Case: American Oversight v. U.S. Department of Efficiency

1:25-cv-00409 | U.S. District Court for the District of District of Columbia

Filed Date: Feb. 11, 2025

Case Ongoing

Clearinghouse coding complete

Case Summary

Freedom of Information Act case against the "Department of Government Efficiency" and the Office of Management and Budget seeking communications involving Elon Musk and his key staff. This case concerns a legal battle over government transparency and access to public records. On February 11, 2025, American Oversight, a nonpartisan nonprofit committed to promoting transparency in government, filed a lawsuit against the U.S. Department of Government Efficiency, the U.S. DOGE Service, the U.S. DOG…

Freedom of Information Act case against the "Department of Government Efficiency" and the Office of Management and Budget seeking communications involving Elon Musk and his key staff.

This case concerns a legal battle over government transparency and access to public records. On February 11, 2025, American Oversight, a nonpartisan nonprofit committed to promoting transparency in government, filed a lawsuit against the U.S. Department of Government Efficiency, the U.S. DOGE Service, the U.S. DOGE Service Temporary Organization, the U.S. Digital Service, and the Office of Management and Budget (OMB) in the United States District Court for the District of Columbia. The lawsuit, brought under the Freedom of Information Act (FOIA), 5 U.S.C. § 552, and the Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 2202, seeks to compel the defendants to produce records related to communications involving Elon Musk and his key staff. American Oversight is represented by in-house counsel, including Elizabeth Haddix and David Kronig. This case is ongoing.

In November 2024, following the U.S. presidential election, then-President-elect Donald Trump announced that Elon Musk would lead a newly formed entity, the Department of Government Efficiency (DOGE). The purpose of this department was initially unclear, with concerns about whether it functioned as a government agency or a private advisory group. On January 20, 2025, Trump issued Executive Order No. 14158, which formally established DOGE and restructured the U.S. Digital Service (USDS) into the U.S. DOGE Service. This order also created a temporary organization within USDS tasked with implementing the administration’s technology and efficiency agenda over the next 18 months. Despite being classified as a government agency under 5 U.S.C. § 552(f)(1), DOGE’s operations were allegedly shrouded in secrecy. Reports surfaced that DOGE officials, including Musk, had gained access to sensitive government systems, engaged in policy decision-making, and issued direct orders to federal employees, raising concerns about executive overreach and unauthorized influence.

On January 30, 2025, American Oversight submitted two FOIA requests to the U.S. DOGE Service and OMB: IG Key Terms Request (Tracking No. OMB-25-0252) – Seeking internal communications related to the sudden removal of inspectors general from 17 federal agencies. IG Communications Request (Tracking No. OMB-25-0253) – Requesting records of communications between DOGE officials and members of Congress regarding these firings.

American Oversight’s complaint alleged that the abrupt terminations of inspectors general across multiple federal agencies raised serious concerns about government integrity and potential misconduct. In response, the organization submitted FOIA requests seeking records related to these dismissals and requested expedited processing under 5 U.S.C. § 552(a)(6)(E)(i). Despite the statutory requirement for a prompt response, the Office of Management and Budget (OMB) acknowledged receipt of the requests on January 31, 2025, but failed to issue a determination within the required timeframe. Meanwhile, between January and early February 2025, officials from the newly established Department of Government Efficiency (DOGE) were reported to have gained unauthorized access to at least 15 federal agencies, including USAID and the Treasury Department. DOGE personnel allegedly froze funding and reduced staffing at USAID, prompting Judge Carl Nichols to issue a temporary injunction on February 7, 2025 (Am. Foreign Service Assoc. v. Trump, 25-cv-352, ECF No. 15). The group also reportedly accessed the Treasury Department’s financial systems, leading to an emergency injunction by Judge Paul Engelmayer, and took control of human resources and financial operations at the Consumer Financial Protection Bureau (CFPB), raising concerns that it was systematically dismantling regulatory agencies. Further compounding transparency concerns, DOGE officials allegedly used encrypted and ephemeral messaging platforms like Signal and Slack, potentially in violation of federal record-keeping laws. In response to these developments, on January 22, 2025, American Oversight sent a formal preservation letter to Elon Musk, reminding him of DOGE’s legal obligations under the Federal Records Act. The complaint alleges that the defendants’ failure to process the FOIA requests in a timely manner violated FOIA regulations.

