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Liz Dye

@lizdye.bsky.social

Does Trump's sparklemagic libelslander lawyer Alejandro Brito know how supplemental authorities work? What is this shit?

Hearing tomorrow morning in the case Trump filed against the WSJ for saying he drew boobs 20 years ago. Should be amazing!

storage.courtlistener.com/recap/gov.us...

Plaintiff President Donald J. Trump (“Plaintiff” or “President Trump”), by and through
undersigned counsel, files this Notice of Filing Supplemental Authority In Support of His
Response in Opposition to Defendants’ Motion to Dismiss with Incorporated Memorandum of
Law (D.E. 46) and Response in Opposition to Defendants’ Request for Judicial Notice (D.E. 47)
(“Notice of Filing”). This Notice of Filing contains additional authorities that further support the
arguments previously raised in Plaintiff’s Response in Opposition to Defendants’ Motion to
Dismiss with Incorporated Memorandum of Law (D.E. 46) and Response in Opposition to
Defendants’ Request for Judicial Notice (D.E. 47). To the extent necessary, Plaintiff intends to rely
on these authorities at the December 9, 2025, hearing at 10:00 a.m. EST, during which the Court
will hear oral argument on Defendants’ Motion to Dismiss the Complaint and Incorporated

Memorandum of Law (D.E. 35) and Defendants’ Request for Judicial Notice (D.E. 38). Plaintiff’s
supplemental authorities are attached as Composite Exhibit A hereto and include:
1. Florida Statute § 92.38.
2. Burch v. P.J. Cheese, Inc., 861 F.3d 1338 (11th Cir. 2017).
3. Horsley v. Feldt, 304 F.3d 1125 (11th Cir. 2002).
4. Miami Beach First Nat. Bank v. Edgerly, 121 So. 2d 417 (Fla. 1960).
5. Monarch Air Group, LLC v. Journalism Development Network, Inc., No. 23-CV61256-BECERRA/STRAUSS, 2025 WL 2411984 (S.D. Fla. May 19, 2025) (report and
recommendation).
6. Monarch Air Group, LLC v. Journalism Development Network, Inc., No. 23-CV61256-BECERRA/STRAUSS, 2025 WL 2409766 (S.D. Fla. August 20, 2025) (order adopting
report and recommendation).
7. Purple Innovation, LLC v. Individuals, Corps., Ltd. Liab. Companies, Partnerships,
& Unincorporated Associations Identified on Schedule "A", No. 1:24-CV-21362-DPG, 2024 WL
4652095 (S.D. Fla. Oct. 22, 2024) (report and recommendation).
8. Purple Innovation, LLC v. Individuals, Corps., Ltd. Liab. Companies, Partnerships,
& Unincorporated Associations Identified on Schedule "A", No. 1:24-CV-21362, 2024 WL
4652096 (S.D. Fla. Nov. 1, 2024) (order adopting report and recommendation in full).
9. Trump Media & Technology Group Corp. v. WP Company LLC, No. 8:23-cv-1535-
TPB-AAS, 2025 WL 1615443 (M.D. Fla. June 6, 2025).

December 9, 2025 at 1:18 AM

Liz Dye

@lizdye.bsky.social

Tempting but no

Unique Guest Opportunity:
Founder of Paid Protesting
Firm Exposes Left's
Billionaire-Funded Chaos
Hey there Liz and Andrew,
Just one last check-in on Adam Swart
—founder of Crowds on Demand and one of the only people with firsthand experience in how modern protests are scripted, funded, and used for political pressure.
With tensions rising nationwide, Adam can offer a rare behind-the-scenes take your audience won't hear anywhere else.
Let me know if there's interest.
Best, Kristin

December 4, 2025 at 6:13 PM

Liz Dye

@lizdye.bsky.social

RUDE

Spotify end of year report says your listening age is 68. “Since you were into music from the early 70s. You’re an old soul.”

December 3, 2025 at 7:02 PM

Liz Dye

@lizdye.bsky.social

Pam Bondi's howler monkeys are on a roll today.

