Case: Talbott v. Trump

Maureen Groppe

Darin S. Selnick

President Donald Trump

President Donald Trump

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF against GARY ASHWORTH, MARK AVERILL, TELITA CROSLAND, DEFENSE HEALTH AGENCY, TERENCE EMMERT, PETER B. HEGSETH, DONALD J. TRUMP, UNITED STATES DEPARTMENT OF THE AIR FORCE, UNITED STATES DEPARTMENT OF THE ARMY, UNITED STATES DEPARTMENT OF THE NAVY, UNITED STATES OF AMERICA ( Filing fee $ 405 receipt number ADCDC-11437641) filed by JAMIE HASH, KODA NATURE, ERICA VANDAL, DANY DANRIDGE, NICOLAS TALBOTT, KATE COLE, GORDON HERRERO, CAEL NEARY. (Attachments: # 1 Civil Cover Sheet, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons, # 6 Summons, # 7 Summons, # 8 Summons, # 9 Summons, # 10 Summons, # 11 Summons, # 12 Summons)(Wardenski, Joseph) (Entered: 01/28/2025)

1 Civil Cover Sheet

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2 Summons

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3 Summons

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4 Summons

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5 Summons

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6 Summons

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7 Summons

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8 Summons

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9 Summons

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10 Summons

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11 Summons

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12 Summons

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Notice of Error- New Case

NOTICE OF NEW CASE ERROR regarding 1 Complaint. The following error(s) need correction: Noncompliance with LCvR 5.1(c). Please file a Notice of Errata stating the error and attach the corrected initiating pleading to include the name & full residence address of each party and file using the event Errata. Blank/Incomplete/Missing civil cover sheet. Please file the Civil Cover Sheet (JS44) form at www.dcd.uscourts.gov/new-case-forms using the event Civil Cover Sheet. Form filed as fillable PDF. Please file form in a non-fillable PDF format. COMPLIANCE DEADLINE is by close of business today. This case will not proceed any further until all errors are satisfied. (zsl)

ERRATA by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY. (Attachments: # 1 Complaint (Corrected))(Wardenski, Joseph) (Entered: 01/28/2025)

1 Complaint (Corrected)

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CIVIL COVER SHEET by JAMIE HASH, KODA NATURE, ERICA VANDAL, DANY DANRIDGE, NICOLAS TALBOTT, KATE COLE, GORDON HERRERO, CAEL NEARY filed by JAMIE HASH, KODA NATURE, ERICA VANDAL, DANY DANRIDGE, NICOLAS TALBOTT, KATE COLE, GORDON HERRERO, CAEL NEARY.(Wardenski, Joseph) (Entered: 01/28/2025)

SEALED DOCUMENT filed by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY(This document is SEALED and only available to authorized persons.)(Wardenski, Joseph) (Entered: 01/28/2025)

Case Assigned to Judge Ana C. Reyes. (zsl)

SUMMONS (11) Issued Electronically as to All Defendants. (Attachment: # 1 Notice and Consent)(zsl) (Entered: 01/29/2025)

1 Notice and Consent

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Notice of Error- New Case

NOTICE OF NEW CASE ERROR The following error(s) need correction: Missing summonses- U.S. government. When naming a U.S. government agent or agency as a defendant, you must supply a summons for each defendant & two additional summonses for the U.S. Attorney & U.S. Attorney General. Please submit using the event Request for Summons to Issue. (zsl)

REQUEST FOR SUMMONS TO ISSUE filed by JAMIE HASH, KODA NATURE, ERICA VANDAL, DANY DANRIDGE, NICOLAS TALBOTT, GORDON HERRERO, CAEL NEARY. (Attachments: # 1 Summons)(Wardenski, Joseph) (Entered: 01/30/2025)

1 Summons

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SUMMONS (2) Issued Electronically as to U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zdp) (Entered: 01/30/2025)

1 Notice and Consent

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Jennifer L. Levi, Filing fee $ 100, receipt number ADCDC-11445702. Fee Status: Fee Paid. by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY. (Attachments: # 1 Declaration of Jennifer Levi, # 2 Supplemental Statement of Jennifer Levi, # 3 Certificate of Good Standing)(Wardenski, Joseph) (Entered: 01/30/2025)

1 Declaration of Jennifer Levi

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2 Supplemental Statement of Jennifer Levi

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3 Certificate of Good Standing

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Mary L. Bonauto, Filing fee $ 100, receipt number ADCDC-11445787. Fee Status: Fee Paid. by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY. (Attachments: # 1 Declaration of Mary Bonauto, # 2 Certificate of Good Standing)(Wardenski, Joseph) (Entered: 01/30/2025)

1 Declaration of Mary Bonauto

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2 Certificate of Good Standing

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MINUTE ORDER granting 8 Motion for Leave to Appear Pro Hac Vice. Attorney Jennifer L. Levi 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 Ana C. Reyes on 01/31/2025. (lcacr2)

