Smith v. Trump, No. 21-cv-02265 (D.C. (D.D.C.) 2025)

Case details
Full caption
CONRAD SMITH v. APM DONALD J. TRUMP
Country
United States
Jurisdiction
Federal
Court
District of Columbia (D.D.C.)
Decided
2025
Majority
United States (J.) (unanimous Court)
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA _________________________________________ ) CONRAD SMITH et al., ) ) Plaintiffs, ) ) v. ) Case No. 21-cv-02265 (APM) ) ) DONALD J. TRUMP et al., ) ) Defendants. ) _________________________________________ ) ORDER TO SHOW CAUSE DIRECTED TO COUNSEL FOR DEFENDANT KELLY MEGGS Counsel of record for Defendant Kelly Meggs, Carolyn A. Stewart, shall show cause by October 21, 2025, why the court should not impose sanctions and make a referral to relevant bar authorities for “knowingly mak[ing] a false statement of . . . law to a tribunal or fail[ing] to correct a false statement of . . . law previously made to the tribunal by the lawyer.” Model Rule of Prof. Conduct 3.3(a)(1); see also D.C. Rule of Prof. Conduct 3.3(a)(1); Fla. Rule of Prof. Conduct 4-3.3(a)(1). On July 11, 2025, Plaintiffs filed a motion to compel various Defendants, including Defendant Meggs, to respond to discovery requests and respond to initial disclosures, ECF No. 409 [hereinafter Pls.’ Mot.]. Ms. Stewart filed an opposition brief on behalf of Mr. Meggs (“Opposition”). See Def. Meggs’s Resp. in Opp’n to Pls.’ Mot., ECF No. 413 [hereinafter Def.’s Opp’n]. The Opposition is rife with fabricated citations to this District Court’s Local Civil Rules, such as: “Civil Procedure Rule 104 (7)-(8),” “local Rule 104,” “D.D.C. local Rule 104(7),” “D.D.C. Rule 8(a),” “Court’s Rule 8(a),” and “L.R. 104.8.” Id. at 1, 5–7. These rules do not exist. Case 1:21-cv-02265-APM Document 442 Filed 10/16/25 Page 1 of 2
2 The Opposition also includes fabricated block quotations purporting to recite the text of “D.D.C. local Rule 104(7)” and “D.D.C. Rule 8(a).” Id. at 5–6. On August 5, 2025, Plaintiffs filed a reply brief that noted the false citations in the Opposition. See Pls.’ Reply Mem. in Supp. of Pls.’ Mot., ECF No. 414, at 1–2, 5 n.5. Ms. Stewart thereafter failed to take appropriate steps to withdraw or correct all of the clear errors. In a notice filed on August 6, 2025, counsel acknowledged her mistake in citing to “local Rule 104(7)” instead of, as intended, to Maryland District Court Local Rule 104(7), but she made no mention of any other false citation. See Def.’s Notice of Intended Filing for Leave to File Surreply, ECF No. 415. Then, when she sought leave to file a surreply, she again referenced her error in misciting a “MD District local rule” but corrected no other error. See Def.’s Mot. for Leave to File a Surreply by Def. Meggs in Opp’n to Pl.’s Mot., ECF No. 420, at 4. Ms. Stewart’s response to this Order to Show Cause shall explain (1) how the fabricated Local Civil Rule citations and quotations came to be included in the Opposition and (2) why upon reviewing Plaintiffs’ reply brief she did not take immediate steps to withdraw or fully correct the Opposition. Dated: October 16, 2025 Amit P. Mehta United States District Judge Case 1:21-cv-02265-APM Document 442 Filed 10/16/25 Page 2 of 2
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