Case: American Civil Liberties Union of Michigan v. U.S. Immigration and Customs Enforcement

COMPLAINT against DIRECTOR OF U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, SECRETARY OF U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT ( Filing fee $ 405 receipt number ADCDC-11421625) filed by AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN. (Attachments: # 1 Index of Exhibits, # 2 Exhibit A, # 3 Exhibit B, # 4 Civil Cover Sheet, # 5 Summons --ICE, # 6 Summons --Director of ICE, # 7 Summons --DHS, # 8 Summons --Secretary of DHS, # 9 Summons --US AG, # 10 Summons --DC US Attorney)(Cho, Eunice) (Attachment 4 replaced on 1/22/2025) (zmtm). (Entered: 01/22/2025)

1 Index of Exhibits

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2 Exhibit A

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3 Exhibit B

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4 Civil Cover Sheet

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5 Summons --ICE

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6 Summons --Director of ICE

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7 Summons --DHS

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8 Summons --Secretary of DHS

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9 Summons --US AG

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10 Summons --DC US Attorney

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Case Assigned/Reassigned

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN (Cho, Eunice) (Entered: 01/22/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Ramis Jamal Wadood, Filing fee $ 100, receipt number ADCDC-11421877. Fee Status: Fee Paid. by AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN. (Attachments: # 1 Declaration of Ramis J. Wadood, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Cho, Eunice) (Entered: 01/22/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Daniel S. Korobkin, Filing fee $ 100, receipt number ADCDC-11421927. Fee Status: Fee Paid. by AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN. (Attachments: # 1 Declaration of Daniel S. Korobkin, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Cho, Eunice) (Entered: 01/22/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Philip Edwin Mayor, Filing fee $ 100, receipt number ADCDC-11421957. Fee Status: Fee Paid. by AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN. (Attachments: # 1 Declaration of Philip E. Mayor, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Cho, Eunice) (Entered: 01/22/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Kyle Virgien, Filing fee $ 100, receipt number ADCDC-11422092. Fee Status: Fee Paid. by AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN. (Attachments: # 1 Declaration of Kyle Virgien, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Cho, Eunice) (Entered: 01/22/2025)

Case Assigned to Judge Amir H. Ali. (zmtm)

SUMMONS (6) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zmtm) (Entered: 01/22/2025)

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER granting 3 motion for leave to appear pro hac vice. Attorney Ramis J. Wadood 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 Amir H. Ali on 1/27/2025. (lcaha2)

MINUTE ORDER granting 4 motion for leave to appear pro hac vice. Attorney Daniel S. Korobkin 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 Amir H. Ali on 1/27/2025. (lcaha2)

MINUTE ORDER granting 5 motion for leave to appear pro hac vice. Attorney Philip E. Mayor 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 Amir H. Ali on 1/27/2025. (lcaha2)

MINUTE ORDER granting 6 motion for leave to appear pro hac vice. Attorney Kyle Virgien 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 Amir H. Ali on 1/27/2025. (lcaha2)

NOTICE of Appearance by Kyle A. Virgien on behalf of AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN (Virgien, Kyle) (Entered: 01/30/2025)

NOTICE of Appearance by Ramis Jamal Wadood on behalf of All Plaintiffs (Wadood, Ramis) (Entered: 02/04/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 2/3/2025., RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. DIRECTOR OF U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT served on 1/30/2025; U.S. DEPARTMENT OF HOMELAND SECURITY served on 1/30/2025; U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT served on 1/30/2025. (See docket entry [12] to view document) (mg)

NOTICE of Appearance by Philip Mayor on behalf of All Plaintiffs (Mayor, Philip) (Entered: 02/04/2025)

NOTICE of Appearance by Daniel Korobkin on behalf of All Plaintiffs (Korobkin, Daniel) (Entered: 02/04/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 2/3/2025. Answer due for ALL FEDERAL DEFENDANTS by 3/5/2025. (Attachments: # 1 Affidavit of Mailing)(Cho, Eunice) (Entered: 02/04/2025)

1 Affidavit of Mailing

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- My Khanh Ngo, Filing fee $ 100, receipt number ADCDC-11456348. Fee Status: Fee Paid. by AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN. (Attachments: # 1 Declaration of My Khanh Ngo, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Cho, Eunice) (Entered: 02/04/2025)

1 Declaration of My Khanh Ngo

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2 Certificate of Good Standing