They just told a federal judge that the Epstein discharge petition requires him to unseal the Ghislaine Maxwell grand jury materials.

storage.courtlistener.com/recap/gov.us...

ncluding the Federal Bureau of Investigation and United States Attorneys’ Offices” that relate to
nine topics, such as “Jeffrey Epstein” and “Ghislaine Maxwell.” Act § 2.
The Department of Justice interprets the Act as requiring it to publish the grand jury and
discovery materials in this case, unless one of the permitted bases for withholding pursuant to the
Act applies. Accordingly, subject to appropriate redactions allowed by the Act, the Department of
Justice files this renewed motion requesting that the Court unseal the grand jury transcripts and
exhibits associated with the above-referenced indictment and amend the applicable protective
order that would otherwise prevent public disclosure by the Government pursuant to the
requirements of the Act.
2 In support of this request, the Department submits the following:

Image of man pointing at his head, known as thinking man meme

November 24, 2025 at 7:47 PM

Liz Dye

@lizdye.bsky.social

Halligan's team is now docketing hourly motions explaining that she absolutely, positively DID NOT F— UP the Comey indictment

storage.courtlistener.com/recap/gov.us...

This confirms the Court's recognition that the two-count true bill is the valid, operative
indictment.
III. The Transcript Leaves No Room for Ambiguity
The complete record eliminates any doubt:
• The foreperson confirmed the vote.
• The Court acknowledged the vote.
• The Court docketed the two-count true bill as the operative indictment.
• Only Count One lacked concurrence;
Counts Two and Three were true-billed by at least twelve jurors.
IV. Conclusion
Accordingly, any assertion that the grand jury "never voted on the two-count indictment"
is contradicted by the official transcript. For the reasons stated herein, the government respectfully

November 20, 2025 at 7:33 PM

Liz Dye

@lizdye.bsky.social

11am: Judge Fitzpatrick orders clerk to give grand jury materials to Comey at 3pm

3pm: Halligan files emergency motion to block

Yes, the motion is stupid on merits

But also, do these people own a clock? Is Bondi planning to ratify the motion back 4 hrs?

storage.courtlistener.com/recap/gov.us...

ORDERED that, by 3:00 p.m. on November 17, 2025, the Clerk of Court shall make available to the defense all grand jury materials filed on the docket under seal by the government (ECF 179); and it is further ORDERED that the government shall, no later than 5:00 p.m. on November 17, 2025, produce to the defense the complete audio recording of the grand jury proceedings; and it is further ORDERED that the Clerk of Court shall file on the public docket the version of the Memorandum Opinion containing narrow redactions of grand jury material; and it is further ORDERED that the Clerk of Court shall maintain the unredacted version of the Memorandum Opinion under seal until further order of the Court as to James B. Comey, Jr. Signed by Magistrate Judge William E. Fitzpatrick on 11/17/2025. (jlan) (Entered: 11/17/2025)

November 17, 2025 at 10:02 PM

Liz Dye

@lizdye.bsky.social

Is it like bad when the prosecutor tells the grand jury that there's no Fifth Amendment right not to testify in your own criminal case?

storage.courtlistener.com/recap/gov.us...

First, after having advised the grand jurors that the prosecutor was their legal advisor (ECF
178-1 at 46), the prosecutor stated:
" (ECF 178-1 at 105)
The prosecutor's statement that
is a fundamental
and highly prejudicial misstatement of the law that suggests to the grand jury that Mr. Comey does
not have a Fifth Amendment right not to testify at trial. The prosecutor's statement ignores the
foundational rule of law that if Mr. Comey exercised his right not to testify the jury could draw no negative inference from that decision. See Griffin v. California, 380 U.S. 609, 615 (1965) (holding that the Fifth Amendment "forbids either comment by the prosecution on the accused's silence or instructions by the court that such silence is evidence of guilt.") The prosecutor's statement that
may have reasonably set an expectation in the minds
of the grand jurors that rather than the government bear the burden to prove Mr. Comey's guilt beyond a reasonable doubt at trial, the burden shifts to Mr. Comey to explain away the government's evidence. See Victor v. Nebraska, 511 U.S. 1, 22 (1994) (holding that the Due

