Case: Mennonite Church USA v. U.S. Department of Homeland Security

United States Department of Homeland Security

COMPLAINT against All Defendants ( Filing fee $ 405 receipt number ADCDC-11470854) filed by RHODE ISLAND STATE COUNCIL OF CHURCHES, CONVENCION BAUTISTA HISPANA DE TEXAS, WISCONSIN COUNCIL OF CHURCHES, AFRICAN METHODIST EPISCOPAL ZION CHURCH, NORTH CAROLINA COUNCIL OF CHURCHES, MENNONITE CHURCH USA, NORTH GEORGIA CONFERENCE OF THE UNITED METHODIST CHURCH, NEW YORK STATE COUNCIL OF CHURCHES, WISDOM, INC., WESTERN NORTH CAROLINA CONFERENCE OF THE UNITED METHODIST CHURCH, MASSACHUSETTS COUNCIL OF CHURCHES, RECONSTRUCTING JUDAISM, UNITED SYNAGOGUE OF CONSERVATIVE JUDAISM, FRIENDS GENERAL CONFERENCE, GENERAL ASSEMBLY OF THE PRESBYTERIAN CHURCH (U.S.A.), UNION FOR REFORM JUDAISM, LATINO CHRISTIAN NATIONAL NETWORK, UNITARIAN UNIVERSALIST ASSOCIATION, CHURCH OF THE BRETHREN, CENTRAL ATLANTIC CONFERENCE UNITED CHURCH OF CHRIST, FELLOWSHIP SOUTHWEST, GENERAL COMMISSION ON RELIGION AND RACE OF THE UNITED METHODIST CHURCH, NEW YORK ANNUAL CONFERENCE OF THE UNITED METHODIST CHURCH, EPISCOPAL CHURCH, CENTRAL CONFERENCE OF AMERICAN RABBIS, RABBINICAL ASSEMBLY, CHRISTIAN CHURCH (DISCIPLES OF CHRIST). (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Civil Cover Sheet, # 8 Summons, # 9 Summons, # 10 Summons, # 11 Summons, # 12 Summons, # 13 Summons)(Corkran, Kelsi) (Entered: 02/11/2025)

1 Exhibit 1

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2 Exhibit 2

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3 Exhibit 3

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4 Exhibit 4

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5 Exhibit 5

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6 Exhibit 6

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7 Civil Cover Sheet

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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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13 Summons

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Notice of Error- New Case

Case Assigned/Reassigned

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by FRIENDS GENERAL CONFERENCE, GENERAL ASSEMBLY OF THE PRESBYTERIAN CHURCH (U.S.A.), GENERAL COMMISSION ON RELIGION AND RACE OF THE UNITED METHODIST CHURCH, LATINO CHRISTIAN NATIONAL NETWORK, MASSACHUSETTS COUNCIL OF CHURCHES, NEW YORK ANNUAL CONFERENCE OF THE UNITED METHODIST CHURCH, NEW YORK STATE COUNCIL OF CHURCHES, NORTH CAROLINA COUNCIL OF CHURCHES, NORTH GEORGIA CONFERENCE OF THE UNITED METHODIST CHURCH, RABBINICAL ASSEMBLY, MENNONITE CHURCH USA, RECONSTRUCTING JUDAISM, RHODE ISLAND STATE COUNCIL OF CHURCHES, UNION FOR REFORM JUDAISM, UNITARIAN UNIVERSALIST ASSOCIATION, UNITED SYNAGOGUE OF CONSERVATIVE JUDAISM, WESTERN NORTH CAROLINA CONFERENCE OF THE UNITED METHODIST CHURCH, WISCONSIN COUNCIL OF CHURCHES, WISDOM, INC., AFRICAN METHODIST EPISCOPAL ZION CHURCH, CENTRAL ATLANTIC CONFERENCE UNITED CHURCH OF CHRIST, CENTRAL CONFERENCE OF AMERICAN RABBIS, CHRISTIAN CHURCH (DISCIPLES OF CHRIST), CHURCH OF THE BRETHREN, CONVENCION BAUTISTA HISPANA DE TEXAS, EPISCOPAL CHURCH, FELLOWSHIP SOUTHWEST (Corkran, Kelsi) (Entered: 02/11/2025)