MINUTE ORDER granting 9 Motion for Leave to Appear Pro Hac Vice. Attorney Mary L. Bonauto 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 Ana C. Reyes on 01/31/2025. (lcacr2)

STANDING ORDER. The Court hereby ORDERS the parties to comply with its Standing Order. See Standing Order for details. Signed by Judge Ana C. Reyes on 02/03/2025. (lcacr2) (Entered: 02/03/2025)

NOTICE of Appearance by Jennifer Levi on behalf of NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY (Levi, Jennifer) (Entered: 02/03/2025)

NOTICE of Appearance by Mary Bonauto on behalf of NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY (Bonauto, Mary) (Entered: 02/03/2025)

MOTION for Preliminary Injunction by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY. (Attachments: # 1 Memorandum in Support, # 2 Declaration of Joseph J. Wardenski, # 3 Index of Exhibits to Wardenski Decl., # 4 Exhibit A to Wardenski Decl., # 5 Exhibit B to Wardenski Decl., # 6 Exhibit C to Wardenski Decl., # 7 Exhibit D to Wardenski Decl., # 8 Exhibit E to Wardenski Decl., # 9 Exhibit F to Wardenski Decl., # 10 Exhibit G to Wardenski Decl., # 11 Exhibit H to Wardenski Decl., # 12 Exhibit I to Wardenski Decl., # 13 Exhibit J to Wardenski Decl., # 14 Exhibit K to Wardenski Decl., # 15 Exhibit L to Wardenski Decl., # 16 Exhibit M to Wardenski Decl., # 17 Exhibit N to Wardenski Decl., # 18 Exhibit O to Wardenski Decl., # 19 Exhibit P to Wardenski Decl., # 20 Declaration of Alex Wagner, # 21 Index of Exhibits to Wagner Decl., # 22 Exhibit A to Wagner Decl., # 23 Exhibit B to Wagner Decl., # 24 Exhibit C to Wagner Decl., # 25 Exhibit D to Wagner Decl., # 26 Exhibit E to Wagner Decl., # 27 Exhibit F to Wagner Decl., # 28 Declaration of Yvette Bourcicot, # 29 Exhibit A to Bourcicot Decl., # 30 Declaration of Gilbert Cisneros, # 31 Declaration of Shawn Skelly, # 32 Declaration of Nicolas Talbott, # 33 Declaration of Erica Vandal, # 34 Declaration of Kate Cole, # 35 Declaration of Gordon Herrero, # 36 Declaration of Dany Danridge, # 37 Declaration of Jamie Hash, # 38 Declaration of Koda Nature, # 39 Declaration of Cael Neary, # 40 Text of Proposed Order)(Wardenski, Joseph) (Entered: 02/03/2025)

1 Memorandum in Support

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2 Declaration of Joseph J. Wardenski

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3 Index of Exhibits to Wardenski Decl.

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4 Exhibit A to Wardenski Decl.

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5 Exhibit B to Wardenski Decl.

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6 Exhibit C to Wardenski Decl.

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7 Exhibit D to Wardenski Decl.

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8 Exhibit E to Wardenski Decl.

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9 Exhibit F to Wardenski Decl.

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10 Exhibit G to Wardenski Decl.

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11 Exhibit H to Wardenski Decl.

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12 Exhibit I to Wardenski Decl.

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13 Exhibit J to Wardenski Decl.

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14 Exhibit K to Wardenski Decl.

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15 Exhibit L to Wardenski Decl.

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16 Exhibit M to Wardenski Decl.

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17 Exhibit N to Wardenski Decl.

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18 Exhibit O to Wardenski Decl.

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19 Exhibit P to Wardenski Decl.

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20 Declaration of Alex Wagner

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21 Index of Exhibits to Wagner Decl.

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22 Exhibit A to Wagner Decl.

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23 Exhibit B to Wagner Decl.

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24 Exhibit C to Wagner Decl.

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25 Exhibit D to Wagner Decl.

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26 Exhibit E to Wagner Decl.

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27 Exhibit F to Wagner Decl.

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28 Declaration of Yvette Bourcicot

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29 Exhibit A to Bourcicot Decl.

