Case: American Federation of Government Employees v. Trump

Legal Defense Fund

Charles Ezell

President Donald Trump

President Donald Trump

Notice of Error- New Case

Case Assigned/Reassigned

COMPLAINT against CHARLES EZELL, DONALD J. TRUMP, UNITED STATES OFFICE OF PERSONNEL MANAGEMENT ( Filing fee $ 405 receipt number ADCDC-11440861) filed by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO, AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO. (Attachments: # 1 Civil Cover Sheet, # 2 Summons for Donald J. Trump, # 3 Summons for Charles Ezell, # 4 Summons for the United States Office of Personnel Management, # 5 Summons for James R. McHenry III, # 6 Summons for Edward R. Martin Jr)(Carter, Abigail) (Entered: 01/29/2025)

1 Civil Cover Sheet

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2 Summons for Donald J. Trump

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3 Summons for Charles Ezell

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4 Summons for the United States Office of Personnel Management

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5 Summons for James R. McHenry III

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6 Summons for Edward R. Martin Jr

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NOTICE OF RELATED CASE by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO, AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO. Case related to Case No. 1:25-cv-170. (Carter, Abigail) (Entered: 01/29/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO (Carter, Abigail) (Entered: 01/29/2025)

NOTICE OF NEW CASE ERROR The following error(s) need correction: Missing Related Case form. Please use the Notice of Designation of Related Cases (CO 932) form at www.dcd.uscourts.gov/new-case-forms and filing using the event Notice of Related Case. COMPLIANCE DEADLINE is by close of business today. This case will not proceed any further until all errors are satisfied. (zmtm)

ENTERED IN ERROR.....NOTICE OF NEW CASE ERROR The following error(s) need correction: Missing Related Case form. Please use the Notice of Designation of Related Cases (CO 932) form at www.dcd.uscourts.gov/new-case-forms and filing using the event Notice of Related Case. COMPLIANCE DEADLINE is by close of business today. This case will not proceed any further until all errors are satisfied. (zmtm) Modified on 1/29/2025 (zmtm).

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO (Carter, Abigail) (Entered: 01/29/2025)

Case Assigned to Judge Jia M. Cobb. (zmtm)

SUMMONS(5) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zmtm) (Entered: 01/29/2025)

NOTICE of Appearance by James Alexander Rowell on behalf of AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO, AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO (Rowell, James) (Entered: 01/29/2025)

NOTICE of Appearance by Mark Samburg on behalf of AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO, AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO (Samburg, Mark) (Main Document 7 replaced on 1/30/2025) (zdp). (Entered: 01/30/2025)

Order on Motion for Leave to Appear Pro Hac Vice

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Elena Goldstein, Filing fee $ 100, receipt number ADCDC-11444118. Fee Status: Fee Paid. by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO, AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO. (Attachments: # 1 Exhibit, # 2 Declaration)(Samburg, Mark) (Entered: 01/30/2025)

MINUTE ORDER granting 8 Motion for Leave to Appear Pro Hac Vice: Attorney Elena Goldstein is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Jia M. Cobb on January 30, 2025. (lcjmc3)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 1/31/2025. Answer due for ALL FEDERAL DEFENDANTS by 4/1/2025. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Carter, Abigail) (Entered: 02/14/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 02/10/2025. (Attachments: # 1 Exhibit A)(Carter, Abigail) (Entered: 02/14/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. DONALD J. TRUMP served on 2/11/2025 (Attachments: # 1 Exhibit A)(Carter, Abigail) (Entered: 02/14/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. CHARLES EZELL served on 2/4/2025 (Attachments: # 1 Exhibit A)(Carter, Abigail) (Entered: 02/14/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. UNITED STATES OFFICE OF PERSONNEL MANAGEMENT served on 2/4/2025 (Attachments: # 1 Exhibit A)(Carter, Abigail) (Entered: 02/14/2025)

NOTICE OF RELATED CASE by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO, AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO. Case related to Case No. 1:25-cv-00347. (Carter, Abigail) (Entered: 02/14/2025)

NOTICE of Appearance by Matthew Stark Blumin on behalf of AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO (Blumin, Matthew) (Main Document 15 replaced on 2/18/2025) (zdp). (Entered: 02/18/2025)

NOTICE of Appearance by Teague Paterson on behalf of AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO (Paterson, Teague) (Main Document 16 replaced on 2/20/2025) (zdp). (Entered: 02/18/2025)

NOTICE of Appearance by Elena Goldstein on behalf of AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO, AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO (Goldstein, Elena) (Main Document 17 replaced on 2/20/2025) (zdp). (Entered: 02/18/2025)

NOTICE of Provisional/Government Not Certified Status re 16 NOTICE of Appearance by Teague Paterson on behalf of AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO (Paterson, Teague).Your attorney renewal/government certification has not been received. As a result, your membership with the U.S. District & Bankruptcy Courts for the District of Columbia is not in good standing, and you are not permitted to file. Pursuant to Local Civil Rule 83.9, you must immediately correct your membership status by following the appropriate instructions on this page of our website: https://www.dcd.uscourts.gov/attorney-renewal. Please be advised that the presiding judge in this case has been notified that you are currently not in good standing to file in this court. Renewal Due by 2/25/2025. (zhcn)

RESOLVED.....NOTICE of Provisional/Government Not Certified Status re 15 NOTICE of Appearance by Matthew Stark Blumin on behalf of AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO (Blumin, Matthew) (Main Document 15 replaced on 2/18/2025) (zdp)..Your attorney renewal/government certification has not been received. As a result, your membership with the U.S. District & Bankruptcy Courts for the District of Columbia is not in good standing, and you are not permitted to file. Pursuant to Local Civil Rule 83.9, you must immediately correct your membership status by following the appropriate instructions on this page of our website: https://www.dcd.uscourts.gov/attorney-renewal. Please be advised that the presiding judge in this case has been notified that you are currently not in good standing to file in this court. Renewal Due by 2/25/2025. (zhcn) Modified on 2/20/2025 (zhcn).

