Case: Las Americas Immigrant Advocacy Center v. Noem

Las Americas Immigrant Advocacy v. Noem

President Donald Trump

COMPLAINT against All Defendants ( Filing fee $ 405 receipt number CDCDC-11475594) filed by Angela Carolina Sequera, AMERICAN GATEWAYS, Yajaira Del Carmen Castillo Rivera, REFUGEE AND IMMIGRANT CENTER FOR EDUCATION AND LEGAL SERVICES, LAS AMERICAS IMMIGRANT ADVOCACY CENTER, AMERICANS FOR IMMIGRANT JUSTICE, Eucaris Carolina Gomez Lugo. (Attachments: # 1 Civil Cover Sheet, # 2 Summons Kristi Noem, # 3 Summons DHS, # 4 Summons Caleb Vitello, # 5 Summons ICE, # 6 Summons Pete Hegseth, # 7 Summons DOD, # 8 Summons Marco Rubio, # 9 Summons DOS, # 10 Summons US Attorney General)(Gelernt, Lee) (Entered: 02/12/2025)

1 Civil Cover Sheet

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2 Summons Kristi Noem

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3 Summons DHS

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4 Summons Caleb Vitello

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5 Summons ICE

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6 Summons Pete Hegseth

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7 Summons DOD

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8 Summons Marco Rubio

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9 Summons DOS

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10 Summons US Attorney General

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LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by LAS AMERICAS IMMIGRANT ADVOCACY CENTER, REFUGEE AND IMMIGRANT CENTER FOR EDUCATION AND LEGAL SERVICES, AMERICAN GATEWAYS, AMERICANS FOR IMMIGRANT JUSTICE (Gelernt, Lee) (Entered: 02/12/2025)

MOTION for Temporary Restraining Order by LAS AMERICAS IMMIGRANT ADVOCACY CENTER, REFUGEE AND IMMIGRANT CENTER FOR EDUCATION AND LEGAL SERVICES, AMERICAN GATEWAYS, AMERICANS FOR IMMIGRANT JUSTICE, Eucaris Carolina Gomez Lugo, Angela Carolina Sequera, Yajaira Del Carmen Castillo Rivera. (Attachments: # 1 Certificate of Counsel, # 2 Memorandum in Support, # 3 Declaration of Eucaris Carolina Gomez Lugo, # 4 Declaration of Angela Carolina Sequera, # 5 Declaration of Yajaira Del Carmen Castillo Rivera, # 6 Declaration of Jennifer Babaie, # 7 Declaration of Javier Hidalgo, # 8 Declaration of Edna Yang, # 9 Declaration of Paul Chavez, # 10 Declaration of My Khanh Ngo, # 11 Declaration of Shayana Kadidal, # 12 Declaration of Jose G. Miranda, # 13 Text of Proposed Order)(Gelernt, Lee) (Entered: 02/12/2025)

1 Certificate of Counsel

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2 Memorandum in Support

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3 Declaration of Eucaris Carolina Gomez Lugo

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4 Declaration of Angela Carolina Sequera

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5 Declaration of Yajaira Del Carmen Castillo Rivera

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6 Declaration of Jennifer Babaie

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7 Declaration of Javier Hidalgo

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8 Declaration of Edna Yang

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9 Declaration of Paul Chavez

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10 Declaration of My Khanh Ngo

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11 Declaration of Shayana Kadidal

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12 Declaration of Jose G. Miranda

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13 Text of Proposed Order

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NOTICE of Appearance by Arthur B. Spitzer on behalf of All Plaintiffs (Spitzer, Arthur) (Entered: 02/12/2025)

NOTICE of Appearance by Eunice Hyunhye Cho on behalf of All Plaintiffs (Cho, Eunice) (Entered: 02/12/2025)

MOTION for Scheduling Order by CALEB VITELLO, IMMIGRATION AND CUSTOMS ENFORCEMENT, PETE HEGSETH, DEPARTMENT OF DEFENSE, MARCO RUBIO, DEPARTMENT OF STATE, KRISTI NOEM, DEPARTMENT OF HOMELAND SECURITY. (Attachments: # 1 Text of Proposed Order)(Hudak, Brian) (Entered: 02/12/2025)

1 Text of Proposed Order

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NOTICE of Appearance by Scott Michelman on behalf of All Plaintiffs (Michelman, Scott) (Entered: 02/12/2025)

Case Assigned/Reassigned

~Util - Set/Reset Deadlines

Set Deadlines

Case Assigned to Judge Carl J. Nichols. (zsl)