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30 Declaration of Gilbert Cisneros

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31 Declaration of Shawn Skelly

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32 Declaration of Nicolas Talbott

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33 Declaration of Erica Vandal

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34 Declaration of Kate Cole

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35 Declaration of Gordon Herrero

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36 Declaration of Dany Danridge

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37 Declaration of Jamie Hash

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38 Declaration of Koda Nature

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39 Declaration of Cael Neary

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40 Text of Proposed Order

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.Order AND ~Util - Set/Reset Deadlines/Hearings

MINUTE ORDER. The Court ORDERS the following schedule for Plaintiffs' 13 Application for Preliminary Injunction:1. Defendants shall file their Opposition by February 12, 2025, at 6:00 PM EST;2. Plaintiffs shall file their Reply by February 14, 2025, at 6:00 PM EST;3. Amicus briefs, if any, shall be filed by February 14, 2025, at 6:00 PM EST;4. The Court will hold a hybrid argument / evidentiary hearing on Plaintiffs' 13 Application on February 18, 2025, beginning at 10:00 AM EST and continuing day-to-day until completed. The Court further AMENDS Section 5 of its 10 Standing Order (courtesy copies to Chambers) as follows: 1. Plaintiffs shall provide three (3) courtesy copies of their 13 Application and key legal references by February 5, 2025, at 12:00 PM EST;2. Defendants shall provide three (3) courtesy copies of their forthcoming Opposition and key legal references by February 15, 2025, at 12:00 PM EST;3. Plaintiffs shall provide three (3) courtesy copies of the Application, Opposition, and Reply briefs (without declarations or exhibits) in one binder by February 17, 2025, at 10:00 AM EST.4. The Parties shall include in the courtesy copies declarations, exhibits, and key academic or government studies. The Court DIRECTS Plaintiffs' counsel to send this Minute Order to Defendants' counsel as soon as possible and no later than 12:00 PM EST on Tuesday, February 4, 2025, as Defendants' counsel has not yet entered appearance.Signed by Judge Ana C. Reyes on 02/04/2025. (lcacr2)

.Order AND ~Util - Set/Reset Hearings

.Order AND ~Util - Set/Reset Deadlines

Status Conference AND ~Util - Set/Reset Deadlines/Hearings

MOTION for Temporary Restraining Order by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Declaration of Miriam Perelson, # 6 Exhibit 1 to Perelson Decl., # 7 Text of Proposed Order)(Wardenski, Joseph) (Entered: 02/04/2025)

1 Memorandum in Support

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2 Exhibit A

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3 Exhibit B

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4 Exhibit C

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5 Declaration of Miriam Perelson

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6 Exhibit 1 to Perelson Decl.

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7 Text of Proposed Order

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MINUTE ORDER. The Court will hold a preliminary hearing on Plaintiffs' 14 Application for Temporary Restraining Order at 4:00 PM on Tuesday, February 4, 2025, in Courtroom 12.Interested parties may access the Court's dial-in line. The Public Access telephone number is 1-833-990-9400, and the access code is 787605272.Signed by Judge Ana C. Reyes on 02/04/2025. (lcacr2)

Minute Entry for proceedings held before Judge Ana C. Reyes: Status Conference held on 2/4/2025 regarding the Plaintiffs 14 Application for Temporary Restraining Order. Hearing on the Plaintiff's motion tentatively set for 2/7/2025 at 10:00 AM in Courtroom 12 (in person) before Judge Ana C. Reyes. Parties to submit a Joint Status Report by 4:00 PM on 2/5/2025 to determine if hearing will proceed. Interested members of the public and media may access the Motion Hearing by dialing the Courts toll-free public access line: (833)-990-9400, access code 787605272. ( Status Report due by 2/5/2025, Motion Hearing set for 2/7/2025 at 10:00 AM in Courtroom 12- In Person (Audio Line Available) before Judge Ana C. Reyes.). (Court Reporter Lisa Edwards.) (zakb)

MINUTE ORDER. Following today's preliminary hearing, the Court ORDERS the parties to submit a joint status report, on or before February 5, 2025, at 4:00 PM, addressing the issues discussed on the record. Signed by Judge Ana C. Reyes on 02/04/2025. (lcacr2)

AMENDED COMPLAINT against All Defendants filed by JAMIE HASH, KODA NATURE, ERICA VANDAL, DANY DANRIDGE, NICOLAS TALBOTT, KATE COLE, GORDON HERRERO, CAEL NEARY, MIRIAM PERELSON.(Wardenski, Joseph) (Entered: 02/04/2025)

SEALED DOCUMENT filed by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON(This document is SEALED and only available to authorized persons.)(Wardenski, Joseph) (Entered: 02/04/2025)

TRANSCRIPT OF STATUS CONFERENCE before Judge Ana C. Reyes held on February 4, 2025; Page Numbers: 1-55. Date of Issuance: February 5, 2025. Court Reporter/Transcriber Lisa Edwards. Telephone number (202) 354-3269. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 2/26/2025. Redacted Transcript Deadline set for 3/8/2025. Release of Transcript Restriction set for 5/6/2025.(Edwards, Lisa) (Entered: 02/05/2025)

.Order

NOTICE of Appearance by Jason C. Lynch on behalf of All Defendants (Lynch, Jason) (Entered: 02/05/2025)

