IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA CITIZENS FOR RESPONSIBILITY AND ETHICS IN WASHINGTON et al Plaintiffs v Case No 19-cv-1333 ABJ DONALD J TRUMP in his official capacity as President of the United States et al Defendants PLAINTIFFS' MOTION FOR A TEMPORARY RESTRAINING ORDER Pursuant to Rule 65 of the Federal Rules of Civil Procedure and LCvR 65 1 Plaintiffs in the above-captioned action hereby move the Court to enter a temporary restraining order required Defendants to immediately preserve for the duration of this litigation 1 all records reflecting Defendants' meetings phone calls and other communications with foreign leaders 2 all records reflecting policies and practices regarding recordkeeping of Defendants' meetings phone calls and other communications with foreign leaders 3 all records reflecting White House or agency investigations of Defendants' recordkeeping policies and practices regarding meetings phone calls and other communications with foreign leaders 4 all records reflecting Defendants' communication of recordkeeping polices or practices to other components of the executive branch 5 all records reflecting instructions guidance or legal advice about recordkeeping requirements and 6 all records of efforts by White House or other executive branch officials to return claw back lock down or recall White House records reflecting Defendants' meetings phone calls and other communications with foreign leaders that were distributed to or otherwise shared with agency officials Further Plaintiffs respectfully request that the Court schedule a hearing on this motion at the Court's earliest convenience As grounds for this motion the Court is respectfully referred to the memorandum of points and authorities filed with this motion Respectfully submitted BAKER MCKENZIE LLP CITIZENS FOR RESPONSIBILITY AND ETHICS IN WASHINGTON s George M Clarke III_______________ George M Clarke III D C Bar No 480073 Mireille R Oldak D C Bar No 1027998 815 Connecticut Avenue N W Washington D C 20006 Phone 202 835-6184 Fax 202 416-7184 Email george clarke@bakermckenzie com Email mireille oldak@bakermckenzie com s Anne L Weismann_______________ Anne L Weismann D C Bar No 298190 Conor M Shaw D C Bar No 1032074 1101 K Street N W Suite 201 Washington D C 20005 Phone 202 408-5565 Email aweismann@citizensforethics org Email cshaw@citizensforethics org Counsel for Plaintiffs Dated October 1 2019 2 This document is from the holdings of The National Security Archive Suite 701 Gelman Library The George Washington University 2130 H Street NW Washington D C 20037 Phone 202 994-7000 Fax 202 994-7005 nsarchiv@gwu edu