Case: Pars Equality Center v. Blinken

COMPLAINT for Declaratory and Injunctive Relief and Petition for Writ of Mandamus against All Defendants ( Filing fee $ 405, receipt number ACANDC-18980160.). Filed by Zahraneda Momenyghehi, Romina Jafari, Sima Jalilisalek, Nasim Asadi Manesh, Maryam Agharamezan Sangtarash, Mona Sadat Sadati, Ehsan Behrouzzadeh, Pars Equality Center, Seyed Ghasem Sadati, Foziyeh Kabodi, Hanieh Ansari, Aryan Salehinasab, Amirhossein Salehinasab, Fatemeh Mirzaei, Tofigh Zafarmand, Masoud Rismanbaf, Roya Khadem, Abbas Jafar Ali Jassebi, Shahram Jafari, Ferra Cummings, Padideh Moghaddam, Mohammadreza Zafarmand, Ali Zafarmand, Soodabeh Rabbani, Mehrdad Forghani, Tahereh Gharibi Khoshkar, Elnaz Khaksar, Mahmoud Sabouniaghdam, Fahimeh Jafarali Jasbi, Ali Moghadam, Ali H. Karimkhan, Mohammad Reza Asadi Manesh, Melina Sabouniaghdam, Navid Baradaranfallahkhair, Radin Jafari, Mojgan Akbari, Shabnam Zafarmand, Abdolreza Baradaran Fallahkhair. (Attachments: # 1 Exhibit A 82 FR 20956, # 2 Exhibit B 9 FAM 304.5-9(D) as of October 12, 2021, # 3 Exhibit C 9 FAM 504.11-2(A), # 4 Exhibit D US Embassy Mumbai, DS-5535, # 5 Exhibit E US Embassy Ankara answer to general question, # 6 Exhibit F U.S. Virtual Embassy Iran AP Estimation, # 7 Exhibit G US Embassy Abu Dhabi Automatic reply, # 8 Exhibit H US Embassy Abu Dhabi, United Arab Emirates ABD, # 9 Exhibit I US Embassy Ankara - After the Interview, # 10 Exhibit J CEAC Online Case Statuses as of January 1, 2024, # 11 Exhibit K Medical Hardship, # 12 Civil Cover Sheet)(Morrison, Curtis) (Filed on 1/1/2024) (Entered: 01/01/2024)

Case assigned to Judge Susan Illston. Counsel for plaintiff or the removing party is responsible for serving the Complaint or Notice of Removal, Summons and the assigned judge's standing orders and all other new case documents upon the opposing parties. For information, visit E-Filing A New Civil Case at http://cand.uscourts.gov/ecf/caseopening.Standing orders can be downloaded from the court's web page at www.cand.uscourts.gov/judges. Upon receipt, the summons will be issued and returned electronically. A scheduling order will be sent by Notice of Electronic Filing (NEF) within two business days. Consent/Declination due by 1/16/2024. (anj, COURT STAFF) (Filed on 1/2/2024) (Entered: 01/02/2024)

Immigration Mandamus Case Procedural Order. (krp, COURT STAFF) (Filed on 1/2/2024) (Entered: 01/02/2024)

Proposed Summons. (Morrison, Curtis) (Filed on 1/2/2024) (Entered: 01/02/2024)

ERRATA re 1 Complaint,,,,,, by Mojgan Akbari, Hanieh Ansari, Navid Baradaranfallahkhair, Ehsan Behrouzzadeh, Ferra Cummings, Abdolreza Baradaran Fallahkhair, Mehrdad Forghani, Radin Jafari, Romina Jafari, Shahram Jafari, Sima Jalilisalek, Fahimeh Jafarali Jasbi, Abbas Jafar Ali Jassebi, Foziyeh Kabodi, Ali H. Karimkhan, Roya Khadem, Elnaz Khaksar, Tahereh Gharibi Khoshkar, Mohammad Reza Asadi Manesh, Nasim Asadi Manesh, Fatemeh Mirzaei, Ali Moghadam, Padideh Moghaddam, Zahraneda Momenyghehi, Pars Equality Center, Soodabeh Rabbani, Masoud Rismanbaf, Mahmoud Sabouniaghdam, Melina Sabouniaghdam, Mona Sadat Sadati, Seyed Ghasem Sadati, Amirhossein Salehinasab, Aryan Salehinasab, Maryam Agharamezan Sangtarash, Ali Zafarmand, Mohammadreza Zafarmand, Shabnam Zafarmand, Tofigh Zafarmand. (Attachments: # 1 Errata corrected pages 4 and 41)(Morrison, Curtis) (Filed on 1/2/2024) (Entered: 01/02/2024)