MINUTE ORDER. In light of Plaintiffs' 3 Motion for Temporary Restraining order and Defendants' 6 Motion for Scheduling Order, it is ORDERED that by 5:00pm EST on 2/13/2025, the Parties shall meet, confer, and file a Joint Status Report addressing the following issues: (1) a proposed briefing schedule for the 3 Motion; (2) Plaintiffs' position on what, if any, irreparable harm will result if the timeframe proposed in Defendants' 6 Motion is adopted; (3) a statement addressing whether a hearing on the 3 Motion is necessary, and if so, a proposed date and time for such a hearing; and (4) a statement addressing whether the Parties anticipate factual disputes between affiants. The Parties may also address any other issues that they believe will be helpful to the Court. Any disagreements should be noted in the Joint Status Report. Signed by Judge Carl J. Nichols on 2/12/2025 (lccjn3) (Entered: 2/12/2025)

NOTICE of Appearance by Nancy Kwang Canter on behalf of All Defendants (Canter, Nancy) (Entered: 02/13/2025)

Joint STATUS REPORT by CALEB VITELLO, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, PETE HEGSETH, U.S. DEPARTMENT OF DEFENSE, MARCO RUBIO, U.S. STATE DEPARTMENT, KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY. (Canter, Nancy) (Entered: 02/13/2025)

ERRATA Corrected Civil Cover Sheet by LAS AMERICAS IMMIGRANT ADVOCACY CENTER, REFUGEE AND IMMIGRANT CENTER FOR EDUCATION AND LEGAL SERVICES, AMERICAN GATEWAYS, AMERICANS FOR IMMIGRANT JUSTICE, EUCARIS CAROLINA GOMEZ LUGO, ANGELA CAROLINA SEQUERA, YAJAIRA DEL CARMEN CASTILLO RIVERA re 1 Complaint,,. (Attachments: # 1 Errata Corrected Civil Cover Sheet)(Gelernt, Lee) (Entered: 02/13/2025)

NOTICE of Appearance by Brett Max Kaufman on behalf of All Plaintiffs (Kaufman, Brett) (Entered: 02/13/2025)

Scheduling Order

MINUTE ORDER: In accordance with the Parties' 11 Joint Status Report, it is ORDERED that Defendants' Opposition to the 3 Motion will be filed on or before 12:00pm EST on 2/20/2025. It is further ORDERED that Plaintiffs' Reply will be filed on or before 2/24/2025. Signed by Judge Carl J. Nichols on 2/13/2025 (lccjn3) (Entered: 2/13/2025)

NOTICE of Appearance by Sarah S. Wilson on behalf of All Defendants (Wilson, Sarah) (Entered: 02/14/2025)

NOTICE of Appearance by Kimberly Robin Grano on behalf of LAS AMERICAS IMMIGRANT ADVOCACY CENTER, REFUGEE AND IMMIGRANT CENTER FOR EDUCATION AND LEGAL SERVICES, AMERICAN GATEWAYS, AMERICANS FOR IMMIGRANT JUSTICE, EUCARIS CAROLINA GOMEZ LUGO, ANGELA CAROLINA SEQUERA, YAJAIRA DEL CARMEN CASTILLO RIVERA (Grano, Kimberly) (Entered: 02/19/2025)

Memorandum in opposition to re 3 Motion for TRO,,, filed by U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, U.S. DEPARTMENT OF DEFENSE, U.S. STATE DEPARTMENT, U.S. DEPARTMENT OF HOMELAND SECURITY. (Attachments: # 1 Exhibit A: Agudelo Declaration, # 2 Exhibit B: Agudelo Detainees Declaration, # 3 Exhibit C: Venghaus Declaration)(Wilson, Sarah) (Entered: 02/20/2025)

1 Exhibit A: Agudelo Declaration

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2 Exhibit B: Agudelo Detainees Declaration

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3 Exhibit C: Venghaus Declaration

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NOTICE of Removals by CALEB VITELLO, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, U.S. DEPARTMENT OF DEFENSE, U.S. STATE DEPARTMENT, U.S. DEPARTMENT OF HOMELAND SECURITY (Attachments: # 1 Declaration Agudelo)(Wilson, Sarah) (Entered: 02/20/2025)

1 Declaration Agudelo

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RESPONSE re 15 Notice (Other) filed by LAS AMERICAS IMMIGRANT ADVOCACY CENTER, REFUGEE AND IMMIGRANT CENTER FOR EDUCATION AND LEGAL SERVICES, AMERICAN GATEWAYS, AMERICANS FOR IMMIGRANT JUSTICE, EUCARIS CAROLINA GOMEZ LUGO, ANGELA CAROLINA SEQUERA, YAJAIRA DEL CARMEN CASTILLO RIVERA. (Gelernt, Lee) (Entered: 02/21/2025)