Through this complaint, American Oversight sought a court order compelling the defendants to expedite processing, a declaratory judgment affirming that the requested records must be disclosed, and injunctive relief to ensure FOIA compliance. Additionally, the plaintiff requests attorneys’ fees and litigation costs under 5 U.S.C. § 552(a)(4)(E).

On March 5, 2025, Judge Beryl A. Howell issued a Standing Order in American Oversight v. U.S. Department of Government Efficiency, et al., Civil Action No. 25-409 (BAH), pending in the United States District Court for the District of Columbia. The order outlines procedural requirements for case management, including deadlines for filings, discovery procedures, and motion practices. It mandates the submission of a Joint Meet and Confer Report within 14 days of the defendants’ answer and sets specific rules for handling FOIA cases, emphasizing judicial efficiency and compliance with procedural obligations. This order signals that the case is actively progressing through its pretrial stages.

The case remains ongoing.

Summary Authors

Karma Karira (2/25/2025)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69630062/parties/oversight-v-efficiency/


Attorney for Plaintiff

Haddix, Elizabeth (District of Columbia)

Kronig, David (District of Columbia)

Attorney for Defendant

Bardo, John (District of Columbia)

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Documents in the Clearinghouse

Document
1

1:25-cv-00409

Complaint

American Oversight v. U.S. Department of Government Efficiency

Feb. 11, 2025

Feb. 11, 2025

Complaint
6

1:25-cv-00409

Standing Order for Civil Cases

March 5, 2025

March 5, 2025

Order/Opinion

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/69630062/oversight-v-efficiency/

Last updated April 21, 2025, 3:57 p.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT by American Oversight against All Defendants ( Filing fee $ 405 receipt number ADCDC-11473030) filed by American Oversight. (Attachments: # 1 Civil Cover Sheet cvr sheet, # 2 Summons USAO summons, # 3 Summons AG Summons, # 4 Summons DOGE Summons, # 5 Summons DOGE Service Summons, # 6 Summons DOGE Service Temp Org summons, # 7 Summons Digital Service summons, # 8 Summons OMB summons)(Haddix, Elizabeth) (Entered: 02/11/2025)

1 Civil Cover Sheet cvr sheet

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2 Summons USAO summons

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3 Summons AG Summons

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4 Summons DOGE Summons

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5 Summons DOGE Service Summons

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6 Summons DOGE Service Temp Org summons

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7 Summons Digital Service summons

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8 Summons OMB summons

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Feb. 11, 2025

Feb. 11, 2025

Clearinghouse
2

AFFIDAVIT re 1 Complaint, Exhibits A-D by American Oversight. (Attachments: # 1 Exhibit Compl Ex A, # 2 Exhibit Compl Ex B, # 3 Exhibit Compl Ex C, # 4 Exhibit Compl Ex D)(Haddix, Elizabeth) (Entered: 02/11/2025)

1 Exhibit Compl Ex A

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2 Exhibit Compl Ex B

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3 Exhibit Compl Ex C

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4 Exhibit Compl Ex D

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Feb. 11, 2025

Feb. 11, 2025

RECAP
3

NOTICE of Appearance by David Kronig on behalf of American Oversight (Kronig, David) (Entered: 02/11/2025)

Feb. 11, 2025

Feb. 11, 2025

PACER

Case Assigned/Reassigned

Feb. 13, 2025

Feb. 13, 2025

PACER

Case Assigned to Judge Beryl A. Howell. (zmtm)

Feb. 13, 2025

Feb. 13, 2025

PACER
4

SUMMONS(7) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zmtm) (Entered: 02/13/2025)