~Util - Case Assigned by Intake

Summons Issued as to Antony J. Blinken, Julie M. Stufft, U.S. Attorney and U.S. Attorney General (sfb, COURT STAFF) (Filed on 1/3/2024) (Entered: 01/03/2024)

NOTICE of Appearance by Caroline McGuire (McGuire, Caroline) (Filed on 1/10/2024) (Entered: 01/10/2024)

NOTICE of Appearance by Victoria Elizabeth Turcios (Turcios, Victoria) (Filed on 1/10/2024) (Entered: 01/10/2024)

SUMMONS Returned Executed by Zahraneda Momenyghehi, Romina Jafari, Sima Jalilisalek, Nasim Asadi Manesh, Maryam Agharamezan Sangtarash, Mona Sadat Sadati, Ehsan Behrouzzadeh, Pars Equality Center, Seyed Ghasem Sadati, Foziyeh Kabodi, Hanieh Ansari, Aryan Salehinasab, Amirhossein Salehinasab, Fatemeh Mirzaei, Tofigh Zafarmand, Masoud Rismanbaf, Roya Khadem, Abbas Jafar Ali Jassebi, Shahram Jafari, Ferra Cummings, Padideh Moghaddam, Mohammadreza Zafarmand, Ali Zafarmand, Soodabeh Rabbani, Mehrdad Forghani, Tahereh Gharibi Khoshkar, Elnaz Khaksar, Mahmoud Sabouniaghdam, Fahimeh Jafarali Jasbi, Ali Moghadam, Ali H. Karimkhan, Mohammad Reza Asadi Manesh, Melina Sabouniaghdam, Navid Baradaranfallahkhair, Radin Jafari, Mojgan Akbari, Shabnam Zafarmand, Abdolreza Baradaran Fallahkhair. All Defendants. (Attachments: # 1 Exhibit)(Morrison, Curtis) (Filed on 1/18/2024) (Entered: 01/18/2024)

MOTION to Dismiss filed by Antony J. Blinken, Julie M. Stufft. Motion to Dismiss Hearing set for 4/19/2024 10:00 AM in San Francisco, - Videoconference Only. Responses due by 3/19/2024. Replies due by 3/26/2024. (Attachments: # 1 Proposed Order, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D)(McGuire, Caroline) (Filed on 3/5/2024) (Entered: 03/05/2024)

ERRATA re 10 MOTION to Dismiss Attaching the correct Exhibit A by Antony J. Blinken, Julie M. Stufft. (Attachments: # 1 Exhibit A)(McGuire, Caroline) (Filed on 3/5/2024) (Entered: 03/05/2024)

OPPOSITION/RESPONSE (re 10 MOTION to Dismiss ) filed byMojgan Akbari, Hanieh Ansari, Navid Baradaranfallahkhair, Ehsan Behrouzzadeh, Ferra Cummings, Abdolreza Baradaran Fallahkhair, Mehrdad Forghani, Radin Jafari, Romina Jafari, Shahram Jafari, Sima Jalilisalek, Fahimeh Jafarali Jasbi, Abbas Jafar Ali Jassebi, Foziyeh Kabodi, Ali H. Karimkhan, Roya Khadem, Elnaz Khaksar, Tahereh Gharibi Khoshkar, Mohammad Reza Asadi Manesh, Nasim Asadi Manesh, Fatemeh Mirzaei, Ali Moghadam, Padideh Moghaddam, Zahraneda Momenyghehi, Pars Equality Center, Soodabeh Rabbani, Masoud Rismanbaf, Mahmoud Sabouniaghdam, Melina Sabouniaghdam, Mona Sadat Sadati, Seyed Ghasem Sadati, Amirhossein Salehinasab, Aryan Salehinasab, Maryam Agharamezan Sangtarash, Ali Zafarmand, Mohammadreza Zafarmand, Shabnam Zafarmand, Tofigh Zafarmand. (Attachments: # 1 Exhibit A, 9 FAM 504.7-2(b), Timeliness of Interview, # 2 Exhibit B, State Dept webpage- Immigrant Visa Prioritization (April 30, 2021), # 3 Exhibit C, Carson Wu Declarations, # 4 Exhibit D, Khan v Blinken, # 5 Exhibit E, Mahmood v. Blinken, # 6 Exhibit F, Raouf v. United States Dep_t of State, # 7 Exhibit G, Akbar v Blinken, # 8 Exhibit H, Salihi v. Blinken)(Morrison, Curtis) (Filed on 3/19/2024) (Entered: 03/19/2024)