NOTICE of Appearance by Kelsi B. Corkran on behalf of All Plaintiffs (Corkran, Kelsi) (Main Document 3 replaced on 2/11/2025) (znmw). (Entered: 02/11/2025)

NOTICE of Appearance by Alexandra Lichtenstein on behalf of All Plaintiffs (Lichtenstein, Alexandra) (Entered: 02/11/2025)

NOTICE of Appearance by Shelby Bradford Calambokidis on behalf of All Plaintiffs (Calambokidis, Shelby) (Entered: 02/11/2025)

NOTICE OF NEW CASE ERROR regarding 1 Complaint. The following error(s) need correction: Attorney Kelsi Corkran is not an Active bar member. Please refer to the court website for Bar Status Lookup, Attorney Admissions, and Renewal Information at www.dcd.uscourts.gov/attorneys. COMPLIANCE DEADLINE is by close of business today. This case will not proceed any further until all errors are satisfied. (znmw) Modified on 2/11/2025 (znmw).

RESOLVED.....NOTICE OF NEW CASE ERROR regarding 1 Complaint. The following error(s) need correction: Attorney Kelsi Corkran is not an Active bar member. Please refer to the court website for Bar Status Lookup, Attorney Admissions, and Renewal Information at www.dcd.uscourts.gov/attorneys. COMPLIANCE DEADLINE is by close of business today. This case will not proceed any further until all errors are satisfied. (znmw) Modified on 2/11/2025 (znmw). Modified on 2/11/2025 (zhcn).

Case Assigned to Judge Dabney L. Friedrich. (znmw)

SUMMONS (6) Issued Electronically as to All Defendants. (Attachments: # 1 Notice and Consent)(znmw) (Entered: 02/11/2025)

NOTICE OF NEW CASE ERROR regarding 1 Complaint. 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. (znmw)

REQUEST FOR SUMMONS TO ISSUE filed by ALL PLAINTIFFS.(Lichtenstein, Alexandra) (Entered: 02/11/2025)

SUMMONS (2) Issued Electronically as to U.S. Attorney and U.S. Attorney General (mg) (Entered: 02/12/2025)

STANDARD ORDER for Civil Cases. See text for details. Signed by Judge Dabney L. Friedrich on February 12, 2025. (lcdlf1) (Entered: 02/12/2025)

Joint MOTION for Scheduling Order by ALL PLAINTIFFS. (Attachments: # 1 Text of Proposed Order)(Corkran, Kelsi) (Entered: 02/21/2025)

1 Text of Proposed Order

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MOTION for Preliminary Injunction by ALL PLAINTIFFS. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order, # 3 Declaration Index, # 4 Exhibit 1, # 5 Exhibit 2, # 6 Exhibit 3, # 7 Exhibit 4, # 8 Exhibit 5, # 9 Exhibit 6, # 10 Exhibit 7, # 11 Exhibit 8, # 12 Exhibit 9, # 13 Exhibit 10, # 14 Exhibit 11, # 15 Exhibit 12, # 16 Exhibit 13, # 17 Exhibit 14, # 18 Exhibit 15, # 19 Exhibit 16, # 20 Exhibit 17, # 21 Exhibit 18, # 22 Exhibit 19, # 23 Exhibit 20, # 24 Exhibit 21, # 25 Exhibit 22, # 26 Exhibit 23, # 27 Exhibit 24, # 28 Exhibit 25, # 29 Exhibit 26, # 30 Exhibit 27, # 31 Exhibit 28, # 32 Exhibit 29, # 33 Exhibit 30, # 34 Exhibit 31, # 35 Exhibit 32, # 36 Exhibit 33, # 37 Exhibit 34, # 38 Exhibit 35, # 39 Exhibit 36, # 40 Exhibit 37, # 41 Exhibit 38, # 42 Exhibit 39, # 43 Exhibit 40, # 44 Exhibit 41, # 45 Exhibit 42, # 46 Exhibit 43, # 47 Exhibit 44, # 48 Exhibit 45, # 49 Exhibit 46, # 50 Exhibit 47, # 51 Exhibit 48, # 52 Exhibit 49, # 53 Exhibit 50, # 54 Exhibit 51, # 55 Exhibit 52, # 56 Exhibit 53, # 57 Exhibit 54, # 58 Exhibit 55, # 59 Exhibit 56, # 60 Exhibit 57, # 61 Exhibit 58, # 62 Exhibit 59, # 63 Exhibit 69, # 64 Exhibit 61, # 65 Exhibit 62, # 66 Exhibit 63, # 67 Exhibit 64, # 68 Exhibit 65, # 69 Exhibit 66)(Corkran, Kelsi) (Entered: 02/21/2025)

