts, pissing off donors

Liz Dye@lizdye· Jun 12

Locked them out of the entire development back end

Liz Dye@lizdye· Jun 12

Washington Nat'l Opera sues the Kennedy Center alleging that the Center STOLE the opera's endowment. WNO had a longterm agreement where KC ran the opera's development back office, and in 2025 KC just ... stopped doing it and seized the funds. storage.courtlistener.com/recap/gov.us...

49. On January 8, the Kennedy Center’s Chief Financial Officer sent an email to
WNO’s General Director and Board President asserting for the first time and, contrary to the terms
of the 2024 Agreement, that the funds in the WNO BSRF belonged to the Kennedy Center. In
addition, the CFO disclosed that the Kennedy Center had used those funds—funds that the 2024
Agreement expressly required to be held for the long-term benefit of WNO—to collateralize the
Kennedy Center’s own line of credit.
50. The next day, on January 9, 2026, the WNO Board voted to terminate the 2024
Agreement. WNO’s Board President and Board Chair immediately notified the Kennedy Center
of that decision in a letter to Mr. Grenell and requested that the parties begin unwinding the
affiliation.

Liz Dye@lizdye· Jun 11

Lolll, I just realized what Trump's lawyer Alejandro Brito did to get smacked again. He refused to meet and confer with BBC counsel because it would be acknowledging the Magistrate's authority to supervise discovery after he moved to recuse her. 🤦‍♀️ storage.courtlistener.com/recap/gov.us...

LOCAL RULE 7.1(a) CERTIFICATION
Pursuant to Local Rule 7.1(a), I hereby certify that Defendants have attempted to confer in
good faith with Plaintiff prior to filing this motion, as described above. Plaintiff’s counsel has
requested that the following statement also be included in this certification:
In the Parties’ conferral efforts, Plaintiff’s counsel expressly
represented to Defendants’ counsel that Defendants do not have
Plaintiff’s authority to file this motion as a Joint Motion for
Discovery Hearing. Plaintiff’s counsel further represented that
Plaintiff seeks to preserve any and all arguments Plaintiff made in
his Motion for the Recusal of Magistrate Judge Enjoliqué A. Lett,
for Reassignment to a New Magistrate Judge to Supervise
Discovery, and for Brief Stay of Discovery with Incorporated
Memorandum of Law (ECF No. 55) (“Motion for Recusal”),
including the request for a brief stay of discovery while the Motion
for Recusal is pending. Plaintiff’s counsel further represented to
Defendants that Plaintiff reserves all rights and waives none.
/s/ Charles D. Tobin
Charles D. Tobin

Liz Dye@lizdye· Jun 11

Trump is big mad because BBC's Request For Admissions includes rude words like "Admit that You lost the 2020 Election to Joseph R. Biden, Jr" Unfair! How is that relevant to whether BBC defamed him by saying he wanted his supporters to attack the Capitol? storage.courtlistener.com/recap/gov.us...

admissions that do not have even a tangential connection to the defamatory statements at issue.
For example, Defendants’ Requests include:
17. Admit that You lost the 2020 Election to Joseph R. Biden, Jr. See Special
Counsel Rep’t at 10 (citing Federal Election Commission, Election Results for 2020
Federal Elections).
41. Admit that on the night of the 2020 Election, You and Rudy Giuliani agreed
that You should declare victory that day. Jan. 6 Rep’t at 207.
47. Admit that between Election Day 2020 and January 6, 2021, You and Your
allies repeatedly made dozens of public statements about Dominion voting
machines being faulty and/or fraudulent. Jan. 6 Rep’t at 216.
64. Admit that at a dinner on December 27, 2020, You spoke with Roger Stone
regarding Your plans for Your January 6 Speech. Jan. 6 Rep’t at 519.
72. Admit that prior to and on the day of January 6, 2021, Vice President Pence
repeatedly rejected your demands that he not certify the 2020 Election results for
President Biden on January 6, 2021. Jan. 6 Rep’t at 428.
83. Admit that Your January 6 Speech was drafted over the course of approximately
36 hours prior to the speech. Jan. 6 Rep’t at 581.
90. Admit that when You gave Your January 6 Speech, You knew that supporters
of You in attendance were carrying firearms. Jan. 6 Rep’t at 540.
96. Admit that You continued to request to go to the Capitol to join your supporters
even after returning to the White House on the afternoon of January 6, 2021. Jan. 6
Rep’t at 588.
See Defendants’ Requests for Admissions at ¶¶ 17, 41, 47, 64, 72, 83, 90, and 96 which are part
of Exhibit B.

Liz Dye@lizdye· Jun 10

Also Brito tried to get the magistrate to recuse because she previously represented one of the defendants in Trump's RICO trollsuit. Brito said he just discovered this, despite having repped Trump in the appeal of said RICO suit. Order: GTFOH storage.courtlistener.com/recap/gov.us...