Feb. 13, 2025

Feb. 13, 2025

PACER
5

AMENDED COMPLAINT against All Defendants filed by AMERICAN OVERSIGHT. (Attachments: # 1 Civil Cover Sheet cvr sheet, # 2 Summons USAO summons, # 3 Summons AG Summons, # 4 Summons DOGE Summons, # 5 Summons USDS summons, # 6 Summons DOGE Temp summons, # 7 Summons US Dig Serv Summons, # 8 Summons OMB summons, # 9 Exhibit Ex A, # 10 Exhibit Ex B, # 11 Exhibit Ex C, # 12 Exhibit Ex D, # 13 Exhibit Ex E, # 14 Exhibit Ex F, # 15 Exhibit Ex G, # 16 Exhibit Ex H, # 17 Exhibit Ex I, # 18 Exhibit Ex J, # 19 Exhibit Ex K, # 20 Exhibit Ex L, # 21 Exhibit Ex M, # 22 Exhibit Ex N, # 23 Exhibit Ex O, # 24 Exhibit Ex P)(Haddix, Elizabeth) (Entered: 03/05/2025)

1 Civil Cover Sheet cvr sheet

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2 Summons USAO summons

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3 Summons AG Summons

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4 Summons DOGE Summons

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5 Summons USDS summons

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6 Summons DOGE Temp summons

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7 Summons US Dig Serv Summons

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8 Summons OMB summons

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9 Exhibit Ex A

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10 Exhibit Ex B

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11 Exhibit Ex C

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12 Exhibit Ex D

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13 Exhibit Ex E

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14 Exhibit Ex F

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15 Exhibit Ex G

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16 Exhibit Ex H

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17 Exhibit Ex I

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18 Exhibit Ex J

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19 Exhibit Ex K

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20 Exhibit Ex L

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21 Exhibit Ex M

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22 Exhibit Ex N

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23 Exhibit Ex O

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24 Exhibit Ex P

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March 5, 2025

March 5, 2025

RECAP
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STANDING ORDER. Signed by Judge Beryl A. Howell on March 5, 2025. (lcbah1) (Entered: 03/05/2025)

March 5, 2025

March 5, 2025

Clearinghouse
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RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 3/6/2025. Answer due for ALL FEDERAL DEFENDANTS by 4/5/2025. (Attachments: # 1 Exhibit Ex 1, # 2 Exhibit Ex 2, # 3 Exhibit Ex 2A, # 4 Exhibit Ex 3, # 5 Exhibit Ex 4, # 6 Exhibit Ex 5, # 7 Exhibit Ex 6, # 8 Exhibit Ex 7, # 9 Exhibit Ex 8, # 10 Exhibit Ex 9)(Haddix, Elizabeth) (Entered: 03/17/2025)

March 17, 2025

March 17, 2025

PACER
8

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 3/6/2025., RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. OFFICE OF MANAGEMENT AND BUDGET served on 3/6/2025; U.S. DEPARTMENT OF GOVERNMENT EFFICIENCY served on 3/6/2025; U.S. DIGITAL SERVICE served on 3/6/2025; U.S. DOGE SERVICE served on 3/6/2025; U.S. DOGE SERVICE TEMPORARY ORGANIZATION served on 3/6/2025. (See docket entry 7 to view document) (mg) (Entered: 03/20/2025)

March 17, 2025

March 17, 2025

PACER
9

MOTION for Extension of Time to Respond to the Complaint by U.S. DEPARTMENT OF GOVERNMENT EFFICIENCY, U.S. DOGE SERVICE, U.S. DOGE SERVICE TEMPORARY ORGANIZATION, U.S. DIGITAL SERVICE, OFFICE OF MANAGEMENT AND BUDGET. (Attachments: # 1 Text of Proposed Order)(Bardo, John) (Entered: 03/20/2025)