November 17, 2025 at 4:34 PM

Liz Dye

@lizdye.bsky.social

Drake invites Second Circuit to release its own diss track

AUBREY DRAKE GRAHAM,
Plaintiff,
v.
UMG RECORDINGS, INC.
Defendant.
No. 1:25-cv-399-JAV
NOTICE OF APPEAL
Plaintiff Aubrey Drake Graham hereby appeals from the District Court’s Opinion and
Order entered on October 9, 2025 (ECF No. 96) in the above-captioned case to the United States
Court of Appeals for the Second Circuit.
Dated: October 29, 2025

October 29, 2025 at 3:17 PM

Liz Dye

@lizdye.bsky.social

Aaaand right on time, the DOJ says that the lies were immaterial, despite the fact that they were repeated 18 times in the panel's opinion. And also, whoopsie doodle, DOJ found a couple more HARMLESS math errors.

storage.courtlistener.com/recap/gov.us...

Defendants do wish to correct a factual discrepancy discovered in the
course of responding to plaintiffs’ letter. The Cantu declaration, in describing
the number of FPS officers deployed in connection with the sustained violence
(1 of 2), Page 1 of 2 Case: 25-6268, 10/27/2025, DktEntry: 88.1, Page 1 of 2
2
associated with the protests in Portland, states that FPS Region 10 has been required to deploy “officers from the other FPS Regions” and that “[t]o date, 115
FPS officers have had to deploy to Portland to maintain a 24/7 operational
tempo.” We are informed by our clients that this 115 figure was the number of
deployments and that some individuals were deployed multiple times. Based on
DHS’s review of the deployment data, the number of individual FPS officers
deployed during the time period appears to be 86 officers.
Relatedly, we stated in our supplemental brief that “it is undisputed that
nearly a quarter of the agency’s entire FPS capacity had to be redirected over a
relatively short period to a single location in one medium-sized American city
due to the unrest there.” ECF No. 69.1 at 30. This statement was incorrect. The
statement was intended to reference the percentage of inspectors who had been
deployed to Portland during the relevant period, since inspectors are the FPS
personnel whose primary mission is to patrol and respond to law enforcement
incidents at federal buildings. But in addition to relying on the 115 figure—which
as noted above, actually consisted of 86 unique individuals—some of the 86
deployed FPS officials the Cantu declaration intended to encompass are not inspectors. Based on the agency’s records, it appears that 65 of the 86 individuals
deployed to Portland were inspectors. The statement should be corrected to reflect that approximately 13.1 percent of the agency’s inspectors had to be redirected to Portland during the period discussed by the Cantu declaration.

October 27, 2025 at 9:18 PM

Liz Dye

@lizdye.bsky.social

How are reporters quoting HHS Spox Tricia McLaughlin w/o noting she routinely fabricates lies about ICE's interactions with citizens and noncitizens alike?

McLaughlin *just* invented a convoy of cars, when it turned out ICE rammed the victim and shot her unprovoked.

www.nytimes.com/2025/10/21/u...

Tricia McLaughlin, a spokeswoman for the Department of Homeland Security, said that during a targeted traffic stop, an undocumented immigrant who was trying to flee had rammed a law enforcement vehicle with his car. Officers with the Homeland Security Department fired shots, striking the man in the elbow. A federal marshal was struck in the hand by a ricochet bullet, Ms. McLaughlin said.

The man and the injured law enforcement officer were both hospitalized, according to the Department of Homeland Security. The officer’s injury was not life-threatening and he was in stable condition, according to the United States Marshals Service. The immigrant’s condition was not immediately known.

The Department of Homeland Security has not identified the man in the traffic stop. Ms. McLaughlin said that he had “previously escaped from custody.” The Marshals Service confirmed that it was helping with the arrest of an undocumented immigrant, and that one of its deputies had been injured.