Notice of Provisional/Government Not Certified Status

LEAVE TO FILE DENIED- Janice Wolk Grenadier, Letter This document is unavailable as the Court denied its filing. Pro Se party has been notified by first class mail. "Leave to file DENIED. This motion does not comply with Local Civil Rule 7 (m).". Signed by Judge Jia M. Cobb on 2/24/2025. (zdp) (Entered: 02/24/2025)

NOTICE of Appearance by Jason Altabet on behalf of All Defendants (Altabet, Jason) (Entered: 03/27/2025)

Consent MOTION for Extension of Time to Respond to the Complaint, Consent MOTION for Briefing Schedule for Defendants' Upcoming Motion to Dismiss by DONALD J. TRUMP, CHARLES EZELL, UNITED STATES OFFICE OF PERSONNEL MANAGEMENT. (Altabet, Jason) (Entered: 03/27/2025)

PROPOSED BRIEFING SCHEDULE re 20 Consent MOTION for Extension of Time to Respond to the ComplaintConsent MOTION for Briefing Schedule for Defendants' Upcoming Motion to Dismiss by DONALD J. TRUMP, CHARLES EZELL, UNITED STATES OFFICE OF PERSONNEL MANAGEMENT. (Altabet, Jason) (Entered: 03/27/2025)

Order on Motion for Briefing Schedule AND Order on Motion for Extension of Time to AND Set/Reset Deadlines

MINUTE ORDER granting 20 Motion for Extension and Briefing Schedule: Having considered the unopposed motion, and for good cause shown, the Court GRANTS the motion. It is further ORDERED that Defendants' response to the complaint is due by April 22, 2025, Plaintiffs' opposition is due by May 22, 2025, and Defendants' reply is due by June 5, 2025. Signed by Judge Jia M. Cobb on March 28, 2025. (lcjmc3)

NOTICE of Appearance by Kevin Bell on behalf of All Defendants (Bell, Kevin) (Entered: 03/28/2025)

MOTION to Dismiss for Lack of Jurisdiction, MOTION to Dismiss under Rule 12(b)(1) and 12(b)(6) by CHARLES EZELL, DONALD J. TRUMP, UNITED STATES OFFICE OF PERSONNEL MANAGEMENT. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Text of Proposed Order)(Altabet, Jason) (Entered: 04/22/2025)

1 Memorandum in Support

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2 Exhibit A

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3 Text of Proposed Order

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MOTION for Extension of Time to File Response/Reply as to 23 MOTION to Dismiss for Lack of Jurisdiction MOTION to Dismiss under Rule 12(b)(1) and 12(b)(6) by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO, AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO. (Carter, Abigail) (Entered: 04/28/2025)

NOTICE OF SUPPLEMENTAL AUTHORITY by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO, AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO (Attachments: # 1 Supplement Supplemental Authority)(Samburg, Mark) (Entered: 04/29/2025)

1 Supplement Supplemental Authority

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Order on Motion for Extension of Time to File Response/Reply

MINUTE ORDER denying 24 Motion for Extension: Plaintiffs' 24 move to extend their deadline to file a response to Defendants' 23 motion to dismiss until 35 days after the completion of the proposed rulemaking announced on April 23, 2025. Defendants would consent to an extension, but not an indefinite one. The Court agrees with Defendants that it is not workable to extend this deadline indefinitely. But the Court would be amenable to a request to stay the case or to extend the deadline until a date certain. As such, the Court DENIES Plaintiffs' 24 motion for extension at this time, subject to Plaintiffs refiling, after conferring with Defendants, a motion seeking an extension until a date certain or seeking to stay the case for a period of time. Signed by Judge Jia M. Cobb on April 29, 2025. (lcjmc3)

Consent MOTION for Extension of Time to File Response/Reply as to 23 MOTION to Dismiss for Lack of Jurisdiction MOTION to Dismiss under Rule 12(b)(1) and 12(b)(6) by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO, AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO. (Attachments: # 1 Text of Proposed Order)(Samburg, Mark) (Entered: 05/02/2025)

1 Text of Proposed Order

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Order on Motion for Extension of Time to File Response/Reply AND Set/Reset Deadlines

MINUTE ORDER granting 26 Motion for Extension: Having considered the unopposed motion, and for good cause shown, the Court GRANTS the motion. It is further ORDERED that Plaintiffs' opposition to Defendants' 23 motion to dismiss is due by July 7, 2025. Signed by Judge Jia M. Cobb on May 12, 2025. (lcjmc3)

Consent MOTION to Stay by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO, AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, AFL-CIO. (Attachments: # 1 Text of Proposed Order)(Samburg, Mark) (Entered: 06/27/2025)

Order on Motion to Stay AND Set/Reset Deadlines

MINUTE ORDER granting 27 Motion to Stay: Having considered the unopposed motion, and for good cause shown, the Court GRANTS the motion. The Court ORDERS that this case is stayed until further order of this Court and directs the Parties to file a joint status report apprising the Court of the status of this matter by October 28, 2025. Signed by Judge Jia M. Cobb on June 30, 2025. (lcjmc3)