March 20, 2025

March 20, 2025

PACER

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

March 20, 2025

March 20, 2025

PACER

.Order

March 20, 2025

March 20, 2025

PACER

MINUTE ORDER (paperless), upon consideration of defendants' 9 Motion for Extension of Time ("Defs.' Mot."), which states that plaintiff opposes the relief sought in the motion, id. at 1, DIRECTING plaintiff to file its opposition by 12:00 PM EST on March 21, 2025. Signed by Judge Beryl A. Howell on March 20, 2025. (lcbah1)

March 20, 2025

March 20, 2025

PACER

Set/Reset Deadlines

March 21, 2025

March 21, 2025

PACER

Set/Reset Deadlines: Plaintiff Opposition due no later than 12:00PM on 3/21/2025. (mac)

March 21, 2025

March 21, 2025

PACER
10

Memorandum in opposition to re 9 Motion for Extension of Time to, filed by AMERICAN OVERSIGHT. (Attachments: # 1 Affidavit Haddix Decl, # 2 Exhibit Ex 1, # 3 Exhibit Ex 2, # 4 Exhibit Ex 3)(Haddix, Elizabeth) (Entered: 03/21/2025)

1 Affidavit Haddix Decl

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2 Exhibit Ex 1

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3 Exhibit Ex 2

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4 Exhibit Ex 3

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March 21, 2025

March 21, 2025

PACER
11

NOTICE of Proposed Order by AMERICAN OVERSIGHT re 10 Memorandum in Opposition, filed by AMERICAN OVERSIGHT. (Haddix, Elizabeth) Modified event on 3/24/2025 (mg). (Entered: 03/21/2025)

March 21, 2025

March 21, 2025

RECAP
12

MOTION for Order for Preservation of Documents by AMERICAN OVERSIGHT. (Attachments: # 1 Memorandum in Support, # 2 Declaration Haddix Declaration, # 3 Exhibit Exhibit A to Haddix Decl., # 4 Text of Proposed Order)(Kronig, David) (Entered: 03/24/2025)

1 Memorandum in Support

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2 Declaration Haddix Declaration

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3 Exhibit Exhibit A to Haddix Decl.

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4 Text of Proposed Order

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March 24, 2025

March 24, 2025

RECAP

.Order

March 25, 2025

March 25, 2025

PACER

MINUTE ORDER (paperless), upon consideration of plaintiff's 12 Motion for a Preservation Order, DIRECTING defendants' to file any opposition by 12:00PM EST on March 27, 2025; and FURTHER DIRECTING plaintiff to file any reply in support of its motion by 12:00PM EST on March 28, 2025. Signed by Judge Beryl A. Howell on March 25, 2025. (lcbah1)

March 25, 2025

March 25, 2025

PACER

Set/Reset Deadlines

March 26, 2025

March 26, 2025

PACER

Set/Reset Deadlines: Defendants' Opposition To Plaintiff's Motion For A Preservation Order due no later than 12:00PM on 3/27/2025. Plaintiff Reply In Support Of Its Motion due no later than 12:00PM on 3/28/2025. (mac)

March 26, 2025

March 26, 2025

PACER
13

Memorandum in opposition to re 12 Motion for Order filed by U.S. DEPARTMENT OF GOVERNMENT EFFICIENCY, U.S. DOGE SERVICE, U.S. DOGE SERVICE TEMPORARY ORGANIZATION, U.S. DIGITAL SERVICE, OFFICE OF MANAGEMENT AND BUDGET. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit United States DOGE Service Records Retention Policy)(Bardo, John) (Entered: 03/27/2025)

1 Text of Proposed Order

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2 Exhibit United States DOGE Service Records Retention Policy

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March 27, 2025

March 27, 2025

RECAP
14

REPLY to opposition to motion re 12 Motion for Order for Preservation of Records Responsive to FOIA requests filed by AMERICAN OVERSIGHT. (Haddix, Elizabeth) (Entered: 03/28/2025)