Joint STATUS REPORT by TELITA CROSLAND, DEFENSE HEALTH AGENCY, DONALD J. TRUMP, UNITED STATES OF AMERICA, PETER B. HEGSETH, MARK AVERILL, UNITED STATES DEPARTMENT OF THE ARMY, TERENCE EMMERT, UNITED STATES DEPARTMENT OF THE NAVY, GARY ASHWORTH, UNITED STATES DEPARTMENT OF THE AIR FORCE. (Attachments: # 1 Declaration of LTC Baker (Feb. 4, 2025))(Lynch, Jason) (Entered: 02/05/2025)

1 Declaration of LTC Baker (Feb. 4, 2025)

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MINUTE ORDER. The Court ORDERS the Government to immediately notify Plaintiffs and the Court if the Department of Defense (or any of its subsidiaries) issues any policy or guidance implementing the challenged Executive Orders in the military. The Court further ORDERS the Government to immediately notify Plaintiffs and the Court before any changes are made to Plaintiffs' status quo in any way, shape, or form. The Court will entertain a motion for a temporary restraining order should any action be taken against Plaintiffs before the preliminary injunction hearing on February 18, 2025. Signed by Judge Ana C. Reyes on 02/05/2025. (lcacr2)

Supplemental STATUS REPORT by TELITA CROSLAND, DEFENSE HEALTH AGENCY, DONALD J. TRUMP, UNITED STATES OF AMERICA, PETER B. HEGSETH, MARK AVERILL, UNITED STATES DEPARTMENT OF THE ARMY, TERENCE EMMERT, UNITED STATES DEPARTMENT OF THE NAVY, GARY ASHWORTH, UNITED STATES DEPARTMENT OF THE AIR FORCE. (Lynch, Jason) (Entered: 02/05/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Sarah K. Austin, Filing fee $ 100, receipt number ADCDC-11463030. Fee Status: Fee Paid. by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON. (Attachments: # 1 Declaration, # 2 Certificate of Good Standing)(Wardenski, Joseph) (Entered: 02/06/2025)

1 Declaration

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2 Certificate of Good Standing

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Michael Robert Haley, Filing fee $ 100, receipt number ADCDC-11463035. Fee Status: Fee Paid. by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON. (Attachments: # 1 Declaration, # 2 Certificate of Good Standing)(Wardenski, Joseph) (Entered: 02/06/2025)

1 Declaration

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2 Certificate of Good Standing

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NOTICE In Response to February 5, 2025 Minute Order by TELITA CROSLAND, DEFENSE HEALTH AGENCY, DONALD J. TRUMP, UNITED STATES OF AMERICA, PETER B. HEGSETH, MARK AVERILL, UNITED STATES DEPARTMENT OF THE ARMY, TERENCE EMMERT, UNITED STATES DEPARTMENT OF THE NAVY, GARY ASHWORTH, UNITED STATES DEPARTMENT OF THE AIR FORCE re Order,, (Attachments: # 1 Exhibit 1 - 04 Feb 2025 Army Memorandum)(Lynch, Jason) (Entered: 02/06/2025)

1 Exhibit 1 - 04 Feb 2025 Army Memorandum

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Shannon Minter, Filing fee $ 100, receipt number ADCDC-11463119. Fee Status: Fee Paid. by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON. (Attachments: # 1 Declaration, # 2 Supplement, # 3 Certificate of Good Standing)(Wardenski, Joseph) (Entered: 02/06/2025)

1 Declaration

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2 Supplement

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3 Certificate of Good Standing

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Christopher F. Stoll, Filing fee $ 100, receipt number ADCDC-11463121. Fee Status: Fee Paid. by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON. (Attachments: # 1 Declaration, # 2 Certificate of Good Standing)(Wardenski, Joseph) (Entered: 02/06/2025)

1 Declaration

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2 Certificate of Good Standing

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Amy Whelan, Filing fee $ 100, receipt number ADCDC-11463124. Fee Status: Fee Paid. by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON. (Attachments: # 1 Declaration, # 2 Certificate of Good Standing)(Wardenski, Joseph) (Entered: 02/06/2025)

1 Declaration

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2 Certificate of Good Standing

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MINUTE ORDER granting 21 Motion for Leave to Appear Pro Hac Vice. Attorney Sarah K. Austin 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 Ana C. Reyes on 02/07/2025. (lcacr2)

MINUTE ORDER granting 22 Motion for Leave to Appear Pro Hac Vice. Attorney Michael Robert Haley 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 Ana C. Reyes on 02/07/2025. (lcacr2)

MINUTE ORDER granting 24 Motion for Leave to Appear Pro Hac Vice. Attorney Shannon Minter 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 Ana C. Reyes on 02/07/2025. (lcacr2)

MINUTE ORDER granting 25 Motion for Leave to Appear Pro Hac Vice. Attorney Christopher F. Stoll 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 Ana C. Reyes on 02/07/2025. (lcacr2)

MINUTE ORDER granting 26 Motion for Leave to Appear Pro Hac Vice. Attorney Amy Whelan 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 Ana C. Reyes on 02/07/2025. (lcacr2)

