United States Court of Appeals for the First Circuit

Daniel E. Hall, a/k/a Sensa Verogna, )

Plaintiff, Appellant, ) Case No. 23-1555
v. )
) APPELLANT’S MOTION
Twitter, Inc., ) TO CORRECT
Defendant, Appellee ) THE RECORD
____________________________________

APPELLANT’S MOTION TO CORRECT THE RECORD

1. On August 14, 2023, Appellant, Daniel E. "Hall" motioned the District Court,
D.150, under Federal Rule 10(e), to correct and modify the current certified record, as
it incorrectly reflects the record of this case and does not include much of the material
evidence, original papers such as orders of the court, Appellant's motions to the court,
and exhibits were left out of the certified record.

2. On August 16, 2023, through an endorsed order, the District Court, denied the
motion citing,

"Pursuant to Local Rule 11.0 of the First Circuit Court of Appeals, the entire
electronic district court record is available to the court of appeals whether or
not individual documents are transmitted as part of the abbreviated electronic
record or are later supplemented. At any time, the Court of Appeals may
require the district court to transmit a supplemental record. The plaintiff's
motion is denied. So Ordered by Judge Samantha D. Elliott."

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3. Under Rule 10(e) of the Federal Rules of Appellate Procedure the trial court is
authorized to correct the record on appeal when a dispute arises as to whether the
record truly disclosed what occurred in the trial court.
3. Federal Rule of Appellate Procedure 10(e) authorizes the modification of the
record to the extent it is necessary to "truly disclose what occurred in the district court."
Fed.R.App.P. 10(e). Hall does not seek to include material outside the record before
the district court, just records within the case files. See In re Capital Cities, 913 F.2d 89,
96 (3d Cir. 1990).
CONCLUSION
For the aforementioned reasons, Hall's Motion should be granted, and the Court should
correct and modify the current certified record, as it incorrectly reflects the record of
this case and does not include much of the material evidence, original papers such as
orders of the court, Appellant's motions to the court, and exhibits were left out of the
certified record.
Respectfully,

/s/ Daniel E. Hall

Plaintiff, Appellant Pro Se

CERTIFICATE OF COMPLIANCE WITH TYPE-VOLUME LIMIT

This document complies with Fed. R. App. P. 27(d)(2)(A) because this document
contains no more than 5,200 words.

CERTIFICATE OF SERVICE

I certify that on August 28, 2023, I served the foregoing Motion upon the Defendant,
through its attorney of record to Demetrio F. Aspiras, counsel of record via the Court’s
electronic filing system.

/s/ Daniel E. Hall

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