1 Memorandum in Support

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2 Text of Proposed Order

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3 Declaration Index

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4 Exhibit 1

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5 Exhibit 2

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6 Exhibit 3

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7 Exhibit 4

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8 Exhibit 5

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9 Exhibit 6

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10 Exhibit 7

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11 Exhibit 8

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12 Exhibit 9

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13 Exhibit 10

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14 Exhibit 11

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15 Exhibit 12

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16 Exhibit 13

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17 Exhibit 14

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18 Exhibit 15

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19 Exhibit 16

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20 Exhibit 17

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21 Exhibit 18

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22 Exhibit 19

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24 Exhibit 21

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25 Exhibit 22

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26 Exhibit 23

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27 Exhibit 24

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28 Exhibit 25

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29 Exhibit 26

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30 Exhibit 27

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31 Exhibit 28

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32 Exhibit 29

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33 Exhibit 30

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34 Exhibit 31

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35 Exhibit 32

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36 Exhibit 33

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37 Exhibit 34

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38 Exhibit 35

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40 Exhibit 37

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42 Exhibit 39

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43 Exhibit 40

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44 Exhibit 41

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45 Exhibit 42

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46 Exhibit 43

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47 Exhibit 44

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48 Exhibit 45

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49 Exhibit 46

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50 Exhibit 47

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51 Exhibit 48

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52 Exhibit 49

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53 Exhibit 50

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54 Exhibit 51

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55 Exhibit 52

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56 Exhibit 53

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57 Exhibit 54

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58 Exhibit 55

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59 Exhibit 56

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60 Exhibit 57

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61 Exhibit 58

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62 Exhibit 59

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63 Exhibit 69

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64 Exhibit 61

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65 Exhibit 62

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66 Exhibit 63

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67 Exhibit 64

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68 Exhibit 65

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69 Exhibit 66

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Order on Motion for Scheduling Order AND Set/Reset Deadlines

MINUTE ORDER granting the 10 Motion for Scheduling Order. The defendants shall file their response to the plaintiffs' 10 Motion for Preliminary Injunction on or before March 14, 2025; and the plaintiff shall file their reply on or before March 24, 2025. The Courtroom Deputy will contact the parties to schedule a motions hearing on April 2, 3, or 4. So Ordered by Judge Dabney L. Friedrich on February 24, 2025. (lcdlf1)

NOTICE of Appearance by Kristina Ann Wolfe on behalf of All Defendants (Wolfe, Kristina) (Entered: 02/25/2025)

NOTICE of Hearing: Preliminary Injunction Hearing set for 4/4/2025 at 10:00 AM in Courtroom 24A (In Person) before Judge Dabney L. Friedrich. (smc)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Julia Gegenheimer, Filing fee $ 100, receipt number ADCDC-11504948. Fee Status: Fee Paid. by ALL PLAINTIFFS. (Attachments: # 1 Exhibit Declaration of Julia Gegenheimer and Certificate of Good Standing, # 2 Text of Proposed Order)(Calambokidis, Shelby) (Entered: 02/26/2025)