NOTICE of Appearance by Shannon P. Minter on behalf of All Plaintiffs (Minter, Shannon) (Entered: 02/07/2025)

NOTICE of Appearance by Amy Whelan on behalf of All Plaintiffs (Whelan, Amy) (Entered: 02/07/2025)

NOTICE of Appearance by Christopher F. Stoll on behalf of All Plaintiffs (Stoll, Christopher) (Entered: 02/07/2025)

NOTICE of Appearance by Sarah K. Austin on behalf of NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON (Austin, Sarah) (Entered: 02/07/2025)

NOTICE of Appearance by Michael R. Haley on behalf of NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON (Haley, Michael) (Entered: 02/07/2025)

DECLARATION of George Richard Brown, MD, DFAPA by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON re 13 MOTION for Preliminary Injunction . (Attachments: # 1 Exhibit A - CV of George Richard Brown, GEORGE RICHARD BROWN, MD, DFAPA, # 2 Exhibit B - Elders et al., Medical Aspects of Transgender Military Service, Armed Forces & Society (2014))(Wardenski, Joseph) (Entered: 02/08/2025)

1 Exhibit A - CV of George Richard Brown, GEORGE RICHARD BROWN, MD, DFAPA

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2 Exhibit B - Elders et al., Medical Aspects of Transgender Military Service, Arme

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NOTICE of Provisional/Government Not Certified Status re 32 DECLARATION of George Richard Brown, MD, DFAPA by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON re 13 MOTION for Preliminary Injunction . (Attachments: (1) Exhibit A - CV of George Richard Brown, GEORGE RICHARD BROWN, MD, DFAPA, (2) Exhibit B - Elders et al., Medical Aspects of Transgender Military Service, Armed Forces & Society (2014))(Wardenski, Joseph).

NOTICE of Provisional/Government Not Certified Status re 32 DECLARATION of George Richard Brown, MD, DFAPA by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON re 13 MOTION for Preliminary Injunction . (Attachments: # 1 Exhibit A - CV of George Richard Brown, GEORGE RICHARD BROWN, MD, DFAPA, # 2 Exhibit B - Elders et al., Medical Aspects of Transgender Military Service, Armed Forces & Society (2014))(Wardenski, Joseph).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 2/15/2025. (zhcn)

MINUTE ORDER. The Court ORDERS the parties to appear before Judge Reyes via Zoom on Thursday, February 13 at 12:00 PM to discuss logistics for the preliminary injunction hearing starting on Tuesday, February 18. The Court plans to accept all declarations as direct evidence. The parties should be prepared to discuss whether they wish to cross-examine any witness and/or make any evidentiary challenges, and how they jointly suggest the hearing should proceed. Interested parties may access the Court's dial-in line for the February 13 Zoom hearing. The dial-in line will also be available for any part of the February 18 preliminary injunction hearing that does not involve witness testimony. The Public Access telephone number is 1-833-990-9400, and the access code is 787605272. Signed by Judge Ana C. Reyes on 02/10/2025. (lcacr2)

.Order AND ~Util - Set/Reset Hearings

NOTICE by TELITA CROSLAND, DEFENSE HEALTH AGENCY, DONALD J. TRUMP, UNITED STATES OF AMERICA, PETER B. HEGSETH, MARK F. AVERILL, UNITED STATES DEPARTMENT OF THE ARMY, TERENCE EMMERT, UNITED STATES DEPARTMENT OF THE NAVY, GARY ASHWORTH, UNITED STATES DEPARTMENT OF THE AIR FORCE re Order,, (Attachments: # 1 Exhibit 1 - SecDef Memo)(Lynch, Jason) (Entered: 02/10/2025)

1 Exhibit 1 - SecDef Memo

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TRANSCRIPT OF STATUS CONFERENCE (CONDUCTED IN CHAMBERS) before Judge Ana C. Reyes held on February 4, 2025; Page Numbers: 1-15. Date of Issuance: February 11, 2025. Court Reporter/Transcriber Lisa Edwards. Telephone number (202) 354-3269. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 3/4/2025. Redacted Transcript Deadline set for 3/14/2025. Release of Transcript Restriction set for 5/12/2025.(Edwards, Lisa) (Entered: 02/11/2025)

NOTICE of Appearance by Sara E. Kropf on behalf of All Plaintiffs (Kropf, Sara) (Entered: 02/12/2025)

Order on Sealed Motion for Leave to File Document Under Seal

SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by TELITA CROSLAND, DEFENSE HEALTH AGENCY, DONALD J. TRUMP, UNITED STATES OF AMERICA, PETER B. HEGSETH, MARK F. AVERILL, UNITED STATES DEPARTMENT OF THE ARMY, TERENCE EMMERT, UNITED STATES DEPARTMENT OF THE NAVY, GARY ASHWORTH, UNITED STATES DEPARTMENT OF THE AIR FORCE (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Sealed Declaration of Lieutenant Colonel Baker, # 2 Text of Proposed Order)(Layendecker, Elizabeth) (Entered: 02/12/2025)

