“Plaintiff President Donald J Trump (‘Plaintiff’ or ‘President Trump’), by and through undersigned counsel and pursuant to Federal Rules of Civil Procedure 26(d), 30(a)(2)(A)(iii), and 32(a)(4)(C), files this Motion to Compel Expedited Deposition De Bene Esse of Defendant Keith Rupert Murdoch (‘Motion’). In support, President Trump states as follows: SUMMARY OF MOTION The Court should grant this Motion and enter an Order compelling the expedited deposition of Defendant Keith Rupert Murdoch (‘Murdoch’) for at least three reasons. First, Murdoch is 94 years old, has suffered from multiple health issues throughout his life, is believed to have suffered recent significant health scares, and is presumed to live in New York, New York. Taken together, these factors weigh heavily in determining that Murdoch would be unavailable for in-person testimony at trial. Second, mindful that there presently is no current scheduling order given the recency of the commencement of this action, the parties have not yet conducted their Rule 26(f) conference, and initial disclosures have not yet been served, the requested discovery sought in this Motion is limited solely to Murdoch.”

“Third, Murdoch has an advantage over President Trump as Murdoch is able to defend himself because he has access to all the information and documents related to the below-defined malicious and defamatory Article, and the decision behind deciding to publish it. On the other hand, President Trump has very limited information related to the Article. For these and other reasons that follow, Murdoch would not suffer any prejudice significant enough to outweigh the good cause that exists to grant this Motion,” write convicted felon President Trump’s lawyers in the motion requesting an expedited deposition of Old Man Murdoch in the fat bastard’s insane lawsuit over the Wall Street Journal’s article about the Epstein birthday letter.