REPLY to opposition to motion re 3 Motion for TRO,,, filed by LAS AMERICAS IMMIGRANT ADVOCACY CENTER, REFUGEE AND IMMIGRANT CENTER FOR EDUCATION AND LEGAL SERVICES, AMERICAN GATEWAYS, AMERICANS FOR IMMIGRANT JUSTICE, EUCARIS CAROLINA GOMEZ LUGO, ANGELA CAROLINA SEQUERA, YAJAIRA DEL CARMEN CASTILLO RIVERA. (Attachments: # 1 Index of Exhibits, # 2 Ex. 1 - Supplemental Declaration of Jennifer Babaie, # 3 Ex. 2 - Declaration of Rebecca Lightsey, # 4 Ex. 3 - Supplemental Declaration of Javier Hidalgo, # 5 Ex. 4 - Declaration of James Connell, # 6 Ex. 5 - Declaration of Adonia Simpson, # 7 Ex. 6 - Declaration of Luis Alberto Castillo Rivera, # 8 Ex. 7 - Declaration of Tilso Ramon Gomez Lugo, # 9 Ex. 8 - Declaration of Yoiker David Sequera, # 10 Ex. 9 - Declaration of Lexdy Georgine Ruiz, # 11 Ex. 10 - Declaration of Yessika Aurimar Palma Rodriguez, # 12 Ex. 11 - Declaration of Marianis Nazareth Guilarte Tobar, # 13 Ex. 12 - Declaration of Mayr Carolina Cardiel Bastardo, # 14 Ex. 13 - Declaration of Doris Margaret Arap Valderrama, # 15 Ex. 14 - Declaration of Mileiny Aimara Alviarez Tabares, # 16 Ex. 15 - Declaration of Daneida Carolina Moreno Rodriguez, # 17 Ex. 16 - Declaration of Judeixy Jormaris Guillen Sanchez, # 18 Ex. 17 - Supplementation Declaration of Luis Alberto Castillo Rivera)(Gelernt, Lee) (Entered: 02/24/2025)

1 Index of Exhibits

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2 Ex. 1 - Supplemental Declaration of Jennifer Babaie

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3 Ex. 2 - Declaration of Rebecca Lightsey

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4 Ex. 3 - Supplemental Declaration of Javier Hidalgo

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5 Ex. 4 - Declaration of James Connell

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6 Ex. 5 - Declaration of Adonia Simpson

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7 Ex. 6 - Declaration of Luis Alberto Castillo Rivera

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8 Ex. 7 - Declaration of Tilso Ramon Gomez Lugo

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9 Ex. 8 - Declaration of Yoiker David Sequera

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10 Ex. 9 - Declaration of Lexdy Georgine Ruiz

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11 Ex. 10 - Declaration of Yessika Aurimar Palma Rodriguez

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12 Ex. 11 - Declaration of Marianis Nazareth Guilarte Tobar

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13 Ex. 12 - Declaration of Mayr Carolina Cardiel Bastardo

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14 Ex. 13 - Declaration of Doris Margaret Arap Valderrama

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15 Ex. 14 - Declaration of Mileiny Aimara Alviarez Tabares

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16 Ex. 15 - Declaration of Daneida Carolina Moreno Rodriguez

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17 Ex. 16 - Declaration of Judeixy Jormaris Guillen Sanchez

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18 Ex. 17 - Supplementation Declaration of Luis Alberto Castillo Rivera

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Notice of Hearing

NOTICE of Hearing: Motion Hearing set for 3/14/2025 at 03:00 PM in Courtroom 17- In Person before Judge Carl J. Nichols. Members of the Public and Media are permitted to attend in person. There will not be a public telephone line connected. (zcam)

NOTICE of Appearance by Deepa Alagesan on behalf of LAS AMERICAS IMMIGRANT ADVOCACY CENTER, REFUGEE AND IMMIGRANT CENTER FOR EDUCATION AND LEGAL SERVICES, AMERICAN GATEWAYS, AMERICANS FOR IMMIGRANT JUSTICE, EUCARIS CAROLINA GOMEZ LUGO, ANGELA CAROLINA SEQUERA, YAJAIRA DEL CARMEN CASTILLO RIVERA (Alagesan, Deepa) (Entered: 03/10/2025)

NOTICE of Appearance- Pro Bono by Judy Rabinovitz on behalf of All Plaintiffs (Rabinovitz, Judy) (Entered: 03/10/2025)