NOTICE by TELITA CROSLAND, DEFENSE HEALTH AGENCY, DONALD J. TRUMP, UNITED STATES OF AMERICA, PETER B. HEGSETH, MARK F. AVERILL, UNITED STATES DEPARTMENT OF THE ARMY, TERENCE EMMERT, UNITED STATES DEPARTMENT OF THE NAVY, GARY ASHWORTH, UNITED STATES DEPARTMENT OF THE AIR FORCE re Order,, (Attachments: # 1 Exhibit 1 - 07 Feb 2025 Army Guidance)(Lynch, Jason) (Entered: 02/12/2025)

1 Exhibit 1 - 07 Feb 2025 Army Guidance

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MINUTE ORDER. Upon consideration of Defendants' 36 Unopposed Motion for Leave to File under Seal, the Court GRANTS the Motion. Signed by Judge Ana C. Reyes on 02/12/2025. (lcacr2) Modified on 2/12/2025 (zcll).

Memorandum in opposition to re 13 Motion for Preliminary Injunction,,,,,, filed by TELITA CROSLAND, DEFENSE HEALTH AGENCY, DONALD J. TRUMP, UNITED STATES OF AMERICA, PETER B. HEGSETH, MARK F. AVERILL, UNITED STATES DEPARTMENT OF THE ARMY, TERENCE EMMERT, UNITED STATES DEPARTMENT OF THE NAVY, GARY ASHWORTH, UNITED STATES DEPARTMENT OF THE AIR FORCE. (Attachments: # 1 Exhibit 1 - 2018 DoD Report, # 2 Exhibit 2 - Feb 2018 Mattis Memo, # 3 Exhibit 3 - Mar 2018 Pres Memo, # 4 Exhibit 4 - Dec 2017 Health Data)(Lynch, Jason) (Entered: 02/12/2025)

1 Exhibit 1 - 2018 DoD Report

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2 Exhibit 2 - Feb 2018 Mattis Memo

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3 Exhibit 3 - Mar 2018 Pres Memo

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4 Exhibit 4 - Dec 2017 Health Data

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NOTICE of Appearance by Elizabeth Brooke Layendecker on behalf of All Defendants (Layendecker, Elizabeth) (Main Document 39 replaced on 2/13/2025) (zdp). (Entered: 02/12/2025)

NOTICE of PUBLIC LINE INFORMATION: Interested parties may access the Court's dial-in line for the February 13 Zoom hearing. The Public Access telephone number is 1-833-990-9400, and the access code is 720718696. (zcll)

Minute Entry for proceedings held before Judge Ana C. Reyes: Pre-motion Conference held on 2/13/2025. Defendant DONALD J. TRUMP in his official capacity as President of the United States is hereby DISMISSED as a Defendant in this matter. Preliminary Injunction hearing remains scheduled for 2/18/2025 at 10:00AM before Judge Ana C. Reyes. (Court Reporter Christine Asif.) (zcll)

TRANSCRIPT OF PROCEEDINGS before Judge Ana C. Reyes held on 2/13/2025; Page Numbers: 1-50. Date of Issuance:2/13/2025. Court Reporter Christine T. Asif, Telephone number 2023543247, Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 3/6/2025. Redacted Transcript Deadline set for 3/16/2025. Release of Transcript Restriction set for 5/14/2025.(Asif, Christine) (Entered: 02/13/2025)

Minute Order: The Court will provide access for the public to telephonically attend the hearing scheduled for 2/18/2025 at 10AM ET. The hearing can be accessed through dialing the Toll Free Number: 833-990-9400, Meeting ID: 787605272. It is hereby ORDERED that the attendees using the public access telephone line shall adhere to the following: persons remotely accessing court proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings (including those held by telephone or videoconference). Parties are also advised that the public line will not be available during witness testimony. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the presiding Judge. SO ORDERED. Signed by Judge Ana C. Reyes on 2/14/2025. (zcll)

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Order on Motion for Leave to Appear AND Order on Motion for Leave to File

Consent MOTION for Leave to File Amicus Curiae Brief by CONSTITUTIONAL ACCOUNTABILITY CENTER. (Attachments: # 1 Appendix Proposed Amicus Curiae Brief, # 2 Text of Proposed Order)(Gorod, Brianne) (Entered: 02/14/2025)

1 Appendix Proposed Amicus Curiae Brief

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2 Text of Proposed Order

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MINUTE ORDER granting 41 Motion for Leave to File an Amicus Curiae Brief by the Constitutional Accountability Center. Signed by Judge Ana C. Reyes on 02/14/2025. (lcacr2)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Inga S. Bernstein, Filing fee $ 100, receipt number ADCDC-11482040. Fee Status: Fee Paid. by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON. (Attachments: # 1 Declaration of Inga S. Bernstein, # 2 Certificate of Good Standing)(Wardenski, Joseph) (Entered: 02/14/2025)