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3 Text of Proposed Order

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Spencer Amdur, Filing fee $ 100, receipt number ADCDC-11456383. Fee Status: Fee Paid. by AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN. (Attachments: # 1 Declaration of Spencer Amdur, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Cho, Eunice) (Entered: 02/04/2025)

1 Declaration of Spencer Amdur

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2 Certificate of Good Standing

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3 Text of Proposed Order

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STANDING ORDER. The parties are ordered to comply with the directives set forth in the attached standing order. See document for details. Signed by Judge Amir H. Ali on 2/5/2025. (lcaha2) (Entered: 02/05/2025)

Summons Returned Executed as to Federal Defendant AND Summons Returned Executed as to U.S. Attorney General

MINUTE ORDER granting 13 motion for leave to appear pro hac vice. Attorney My Khanh Ngo 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 Amir H. Ali on 2/6/2025. (lcaha2)

MINUTE ORDER granting 14 motion for leave to appear pro hac vice. Attorney Spencer Amdur 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 Amir H. Ali on 2/6/2025. (lcaha2)

NOTICE of Appearance by My Khanh Ngo on behalf of AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN (Ngo, My Khanh) (Entered: 02/06/2025)

NOTICE of Appearance by Spencer Elijah Wittmann Amdur on behalf of AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN (Amdur, Spencer) (Entered: 02/06/2025)

Consent MOTION for Extension of Time to Respond to the Complaint by U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, DIRECTOR OF U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, U.S. DEPARTMENT OF HOMELAND SECURITY, SECRETARY OF U.S. DEPARTMENT OF HOMELAND SECURITY. (Attachments: (1) Text of Proposed Order)(Escher, Sam)

1 Text of Proposed Order

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MINUTE ORDER. Defendants' 19 consent motion for an extension of time to respond to the complaint is granted. Defendants shall respond to the complaint by May 9, 2025. Signed by Judge Amir H. Ali on 3/21/2025. (lcaha2)

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

NOTICE OF WITHDRAWAL OF APPEARANCE as to AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN. Attorney Daniel Korobkin terminated.(Attachments: # 1 Text of Proposed Order Proposed Order Grt Motion to Withdraw)(Korobkin, Daniel) Modified event on 5/1/2025 (mg). (Entered: 04/30/2025)

1 Text of Proposed Order Proposed Order Grt Motion to Withdraw

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MOTION to Dismiss by DIRECTOR OF U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, SECRETARY OF U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT. (Attachments: # 1 Stipulated Order in Michigan Case, # 2 Text of Proposed Order)(Escher, Sam) (Entered: 05/09/2025)

1 Stipulated Order in Michigan Case

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2 Text of Proposed Order

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Consent MOTION for Extension of Time to File Response/Reply as to 21 MOTION to Dismiss by AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN. (Attachments: # 1 Text of Proposed Order)(Wadood, Ramis) (Entered: 05/13/2025)

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. Plaintiffs' 22 consent motion for an extension of briefing deadlines is granted. Plaintiffs shall file their opposition to the 21 motion to dismiss by July 3, 2025. Defendants shall file their reply by July 31, 2025. Signed by Judge Amir H. Ali on 5/13/2025. (lcaha2)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Bonsitu Kitaba-Gaviglio, Filing fee $ 100, receipt number ADCDC-11774177. Fee Status: Fee Paid. by AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN. (Attachments: (1) Declaration Bonsitu Kitaba-Gaviglio, (2) Supplement Certificate of Good Standing, (3) Text of Proposed Order)(Cho, Eunice)

1 Declaration Bonsitu Kitaba-Gaviglio

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2 Supplement Certificate of Good Standing

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3 Text of Proposed Order

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MINUTE ORDER granting 23 motion for leave to appear pro hac vice. Attorney Bonsitu Kitaba-Gaviglio 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 Amir H. Ali on 6/24/2025. (lcaha2)

NOTICE of Appearance by Bonsitu Kitaba on behalf of All Plaintiffs (Kitaba, Bonsitu)

Memorandum in opposition to re [21] MOTION to Dismiss filed by AMERICAN CIVIL LIBERTIES UNION FUND OF MICHIGAN, AMERICAN CIVIL LIBERTIES UNION OF MICHIGAN. (Wadood, Ramis)

REPLY to opposition to motion re [21] Motion to Dismiss, filed by DIRECTOR OF U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, SECRETARY OF U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT. (Escher, Sam)