October 21, 2025 at 10:50 PM

Liz Dye

@lizdye.bsky.social

Update: Comey's motion to disqualify Lindsey Halligan because she was illegally appointed US Atty for EDVA has been assigned to Judge Cameron McGowan Currie of the District of South Carolina.

storage.courtlistener.com/recap/gov.us...

Pursuant to the October 21, 2025 Order of Chief Judge Albert Diaz of the United States
Court of Appeals for the Fourth Circuit, attached hereto, it is hereby ORDERED that the motion
challenging the qualification of the current Interim United States Attorney in the above-entitled
action (ECF 60) is hereby transferred to the Honorable Cameron McGowan Currie, Senior United
States District Judge of the District of South Carolina.
The Clerk of Court is directed to forward a copy of this Order to counsel of record.
IT IS SO ORDERED.
/s/
Michael S. Nachmanoff
United States District Judge

October 21, 2025 at 7:58 PM

Liz Dye

@lizdye.bsky.social

Law and Chaos represent

With @andrewtorrez.bsky.social

October 18, 2025 at 5:51 PM

Liz Dye

@lizdye.bsky.social

What are you looking at?

NOTHING!!!

Ace and Gary, 90s characters from SNL, recurring sketch by Stephen Colbert and Steve Carrell. Pictured here in their trademark aqua costumes, Gary giving Ace the Heimlich.

October 17, 2025 at 6:27 PM

Liz Dye

@lizdye.bsky.social

Oh, lord that Ninth Circuit hearing was bad. Let's console ourselves with this nice TRO out of Chicago blocking ICE from gassing peaceful protesters and journalists

storage.courtlistener.com/recap/gov.us...

Temporary Restraining Order
Plaintiffs filed an Emergency Motion for a Temporary Restraining Order [21] against
Defendants. Having held hearings on October 6, 8, and 9, 2025, the Court finds that Plaintiffs
have met their burden to support the issuance of a Temporary Restraining Order. Accordingly,
the Court grants the motion and orders as follows:
1. It is hereby ORDERED that Defendants,1 their officers, agents, assigns, and all
persons acting in concert with them (hereafter referred to as “Federal Agents”), are temporarily
ENJOINED in this judicial district from:
a. Dispersing, arresting, threatening to arrest, threatening or using physical
force against any person whom they know or reasonably should know is a Journalist, unless
Defendants have probable cause to believe that the individual has committed a crime.
Defendants may order a Journalist to change location to avoid disrupting law enforcement,

October 9, 2025 at 5:26 PM

Liz Dye

@lizdye.bsky.social

Fox News moves to transfer Newsmax's antitrust suit back to Florida from Wisconsin, and OH LOOKIE HERE who's arguing for Fox

storage.courtlistener.com/recap/gov.us...

Respectfully submitted,
/s/ Ryan J. Walsh___________
Ryan J. Walsh
EIMER STAHL LLP
10 East Doty Street
Suite 621
Madison, WI 53703
Telephone: 608.620.8346
rwalsh@eimerstahl.com
Bradley J. Bondi*
Michael F. Murray*
Benjamin W. Snyder
Ronald K. Anguas
*Application for Admission Submitted
PAUL HASTINGS LLP
2050 M Street NW
Washington, DC 20036
Telephone: 202.551.1700
bradbondi@paulhastings.com
michaelmurray@paulhastings.com
bensnyder@paulhastings.com
ronaldanguas@paulhastings.com
Attorneys for Defendants

September 22, 2025 at 6:37 PM

Liz Dye

@lizdye.bsky.social

Is Trump appointing Lindsey Halligan interim USA at EDVA? Or nominating her for Senate confirmation? Or both?

Pam Bondi is doing a GREAT job as Attorney General of the United States. She is very careful, very smart, loves our Country, but needs a tough prosecutor in the Eastern District of Virginia, like my recommendation, Lindsey Halligan, to get things moving. What we don’t need is a Democrat Endorsed “Republican.” I will be nominating Lindsey Halligan to be the United States Attorney in this very important part of our Great Country. She will be Fair, Smart, and will provide, desperately needed, JUSTICE FOR ALL!