1 Declaration of Inga S. Bernstein

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2 Certificate of Good Standing

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AMICUS BRIEF by STATE OF VERMONT, STATE OF WASHINGTON. (Rose, Jonathan) (Entered: 02/14/2025)

ENTERED IN ERROR.....AMICUS BRIEF by STATE OF VERMONT, STATE OF WASHINGTON. (zdp) Modified on 2/14/2025 (zdp). (Entered: 02/14/2025)

AMICUS BRIEF by CONSTITUTIONAL ACCOUNTABILITY CENTER. (zdp) (Entered: 02/14/2025)

MOTION for Leave to Appear on behalf of amici curiae by FRANK KENDALL, CHRISTINE WORMUTH. (Tutt, Andrew) (Entered: 02/14/2025)

Consent MOTION for Leave to File Amicus Brief in Support of Motion for Preliminary Injunction by FRANK KENDALL, CHRISTINE WORMUTH. (Attachments: # 1 Proposed Brief, # 2 Text of Proposed Order)(Tutt, Andrew) (Entered: 02/14/2025)

1 Proposed Brief

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2 Text of Proposed Order

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MINUTE ORDER granting 46 Motion for Leave to Appear and 47 Motion for Leave to File an Amicus Curiae Brief by Former Military Department Heads. Signed by Judge Ana C. Reyes on 02/14/2025. (lcacr2)

REPLY to opposition to motion re 13 Motion for Preliminary Injunction,,,,,, filed by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON. (Attachments: # 1 Declaration of Minerva Bettis, # 2 Declaration of Carlos Del Toro, # 3 Declaration of Audrie Graham, # 4 Declaration of Michael Haley, # 5 Exhibit A to Haley Decl., # 6 Exhibit B to Haley Decl., # 7 Exhibit C to Haley Decl., # 8 Exhibit D to Haley Decl., # 9 Exhibit E to Haley Decl., # 10 Exhibit F to Haley Decl., # 11 Exhibit G to Haley Decl., # 12 Exhibit H to Haley Decl., # 13 Exhibit I to Haley Decl., # 14 Exhibit J to Haley Decl., # 15 Exhibit K to Haley Decl., # 16 Declaration of Roan Pickett, # 17 Exhibit A to Pickett Decl., # 18 Declaration of Amiah Sale, # 19 Declaration of Quinn Tyson, # 20 Exhibit A to Tyson Decl., # 21 Exhibit B to Tyson Decl., # 22 Supplemental Declaration of Jamie Hash, # 23 Supplemental Declaration of Gordon Herrero, # 24 Supplemental Declaration of Miriam Perelson, # 25 Supplemental Declaration of Erica Vandal, # 26 Exhibit A to Supplemental Vandal Decl., # 27 Supplemental Declaration of Alex Wagner, # 28 Exhibit A to Supplemental Wagner Decl., # 29 Declaration of Joseph Wardenski, # 30 Exhibit A to Wardenski Decl., # 31 Exhibit B to Wardenski Decl., # 32 Exhibit C to Wardenski Decl.)(Wardenski, Joseph) (Entered: 02/14/2025)

1 Declaration of Minerva Bettis

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2 Declaration of Carlos Del Toro

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3 Declaration of Audrie Graham

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4 Declaration of Michael Haley

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5 Exhibit A to Haley Decl.

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6 Exhibit B to Haley Decl.

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7 Exhibit C to Haley Decl.

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8 Exhibit D to Haley Decl.

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9 Exhibit E to Haley Decl.

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10 Exhibit F to Haley Decl.

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11 Exhibit G to Haley Decl.

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12 Exhibit H to Haley Decl.

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13 Exhibit I to Haley Decl.

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14 Exhibit J to Haley Decl.

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15 Exhibit K to Haley Decl.

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16 Declaration of Roan Pickett

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17 Exhibit A to Pickett Decl.

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18 Declaration of Amiah Sale

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19 Declaration of Quinn Tyson

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20 Exhibit A to Tyson Decl.

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21 Exhibit B to Tyson Decl.

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22 Supplemental Declaration of Jamie Hash

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23 Supplemental Declaration of Gordon Herrero

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24 Supplemental Declaration of Miriam Perelson

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25 Supplemental Declaration of Erica Vandal

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26 Exhibit A to Supplemental Vandal Decl.

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27 Supplemental Declaration of Alex Wagner

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28 Exhibit A to Supplemental Wagner Decl.

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29 Declaration of Joseph Wardenski

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30 Exhibit A to Wardenski Decl.

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31 Exhibit B to Wardenski Decl.

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32 Exhibit C to Wardenski Decl.

