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![I. THE TRUMP TRUST’S REQUEST FOR A STAY IS NOT AN EMERGENCY.
As a threshold matter, the Trump Trust’s motion for a stay is hardly an emergency. As
the Trump Trust frames the issue, its motion is an emergency because “[o]nce the Trust were to
begin handing those records over to the BBC, that disclosure could not be undone, and the
Trust’s pending objections could not restore what the BBC will have already seen.” Mot. at 2.
But “bona fide emergencies involve the health and safety of individuals, the impending departure
of a witness with no plans to return to the jurisdiction, the imminent destruction of a building or other property, the imminent deportation of an individual to another country, the need to give
critical medical treatment to a patient in a hospital, the threatened loss of civil rights, the
immediate, threatened loss of an entire business, or when someone is at risk of being denied an
essential service.” Companhia Energetica Potiguar v. Caterpillar Inc., 2016 WL 7469993, at *3
(S.D. Fla. Apr. 13, 2016) (Goodman, M.J.) (denying emergency motion to stay enforcement of
Magistrate Judge’s discovery order). By contrast, a deadline arriving after two weeks’ notice to
produce non-privileged documents—which may be designated “Confidential” or “Attorneys’
Eyes Only” under the Court’s Protective Order—does not justify the rare invocation of the
Court’s emergency procedures.
It is not even clear from the Trump Trust’s briefing what the purported emergency is
here. See id. (“But the mere fact that [the movant] did not obtain all the relief it wanted hardly
means that this situation is an emergency.”) (emphasis in original). Simply because the Trump
Trust faces an obligation it does not agree with, and is confronted with an imminent deadline of
its own making by waiting to file its stay motion until the day before its first Court-ordered
disclosure day, does not make its request an emergency](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:bbp2b224lro3bfnzcqwwnkfo/bafkreihfw75bjjm6e3um2e76g2xx4trhl3sfnsh2arkqo4o7j7ngnhpygy)