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER granting the 13 Motion for Leave to Appear Pro Hac Vice. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. So Ordered by Judge Dabney L. Friedrich on February 26, 2025. (lcdlf1)

NOTICE of Appearance by Julia Gegenheimer on behalf of All Plaintiffs (Gegenheimer, Julia) (Entered: 02/26/2025)

Order on Motion for Leave to Appear Pro Hac Vice

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Kate Talmor, Filing fee $ 100, receipt number ADCDC-11509597. Fee Status: Fee Paid. by ALL PLAINTIFFS. (Attachments: # 1 Exhibit Declaration of Kate Talmor and Certificate of Good Standing, # 2 Text of Proposed Order)(Lichtenstein, Alexandra) Modified docket text on 3/4/2025 (mg). (Entered: 03/04/2025)

MINUTE ORDER granting the 15 Motion for Leave to Appear Pro Hac Vice. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. So Ordered by Judge Dabney L. Friedrich on March 4, 2025. (lcdlf1)

Memorandum in opposition to re 11 Motion for Preliminary Injunction,,,,, filed by U.S. DEPARTMENT OF HOMELAND SECURITY, KRISTI NOEM, U.S. CUSTOMS AND BORDER PROTECTION, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, CALEB VITELLO. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Text of Proposed Order)(Wolfe, Kristina) (Entered: 03/14/2025)

Order on Motion for Leave to File Amicus Brief

MINUTE ORDER granting the 17 Unopposed Motion for Leave to File Amici Curiae Brief. The Clerk of Court is directed to file the [17-1] Brief of Immigration Reform Law Institute on the docket. So Ordered by Judge Dabney L. Friedrich on March 19, 2025. (lcdlf1) Modified to correct chambers error on 3/20/2025 (smc).

Notice of Provisional/Government Not Certified Status

Unopposed MOTION for Leave to File Amicus Brief in support of Defendants by IMMIGRATION REFORM LAW INSTITUTE. (Attachments: # 1 Exhibit amicus brief, # 2 Exhibit proposed order)(Hajec, Christopher) (Entered: 03/19/2025)

NOTICE of Provisional/Government Not Certified Status re 17 Unopposed MOTION for Leave to File Amicus Brief in support of Defendants by IMMIGRATION REFORM LAW INSTITUTE. (Attachments: # 1 Exhibit amicus brief, # 2 Exhibit proposed order)(Hajec, Christopher).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 3/26/2025. (zhcn)

RESOLVED.....NOTICE of Provisional/Government Not Certified Status re 17 Unopposed MOTION for Leave to File Amicus Brief in support of Defendants by IMMIGRATION REFORM LAW INSTITUTE. (Attachments: # 1 Exhibit amicus brief, # 2 Exhibit proposed order)(Hajec, Christopher).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 3/26/2025. (zhcn) 3/21/2025 (zapb).

AMICUS BRIEF by IMMIGRATION REFORM LAW INSTITUTE. (mg) (Entered: 03/20/2025)

NOTICE of Proposed Order for Preliminary Injunction by ALL PLAINTIFFS re 11 MOTION for Preliminary Injunction (Attachments: # 1 Text of Proposed Order)(Gegenheimer, Julia) (Entered: 03/20/2025)

1 Text of Proposed Order

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Notice of Provisional/Government Not Certified Status

REPLY to opposition to motion re 11 Motion for Preliminary Injunction,,,,, filed by ALL PLAINTIFFS. (Corkran, Kelsi) (Entered: 03/24/2025)

NOTICE of Appearance by Kate Talmor on behalf of All Plaintiffs (Talmor, Kate) (Entered: 03/25/2025)

Unopposed MOTION for Order Providing Remote Public Access to Courtroom Audio for the April 4, 2025 Hearing by ALL PLAINTIFFS. (Attachments: # 1 Text of Proposed Order)(Gegenheimer, Julia) (Entered: 03/25/2025)