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NOTICE by TELITA CROSLAND, DEFENSE HEALTH AGENCY, UNITED STATES OF AMERICA, PETER B. HEGSETH, MARK F. AVERILL, UNITED STATES DEPARTMENT OF THE ARMY, TERENCE EMMERT, UNITED STATES DEPARTMENT OF THE NAVY, GARY ASHWORTH, UNITED STATES DEPARTMENT OF THE AIR FORCE re Order,, (Attachments: # 1 Exhibit 1 - Feb. 14, 2025 amendment to Army EXORD 150-25)(Lynch, Jason) (Entered: 02/14/2025)

1 Exhibit 1 - Feb. 14, 2025 amendment to Army EXORD 150-25

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DECLARATION of Greyson Shishkina by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON re 48 Reply to opposition to Motion,,,,,. (Wardenski, Joseph) (Entered: 02/14/2025)

DECLARATION of Clayton McCallister by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON re 48 Reply to opposition to Motion,,,,,. (Wardenski, Joseph) (Entered: 02/14/2025)

Unopposed MOTION for Leave to File Declaration of Timothy Dill by TELITA CROSLAND, DEFENSE HEALTH AGENCY, UNITED STATES OF AMERICA, PETER B. HEGSETH, MARK F. AVERILL, UNITED STATES DEPARTMENT OF THE ARMY, TERENCE EMMERT, UNITED STATES DEPARTMENT OF THE NAVY, GARY ASHWORTH, UNITED STATES DEPARTMENT OF THE AIR FORCE. (Attachments: # 1 Exhibit Dill Declaration, # 2 Text of Proposed Order)(Layendecker, Elizabeth) (Entered: 02/14/2025)

1 Exhibit Dill Declaration

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2 Text of Proposed Order

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MINUTE ORDER granting 42 Motion for Leave to Appear Pro Hac Vice. Attorney Inga S. Bernstein 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 Ana C. Reyes on 02/15/2025. (lcacr2)

.Order

MINUTE ORDER. Upon consideration of Defendants' 52 Unopposed Motion for Leave to File the Declaration of Timothy Dill, the Court GRANTS the Motion. Signed by Judge Ana C. Reyes on 02/15/2025. (lcacr2)

MINUTE ENTRY. The Court extends its appreciation to all amici who submitted briefs in this matter. Signed by Judge Ana C. Reyes on 02/15/2025. (lcacr2)

MINUTE ORDER. After conferring with the parties, the Court ORDERS that oral argument on Plaintiffs' 13 Motion for Preliminary Injunction will be heard on Tuesday, February 18 starting at 10:00 AM. Interested parties may access the Court's dial-in line and must adhere to the rules outlined in the Court's February 14, 2025 Minute Order. The Public Access telephone number is 1-833-990-9400, and the access code is 787605272. At this time, the Court does not expect to hear live testimony. If that changes, the public line will not be available for that testimony. Signed by Judge Ana C. Reyes on 02/15/2025. (lcacr2)

Unopposed MOTION for Leave to File Supplemental Declaration of Gilbert R. Cisneros Jr. by NICOLAS TALBOTT, ERICA VANDAL, KATE COLE, GORDON HERRERO, DANY DANRIDGE, JAMIE HASH, KODA NATURE, CAEL NEARY, MIRIAM PERELSON. (Attachments: # 1 Exhibit, # 2 Text of Proposed Order)(Kropf, Sara) (Entered: 02/16/2025)

1 Exhibit

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2 Text of Proposed Order

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MINUTE ORDER. Upon consideration of Plaintiffs' 53 Unopposed Motion for Leave to File the Supplemental Declaration of Gilbert R. Cisneros, Jr., the Court GRANTS the Motion. Signed by Judge Ana C. Reyes on 02/16/2025. (lcacr2)

NOTICE of Appearance by Inga S. Bernstein on behalf of All Plaintiffs (zdp) (Entered: 02/18/2025)

Minute Entry for proceedings held before Judge Ana C. Reyes: Preliminary Injunction hearing began and held on 2/18/2025. Further Preliminary Injunction Hearing set on 2/19/2025 at 10:30 AM in Courtroom 12- In Person (Audio Line Available) before Judge Ana C. Reyes. (Court Reporter Lisa Edwards.) (zcll)

Status Conference AND ~Util - Set/Reset Hearings

Minute Entry for proceedings held before Judge Ana C. Reyes: Preliminary Injunction hearing began on 2/18/2025. Preliminary Injunction Hearing continued to 2/19/2025 at 10:30 AM in Courtroom 12- In Person (Audio Line Available) before Judge Ana C. Reyes. (Court Reporter Lisa Edwards.) (zcll)

Minute Entry for proceedings held before Judge Ana C. Reyes: Continued Preliminary Injunction hearing held on 2/19/2025. Further Preliminary Injunction Hearing set for 3/3/2025 at 10:30 AM in Courtroom 12- In Person (Audio Line Available) before Judge Ana C. Reyes. (Court Reporter Lisa Edwards.) (zcll)

Status Conference AND ~Util - Set/Reset Deadlines/Hearings