September 21, 2025 at 3:41 PM

Liz Dye

@lizdye.bsky.social

"As every lawyer knows (or is presumed to know), a complaint is not a public forum for vituperation and invective — not a protected platform to rage against an adversary."

Shaaaaaade.

Also, if the judge is making fun of you for not capitalizing the Z in zeitgeist ... go home, son.

The reader must endure an allegation of “the desperate need to defame with
a partisan spear rather than report with an authentic looking glass” and an allegation
that “the false narrative about ‘The Apprentice’ was just the tip of Defendants’ melting iceberg of falsehoods.” Similarly, in one of many, often repetitive, and laudatory
(toward President Trump) but superfluous allegations, the pleader states, “‘The
Case 8:25-cv-02487-SDM-NHA Document 5 Filed 09/19/25 Page 2 of 4 PageID 166
- 3 -
Apprentice’ represented the cultural magnitude of President Trump’s singular brilliance, which captured the [Z]eitgeist of our time.”
The complaint continues with allegations in defense of President Trump’s father and the acquisition of the Trumps’ wealth; with a protracted list of the many
properties owned, developed, or managed by The Trump Organization

September 19, 2025 at 4:15 PM

Liz Dye

@lizdye.bsky.social

BREAKING: Judge Stephen Merryday strikes Trump's complaint against the NYT for being hot garbage — that is, for making a mockery of the rules for concise and precise pleading in federal court.

storage.courtlistener.com/recap/gov.us...

Even under the most generous and lenient application of Rule 8, the complaint is decidedly improper and impermissible. The pleader initially alleges an electoral victory by President Trump “in historic fashion” — by “trouncing” the opponent — and alludes to “persistent election interference from the legacy media, led
most notoriously by the New York Times.” The pleader alludes to “the halcyon
days” of the newspaper but complains that the newspaper has become a “fullthroated mouthpiece of the Democrat party,” which allegedly resulted in the “deranged endorsement” of President Trump’s principal opponent in the most recent
presidential election. The reader of the complaint must labor through allegations,
such as “a new journalistic low for the hopelessly compromised and tarnished ‘Gray
Lady.’” The reader must endure an allegation of “the desperate need to defame with
a partisan spear rather than report with an authentic looking glass” and an allegation
that “the false narrative about ‘The Apprentice’ was just the tip of Defendants’ melting iceberg of falsehoods.” Similarly, in one of many, often repetitive, and laudatory
(toward President Trump) but superfluous allegations, the pleader states, “‘The

September 19, 2025 at 3:59 PM

Liz Dye

@lizdye.bsky.social

How very dare you impugn the honor of a man who had cameos on Wrestlemania V and Home Alone 2!

storage.courtlistener.com/recap/gov.us...

58. President Trump’s hundreds of history-making media appearances and
roles include: WrestleMania V (1989); Ghosts Can’t Do It (1989); All My Children
(1992); Lady Boss (1992); Home Alone 2 (1992); Fallen Champ: The Untold Story
of Mike Tyson (1993); Fresh Prince of Bel Air (1994); The Little Rascals (1994);
Across the Sea of Time (1995); Eddie (1996); The Nanny (1996); The Associate
(1996); The Drew Carey Show (1997); NightMan (1997); Spin City (1998); 54
(1998); Celebrity (1998); Sex In The City (1998); Miss Universe 2001 (2001); The
Job (2001-2002); Zoolander (2001); Donald Trump Real Estate Tycoon! (2002)
(video game); Two Weeks Notice (2002); Miss USA 2002 (2002); Ali G Show (2003);
Marmalade (2004); Days of Our Lives (2005); Miss Universe Pageant; The
Apprentice (2004-2015) and Celebrity Apprentice (2008-2015); Hosted Saturday
Night Live (2015); Hosted WWE; and much more.

September 16, 2025 at 2:24 PM

Liz Dye

@lizdye.bsky.social

Guess who Newsmax's antitrust suit against Fox was just assigned to...

www.courtlistener.com/docket/71258...