1 Text of Proposed Order

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.Order

Order on Motion for Order

MINUTE ORDER granting the 22 Motion for Order Providing Remote Public Access. The docket will be updated to provide the public dial-in line for the hearing of April 4, 2025. So Ordered by Judge Dabney L. Friedrich on March 26, 2025. (lcdlf1)

MINUTE ORDER: The court will provide access for the public to telephonically attend the hearing scheduled for April 4, 2025, at 10:00 AM. The hearing can be accessed by dialing the Toll-Free Number: 833-990-9400 (Meeting ID: 117076001). 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 any court proceedings (including those held by telephone or videoconference). 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. Signed by Judge Dabney L. Friedrich on 3/26/2025. (smc)

Order

LEAVE TO FILE DENIED- Jonah the Tishbite Motion to Intervene. This document is unavailable as the Court denied its filing. Pro Se party has been notified by first class mail. "Leave to file DENIED. The putative intervenor has not established that he is entitled to intervene as of right, or that he qualifies for permissive intervention, under Federal Rule of Civil Procedure 24(a), (b)." Signed by Judge Dabney L. Friedrich on 3/31/2025. (mg) (Entered: 04/01/2025)

NOTICE of Corrected Declarations by ALL PLAINTIFFS (Attachments: # 1 Declaration, # 2 Declaration)(Gegenheimer, Julia) (Entered: 04/02/2025)

NOTICE of Filing of Proof of Service/Summons Executed by ALL PLAINTIFFS (Attachments: # 1 Declaration, # 2 Exhibit USPS Tracking Delivery Confirmations)(Gegenheimer, Julia) (Entered: 04/03/2025)

1 Declaration

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2 Exhibit USPS Tracking Delivery Confirmations

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Motion Hearing

Minute Entry for Motion Hearing held on 4/4/2025 before Judge Dabney L. Friedrich: re 11 MOTION for Preliminary Injunction. Oral arguments heard and TAKEN UNDER ADVISEMENT. Court Reporter: Sara Wick. (smc)

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

Unopposed MOTION to Clarify re Order on Motion for Scheduling Order,, Set/Reset Deadlines, by PETE R. FLORES, KRISTI NOEM, U.S. CUSTOMS AND BORDER PROTECTION, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, CALEB VITELLO. (Attachments: # 1 Text of Proposed Order)(Wolfe, Kristina) (Entered: 04/09/2025)

1 Text of Proposed Order

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Order on Motion to Clarify

MINUTE ORDER granting the 27 Unopposed Motion to Clarify. It is ordered that all filing deadlines, case management obligations, and discovery are STAYED pending resolution of plaintiffs' 11 Motion for a Preliminary Injunction. This stay applies, without limitation, to defendants' response to plaintiffs' complaint, the attorney conference required pursuant to Federal Rule of Civil Procedure 26(f); the issuance of a scheduling order pursuant to Federal Rule of Civil Procedure 16(b); initial disclosure obligations pursuant to Rule 26(a)(1); and all other written, documentary, and oral discovery. The stay is entered without prejudice to either party moving to lift the stay. So Ordered by Judge Dabney L. Friedrich on April 9, 2025. (lcdlf1)

ORDER denying the 11 Motion for Preliminary Injunction. See text for details. Signed by Judge Dabney L. Friedrich on April 11, 2025. (lcdlf1) (Entered: 04/11/2025)

MEMORANDUM OPINION regarding the 11 Motion for Preliminary Injunction. See text for details. Signed by Judge Dabney L. Friedrich on April 11, 2025. (lcdlf1) (Entered: 04/11/2025)

REQUEST FOR LEAVE TO FILE REVIEW. The attached document requires leave to file: Motion to Intervene; Jonah the Tishbite.. Reason(s): Filer is not a party to the case. (Attachments: # 1 Exhibit Part 1 of 2, # 2 Exhibit Part 2 of 2) (zdp) (Entered: 04/18/2025)