Excerpt:

To protect the integrity of this criminal proceeding and avoid prejudice to the jury, the People respectfully request that this Court issue a narrowly tailored order restricting certain prejudicial extrajudicial statements by defendant. The legal authority for such an order is wellestablished. And the need for such protection is compelling. Defendant has a long history of making public and inflammatory remarks about the participants in various judicial proceedings against him, including jurors, witnesses, lawyers, and court staff. Those remarks, as well as the inevitable reactions they incite from defendant’s followers and allies, pose a significant and imminent threat to the orderly administration of this criminal proceeding and a substantial likelihood of causing material prejudice. For these reasons, the U.S. Court of Appeals for the D.C. Circuit recently upheld restrictions on defendant’s extrajudicial speech that are essentially identical to the ones requested by the People here. This Court should accordingly grant the narrowly tailored protective measures sought here.