March 28, 2025

March 28, 2025

PACER

Order on Motion for Extension of Time to

April 2, 2025

April 2, 2025

PACER

Order on Motion for Order

April 2, 2025

April 2, 2025

PACER

MINUTE ORDER (paperless) GRANTING plaintiff's American Oversight 12 Motion for a Preservation Order ("Pl.'s Mot.") over defendants' 13 opposition ("Defs.' Opp'n"). "Federal courts have the inherent power to issue orders preserving information relevant to the claims and defenses brought before them." United States ex rel. Staggers v. Medtronic, Inc., No. 1:15-CV-392-TSC-RMM, 2022 WL 4078969, at *2 (D.D.C. Sept. 6, 2022). Plaintiff asks that the Court exercise its inherent authority to issue a preservation order requiring defendants U.S. Department of Government Efficiency, U.S. DOGE Service, U.S. DOGE Service Temporary Organization, U.S. Digital Service (collectively, "DOGE"), (1) "to preserve all records responsive" to all eight of the requests, pursuant to the Freedom of Information Act ("FOIA"), 5 U.S.C. §552, for records at issue in this case, and (2) "disclose whether all such records have been preserved to date." Pl.'s Mot. at 1. Such a preservation order is necessary, plaintiff contends, because "DOGE staff... have used non-governmental, ephemeral messaging systems such as Signal to communicate regarding official matters," id.; "DOGE's record-keeping practices suggest that it may, to date, have been unfamiliar with or indifferent to its preservation obligations," id. at 15; and "DOGE [has] refused to stipulate that it would preserve records responsive to [plaintiff's] requests," id. at 19. In response, defendants disclaim any need for a preservation order because "[DOGE] has already issued a litigation hold in light of plaintiff's complaint," Defs.' Opp'n at 1; "[DOGE] complies with its Presidential Records Act obligations," id.; and "[t]he presumption of Executive Branch officials' good faith require" denial of the motion, id. To the extent that defendants argue that it is not subject to FOIA, 5 U.S.C. § 552 et seq., those arguments go to the underlying merits, see Citizens for Responsibility and Ethics in Washington v. U.S. DOGE Service ("CREW"), No. 25-cv-511, 2025 WL 752367, at *10-13 (D.D.C. Mar. 10, 2025) (holding that DOGE is likely an agency subject to FOIA), rather than DOGE's obligations to preserve documents when litigation is reasonably anticipated or pending. See Fed. R. Civ. P. 37(e); Gerlich v. U.S. Dep't of Justice, 711 F.3d 161, 170-71 (D.C. Cir. 2013) (holding that the duty to preserve begins "when a party should have known that the evidence may be relevant to future litigation" (emphasis in original)). Notwithstanding the fact that DOGE has issued a litigation hold, DOGE personnel "may not fully appreciate their obligations to preserve federal records," under either the FOIA or the Presidential Records Act, as "many of [the] staffers are reported to have joined the federal government only recently and... may not be steeped in its document retention policies," CREW, 2025 WL 752367, at *16-17 (D.D.C. Mar. 10, 2025), which, under FOIA, reaches even those government records stored on private devices, see generally Competitive Enter. Inst. v. Off. of Sci. & Tech. Pol'y, 827 F.3d 145 (D.C. Cir. 2016). Finally, while "the Court presumes that executive officials... act in good faith," "absent a court order punishable by contempt requiring the maintenance and preservation" of potentially responsive records, plaintiff "would have no recourse" were the records at issue not maintained and preserved pursuant only to a litigation hold letter. Citizens for Resp. & Ethics in Wash. v. Off. of Admin., 593 F. Supp. 2d 156, 162 (D.D.C. 2009). Additional concerns arise due to the fact that DOGE "operat[es] with unusual secrecy," which includes the use of "Signal, an encrypted messaging app with an auto-delete function," CREW, 2025 WL 752367, at *16, and has refused to stipulate to its preservation obligations of documents that are at the heart of this litigation, Pl.'s Mot. at 19. See also CREW, 2025 WL 752367, at *16 (noting that DOGE's lack of assurances of compliance with the Federal Records Act was evidence that a preservation order was necessary). Moreover, to the extent that DOGE insists that this entity's compliance with the Presidential Records Act ("PRA"), 44 U.S.C. § 2201 et seq., is sufficient compliance with preservation obligations in this case, Defs.' Opp'n at 1, only confirms plaintiff's concern about the need for a preservation order since the what qualifies as a record and the respective retention obligations differ between the PRA and the FOIA, see generally Armstrong v. Exec. Office of the President, 90 F.3d 553 (D.C. Cir. 1996), U.S. Dep't of Justice v. Tax Analysts, 492 U.S. 136 (1989). At the same time, DOGE's actual compliance with PRA record retention obligations mitigates any burden of DOGE also complying with obligations to preserve records at issue in this case and prevent spoilation of records and information during the pendency of this litigation.Accordingly, plaintiff's motion is GRANTED, and a preservation order will be entered contemporaneously. Signed by Judge Beryl A. Howell on April 2, 2025. (lcbah1)