REPLY (re 10 MOTION to Dismiss ) filed byAntony J. Blinken, Julie M. Stufft. (McGuire, Caroline) (Filed on 3/26/2024) (Entered: 03/26/2024)

NOTICE of Supplemental Authority in Support of 12 Paintiffs' Opposition to 10 MOTION to Dismiss by Pars Equality Center (Attachments: # 1 Exhibit A, Li v Blinken order)(Morrison, Curtis) (Filed on 4/6/2024) Modified on 4/8/2024 (kmm2, COURT STAFF). (Entered: 04/06/2024)

CLERK'S NOTICE CONTINUING MOTION HEARING & SETTING ZOOM REGISTRATION: The MOTION to Dismiss 10 Hearing is CONTINUED TO 5/10/2024 at 10:00 AM - Videoconference Only before Judge Susan Illston. This proceeding will be held via a Zoom webinar.Webinar Access: All counsel, members of the public, and media may access the webinar information at https://www.cand.uscourts.gov/si MANDATORY REGISTRATION: Advanced notice is required of counsel or parties who wish to be identified by the court as making an appearance or will be participating in the argument at the hearing. A list of names and emails must be sent to the CRD at sicrd@cand.uscourts.gov no later than 5/1/2024 at 2 pm.General Order 58. Persons granted access to court proceedings held by telephone or videoconference are reminded that photographing, recording, and rebroadcasting of court proceedings, including screenshots or other visual copying of a hearing, is absolutely prohibited.Zoom Guidance and Setup: https://www.cand.uscourts.gov/zoom/. Motion Hearing set for 5/10/2024 10:00 AM in San Francisco, - Videoconference Only before Judge Susan Illston. (ec, COURT STAFF) (Filed on 4/10/2024). (This is a text-only entry generated by the court. There is no document associated with this entry.) (Entered: 04/10/2024)

Clerk's Notice AND ~Util - Teleconference Zoom

STIPULATION WITH PROPOSED ORDER to Stay Defendants' Deadline to File a Summary Judgment Motion, Until After the Court Decides Defendants' Motion to Dismiss filed by Antony J. Blinken, Julie M. Stufft, All Plaintiffs (Attachments: # 1 Declaration of Caroline McGuire in support of the Stipulation, # 2 Proposed Order)(McGuire, Caroline) (Filed on 4/16/2024) Modified on 4/17/2024 (kmm2, COURT STAFF). (Entered: 04/16/2024)

Order by Judge Susan Illston granting 16 Stipulation to Stay Summary Judgment Deadline.(ec, COURT STAFF) (Filed on 4/17/2024) (Entered: 04/17/2024)

NOTICE of Voluntary Dismissal (by 8 plaintiffs only) by Navid Baradaranfallahkhair, Abdolreza Baradaran Fallahkhair, Radin Jafari, Romina Jafari, Shahram Jafari, Foziyeh Kabodi, Tahereh Gharibi Khoshkar, Zahraneda Momenyghehi (Morrison, Curtis) (Filed on 5/9/2024) (Entered: 05/09/2024)

NOTICE of Supplemental Authority in Support of 10 Defendants' Motion to Dismiss by Antony J. Blinken, Julie M. Stufft (Attachments: # 1 Exhibit A)(McGuire, Caroline) (Filed on 5/10/2024) Modified on 5/13/2024 (kmm2, COURT STAFF). (Entered: 05/10/2024)

NOTICE of Voluntary Dismissal (by 6 plaintiffs only) by Ehsan Behrouzzadeh, Roya Khadem, Elnaz Khaksar, Amirhossein Salehinasab, Aryan Salehinasab, Maryam Agharamezan Sangtarash (Morrison, Curtis) (Filed on 5/10/2024) (Entered: 05/10/2024)

ORDER FOR PLAINTIFFS TO PROVIDE STATUS UPDATE Status Report due by 5/24/2024.. Signed by Judge Susan Illston on 5/10/2024. (ec, COURT STAFF) (Filed on 5/10/2024) (Entered: 05/10/2024)