Photo of Judge Aileen Cannon, a dark haired woman smiling in black judicial robes

September 3, 2025 at 6:31 PM

Liz Dye

@lizdye.bsky.social

August 31/September 1

September 2, 2025 at 12:06 AM

Liz Dye

@lizdye.bsky.social

Mecha Hitler has thoughts on user safety

OpenAI Shifts From Benefitting Humanity To Putting Profit Over Safety
42. The blockbuster success of ChatGPT seduced OpenAI into taking actions at odds
with its altruistic beginnings. When OpenAI first applied for tax-exempt status in 2016, it stated
that it would “be a nonprofit corporation organized exclusively for charitable and/or educational
purposes”; that “the specific purpose of this corporation is to provide funding for research,
development and distribution of technology related to artificial intelligence”; and that “[t]he
corporation is not organized for the private gain of any person.” It also promised that “OpenAI
does not plan to play any role in developing commercial products or equipment.”
43. OpenAI’s philanthropic ideals lasted only three years. Lured by the size of the AI
startup investment pie (which by 2019 totaled $40.4 billion globally), OpenAI announced on
March 11, 2019 the formation of OpenAI LP, a for-profit entity that would ostensibly help “raise
investment capital and attract employees” by promising its investors “a capped return” of “100x
their investment”—a cap that OpenAI buried in the text of the announcement.

September 1, 2025 at 4:15 PM

Liz Dye

@lizdye.bsky.social

Let me take a big swig of Diet Coke and crack open Twitter's trollsuit against Apple and OpenAI ...

OWWW MY NOSE BURNS

storage.courtlistener.com/recap/gov.us...

FACTUAL ALLEGATIONS
A. The Rise of AI: From Turing to Billions
33. Can machines think? Within a century after Alan Turing, the recognized father of
artificial intelligence, first asked that question, machines are not only thinking; they are thinking
for us faster than we ever could. AI could beat its programmer at checkers by 1959, engage in
conversation by 1966 (ELIZA), defeat the world’s reigning chess champion by 1997 (IBM Deep
Blue), and topple former Jeopardy! champions by 2011 (IBM Watson).
34. ELIZA was the world’s first chatbot—i.e., AI that can simulate human
conversation. While ELIZA could simulate a conversation with a psychotherapist, it used
keyword recognition to produce replies to questions from a set of predefined scripts and could
not produce new responses outside that set of scripts.
35. Unlike ELIZA, generative AI chatbots today can generate new content in
response to a user’s prompt (i.e., a user question or request) and are not limited to answers from
a predefined set of information. For example, if a user were discussing Shakespeare but suddenly
pivoted to talking about lunch, a generative AI chatbot would be able to keep up with that drastic
change in topic, while a non-generative AI chatbot would be limited to preexisting topics and
keywords it had access to, breaking the natural flow of the conversation.

September 1, 2025 at 4:13 PM

Liz Dye

@lizdye.bsky.social

This child deportees case started ugly, and it's getting uglier fast.

DOJ blows off deadline for status report confirming that they took all the Guatemalan children off the planes in Texas.

Docket: www.courtlistener.com/docket/71240...

MINUTE ORDER: The Court ordered the Defendants to file a status report by August 31, 2025, at 4:00 PM. They have not done so. The Court ORDERS the Defendants to show cause why a status report was not filed by that deadline. The Defendants remain under their obligation to file a status report addressing the current status of the deplaning of putative class members. If all class members have not been deplaned and moved back to the custody of ORR, the Defendants should advise when they expect that to occur. The Court further ORDERS the Plaintiffs to file a status report by August 31, 2025, at 6:30 PM, that addresses their understanding of whether the putative class members have been deplaned and moved to ORR. Signed by Judge Sparkle L. Sooknanan on 8/31/2025. (lcak)

August 31, 2025 at 9:26 PM

Liz Dye

@lizdye.bsky.social

Dammit, I have spread fake news. Deleting and eating crow.

Thanks to @zgoldberg.bsky.social for keeping me honest.

Repost with joke about ftc investigation of Stephen Colbert with fake article about Netflix deal

August 30, 2025 at 8:37 PM

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