April 2, 2025

April 2, 2025

PACER

MINUTE ORDER (paperless) GRANTING defendants' 9 Motion for Extension of Time; and DIRECTING defendants to respond to plaintiff's 1 Complaint by April 21, 2025. Signed by Judge Beryl A. Howell on April 2, 2025. (lcbah1)

April 2, 2025

April 2, 2025

PACER
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PRESERVATION ORDER. Signed by Judge Beryl A. Howell on April 2, 2025. (lcbah1) (Entered: 04/02/2025)

April 2, 2025

April 2, 2025

RECAP

Set/Reset Deadlines: Defendants Response To Plaintiff's Complaint due by 4/21/2025. (mac)

April 3, 2025

April 3, 2025

PACER

Set/Reset Deadlines

April 3, 2025

April 3, 2025

PACER

Set/Reset Deadlines: Defendants U.S. Department of Government Efficiency, U.S. DOGE Service, U.S. DOGE Service Temporary Organization, U.S. Digital Service (collectively, "DOGE") Notice To The Court due by 4/7/2025. (mac)

April 3, 2025

April 3, 2025

PACER
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STATUS REPORT by OFFICE OF MANAGEMENT AND BUDGET, U.S. DEPARTMENT OF GOVERNMENT EFFICIENCY, U.S. DIGITAL SERVICE, U.S. DOGE SERVICE, U.S. DOGE SERVICE TEMPORARY ORGANIZATION. (Bardo, John) (Entered: 04/07/2025)

April 7, 2025

April 7, 2025

RECAP
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STATUS REPORT Response by AMERICAN OVERSIGHT. (Haddix, Elizabeth) (Entered: 04/08/2025)

April 8, 2025

April 8, 2025

RECAP

Case Details

State / Territory: District of Columbia

Case Type(s):

Presidential/Gubernatorial Authority

Special Collection(s):

Trump Administration 1.0 & 2.0 FOIA cases

Trump Administration 2.0: Challenges to the Government

Trump Administration 2.0: Challenges to the Government (DOGE Status/Information Access)

Key Dates

Filing Date: Feb. 11, 2025

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

American Oversight is a nonpartisan, nonprofit watchdog organization dedicated to government transparency and accountability.

Plaintiff Type(s):

Non-profit NON-religious organization

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Department of Government Efficiency (- United States (national) -), Federal

U.S. Digital Service (- United States (national) -), Federal

Office of Management and Budget (OMB) (- United States (national) -), Federal

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

Declaratory Judgment Act, 28 U.S.C. § 2201

FOIA (Freedom of Information Act), 5 U.S.C. § 552

Constitutional Clause(s):

Separation of Powers

Available Documents:

Trial Court Docket

Complaint (any)

Outcome

Prevailing Party: None Yet / None

Nature of Relief:

None yet

Source of Relief:

None yet

Issues

Presidential/Gubernatorial Authority:

DOGE (Department of Government Efficiency)