Minute Entry for proceedings held via Zoom webinar before Judge Susan Illston: Motion Hearing held on 5/10/2024 re 10 MOTION to Dismiss .Total Time in Court: 24 Minutes. Court Reporter: Marla Knox. Plaintiff Attorney: Curtis Morrison, Paris Scott. Defendant Attorney: Caroline McGuire. (ec, COURT STAFF) (Date Filed: 5/10/2024) Modified on 5/14/2024 (kmm2, COURT STAFF). (Entered: 05/13/2024)

NOTICE of Voluntary Dismissal (by/of 13 Plaintiffs only) by Pars Equality Center (Morrison, Curtis) (Filed on 5/24/2024) (Entered: 05/24/2024)

STATUS REPORT (responsive to Court's order at ECF No. 21) by Pars Equality Center. (Attachments: # 1 Exhibit A, CEAC statuses as of May 24, 2024)(Morrison, Curtis) (Filed on 5/24/2024) (Entered: 05/24/2024)

Second NOTICE of Supplemental Authority in Support of Opposition to 10 MOTION to Dismiss by Pars Equality Center (Attachments: # 1 Exhibit A, Igal v. US Consulate order, # 2 Exhibit B, Afghan and Iraqi Allies opinion)(Morrison, Curtis) (Filed on 6/15/2024) Modified on 6/17/2024 (kmm2, COURT STAFF). (Entered: 06/15/2024)

Second Notice of Supplemental Authority in Support of Their Motion to Dismiss by Antony J. Blinken, Julie M. Stufft re 10 MOTION to Dismiss (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(McGuire, Caroline) (Filed on 7/18/2024) Modified on 7/19/2024 (kmm2, COURT STAFF). (Entered: 07/18/2024)

Response re 26 Second Notice of Supplemental Authority by Pars Equality Center. (Morrison, Curtis) (Filed on 7/18/2024) Modified on 7/19/2024 (kmm2, COURT STAFF). (Entered: 07/18/2024)

Third Notice of Supplemental Authority in Support of 10 MOTION to Dismiss by Antony J. Blinken, Julie M. Stufft (Attachments: # 1 Exhibit A)(McGuire, Caroline) (Filed on 8/7/2024) Modified on 8/7/2024 (kmm2, COURT STAFF). (Entered: 08/07/2024)

Response re 28 Notice (Other) Third Notice of Supplemental Authority by Pars Equality Center. (Attachments: # 1 Exhibit A, Vajjala Kesava v. Garland order, # 2 Exhibit B, Fimbres v. Cohan order)(Morrison, Curtis) (Filed on 8/8/2024) (Entered: 08/08/2024)

Third Notice of Supplemental Authority in Support of Plaintiffs' Opposition to Defendants' Motion to Dismiss by Pars Equality Center (Attachments: # 1 Exhibit A, Iqbal v Blinken MSJ order, # 2 Exhibit B, Durham v Blinken MTD order)(Morrison, Curtis) (Filed on 8/23/2024) Modified on 8/28/2024 (kmm2, COURT STAFF). Modified on 8/28/2024 (kmm2, COURT STAFF). (Entered: 08/23/2024)

NOTICE of Voluntary Dismissal of 2 Plaintiffs only by Ali Moghadam, Padideh Moghaddam (Morrison, Curtis) (Filed on 9/14/2024) (Entered: 09/14/2024)

NOTICE of Voluntary Dismissal of 2 plaintiffs only. by Mehrdad Forghani, Fatemeh Mirzaei (Morrison, Curtis) (Filed on 10/15/2024) (Entered: 10/15/2024)

ORDER GRANTING IN PART AND DENYING IN PART MOTION TO DISMISS granting in part and denying in part 10 Motion to Dismiss. (Illston, Susan) (Filed on 11/5/2024) (Entered: 11/05/2024)

NOTICE by Ali H. Karimkhan, Hanieh Ansari, Mona Sadat Sadati, Seyed Ghasem Sadati re 33 Order on Motion to Dismiss (Morrison, Curtis) (Filed on 11/6/2024) (Entered: 11/06/2024)

TRANSFER ORDER RE: FOUR PLAINTIFFS. Signed by Judge Susan Illston on 11/7/2024.The Court hereby ORDERS that the claims of Ali H. Karimkhan, Haniyeh Ansari, Mona Sadat Sadati, and Seyed Ghasem Sadati are TRANSFERRED to the United States District Court for the District of Columbia. The Clerk shall transmit to the transferee court a copy of the complaint (Dkt. No. 1), this Courts order on the motion to dismiss (Dkt. No. 33), and this transfer order. (ec, COURT STAFF) (Filed on 11/7/2024) (Entered: 11/07/2024)

STIPULATION WITH PROPOSED ORDER Re Proposed Summary Judgment Briefing Schedule Pursuant to ECF Nos. 16, 17, and 33 filed by Antony J. Blinken, Julie M. Stufft. (Attachments: # 1 Proposed Order)(McGuire, Caroline) (Filed on 11/12/2024) Modified on 11/12/2024 (kmm2, COURT STAFF). (Entered: 11/12/2024)

Order by Judge Susan Illston granting 36 Stipulation re: Joint Summary Judgment Schedule.(ec, COURT STAFF) (Filed on 11/12/2024) (Entered: 11/12/2024)

Remark

Remark: Case transferred from California Northern only regarding the claims of Plaintiffs Ali H. Karimkhan, Haniyeh Ansari, Mona Sadat Sadati, and Seyed Ghasem Sadati has been opened in District of Columbia as case 1:24-cv-03169, filed 11/12/2024. (kmm2, COURT STAFF) (Filed on 11/12/2024)

ANSWER to Complaint by Antony J. Blinken, Julie M. Stufft. (Turcios, Victoria) (Filed on 11/22/2024) (Entered: 11/22/2024)

ERRATA re 38 Answer to Complaint by Antony J. Blinken, Julie M. Stufft. (McGuire, Caroline) (Filed on 12/6/2024) (Entered: 12/06/2024)

MOTION for Summary Judgment filed by Abbas Jafar Ali Jassebi, Fahimeh Jafarali Jasbi. Motion for Summary Judgment Hearing set for 1/31/2025 10:00 AM in San Francisco, - Videoconference Only before Judge Susan Illston. Responses due by 1/16/2025. Replies due by 2/15/2025. (Morrison, Curtis) (Filed on 12/17/2024) (Entered: 12/17/2024)

CLERK'S NOTICE CORRECTING BRIEFING SCHEDULE: Pursuant to the Order filed at Dkt. 37 re: 40 MOTION for Summary Judgment Opposition due by 2/15/2025. Replies due by 3/17/2025. Motion hearing date TBD. (ec, COURT STAFF) (Filed on 12/18/2024). (This is a text-only entry generated by the court. There is no document associated with this entry.) (Entered: 12/18/2024)

CLERK'S NOTICE CLARIFYING MOTIONS FOR SUMMARY JUDGMENT DEADLINES: The parties are to review Docket 37 for briefing and filing deadlines concerning the Motion and Cross-Motions for Summary Judgment. (This is a text-only entry generated by the court. There is no document associated with this entry.) (ec, COURT STAFF) (Filed on 12/18/2024) (Entered: 12/18/2024)

Clerk's Notice AND ~Util - Set Motion and Deadlines/Hearings

Clerk's Notice

MOTION for Summary Judgment and Opposition to 40 Plaintiffs' Opening Summary Judgment Motion - Hearing Date TBD per ECF No. 41 filed by Antony J. Blinken, Julie M. Stufft. Responses due by 2/15/2025. Replies due by 3/17/2025. (Attachments: # 1 Exhibit A, # 2 Proposed Order)(McGuire, Caroline) (Filed on 1/16/2025) (Entered: 01/16/2025)

Joint MOTION to Adjust Summary Judgement Briefing schedule as to 37 Order on Stipulation filed by Abbas Jafar Ali Jassebi, Fahimeh Jafarali Jasbi. (Attachments: # 1 Proposed Order)(Morrison, Curtis) (Filed on 2/6/2025) Modified on 2/11/2025 (kxo, COURT STAFF). (Entered: 02/06/2025)

Order by Judge Susan Illston granting 44 Motion for Extension of Time to File Response/Reply.(ec, COURT STAFF) (Filed on 2/7/2025) (Entered: 02/07/2025)

STIPULATION WITH PROPOSED ORDER of Dismissal with Prejudice (FRCP 41(a)) re 1 Complaint filed by Antony J. Blinken, Julie M. Stufft. (Attachments: # 1 Proposed Order)(McGuire, Caroline) (Filed on 2/24/2025) Modified on 2/24/2025 (kmm2, COURT STAFF). (Entered: 02/24/2025)

ORDER OF DISMISSAL WITH PREJUDICE 46 . Signed by Judge Susan Illston on 2/24/2025. (afm, COURT STAFF) (Filed on 2/24/2025) (Entered: 02/24/2025)