NOTICE of Appearance- Pro Bono by My Khanh Ngo on behalf of All Plaintiffs (Ngo, My Khanh) (Entered: 03/10/2025)

NOTICE of Appearance- Pro Bono by Noor Zafar on behalf of All Plaintiffs (Zafar, Noor) (Entered: 03/10/2025)

NOTICE of Appearance- Pro Bono by Omar C. Jadwat on behalf of All Plaintiffs (Jadwat, Omar) (Entered: 03/10/2025)

NOTICE of Appearance- Pro Bono by Wafa Junaid on behalf of All Plaintiffs (Junaid, Wafa) (Entered: 03/10/2025)

NOTICE of Appearance- Pro Bono by Kyle A. Virgien on behalf of All Plaintiffs (Virgien, Kyle) (Entered: 03/10/2025)

Set/Reset Hearings

NOTICE of Provisional/Government Not Certified Status re 18 NOTICE of Appearance by Deepa Alagesan on behalf of LAS AMERICAS IMMIGRANT ADVOCACY CENTER, REFUGEE AND IMMIGRANT CENTER FOR EDUCATION AND LEGAL SERVICES, AMERICAN GATEWAYS, AMERICANS FOR IMMIGRANT JUSTICE, EUCARIS CAROLINA GOMEZ LUGO, ANGELA CAROLINA SEQUERA, YAJAIRA DEL CARMEN CASTILLO RIVERA (Alagesan, Deepa).

Set/Reset Hearings: Motion Hearing reset for 3/14/2025 at 02:00 PM in Courtroom 17- In Person before Judge Carl J. Nichols. Note time change. Members of the Public and Media are permitted to attend in person. There will not be a public telephone line connected. (zcam)

RESOLVED.....NOTICE of Provisional/Government Not Certified Status re 18 NOTICE of Appearance by Deepa Alagesan on behalf of LAS AMERICAS IMMIGRANT ADVOCACY CENTER, REFUGEE AND IMMIGRANT CENTER FOR EDUCATION AND LEGAL SERVICES, AMERICAN GATEWAYS, AMERICANS FOR IMMIGRANT JUSTICE, EUCARIS CAROLINA GOMEZ LUGO, ANGELA CAROLINA SEQUERA, YAJAIRA DEL CARMEN CASTILLO RIVERA (Alagesan, Deepa).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 3/17/2025. (zhcn) Modified on 3/12/2025 (zhcn).

Notice of Provisional/Government Not Certified Status

NOTICE of Appearance by Drew C Ensign on behalf of All Defendants (Ensign, Drew) (Entered: 03/13/2025)

Minute Order and Entry for Proceedings held before Judge Carl J. Nichols: Motion Hearing held on 3/14/2025 re Motion 3 in 1:25-cv-00418-CJN and Motion 2 in 1:25-cv-00604-CJN. Motion 3; DENIED for reasons set forth on the record by the Court. Motion 2; DENIED for reasons set forth on the record by the Court. Further Order to be issued by the Court. Government Notice regarding transfer due by 3/19/2025. Court Reporter: Stacy Johns. (zcam)

Minute Order and Entry for Proceedings held before Judge Carl J. Nichols: Motion Hearing held on 3/14/2025 re Motion 3 in 1:25-cv-00418-CJN and Motion 2 in 1:25-cv-00604-CJN. Motion 3 ; DENIED for reasons set forth on the record by the Court. Motion 2 ; DENIED for reasons set forth on the record by the Court. Further Order to be issued by the Court. Government Notice regarding transfer due by 3/19/2025. Court Reporter: Stacy Johns. (zcam)

Set/Reset Deadlines

Motion Hearing AND Order on Motion for TRO AND Order on Motion to Stay

Set/Reset Deadlines: Government Notice of Transfer due by 3/19/2025. (zcam)

NOTICE of Appearance by Jason Kyle Zubata on behalf of All Defendants (Zubata, Jason) (Entered: 03/19/2025)

NOTICE of Transfer Notification Protocol by CALEB VITELLO, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, PETE HEGSETH, U.S. DEPARTMENT OF DEFENSE, MARCO RUBIO, U.S. STATE DEPARTMENT, KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY (Zubata, Jason) (Entered: 03/19/2025)

SUMMONS (10) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachment: (1) Notice and Consent)(zsl)

1 Notice and Consent

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NOTICE OF WITHDRAWAL OF APPEARANCE as to PETER B. HEGSETH, KRISTI NOEM, MARCO A. RUBIO, U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, U.S. STATE DEPARTMENT, CALEB VITELLO. Attorney Nancy Kwang Canter terminated. (Canter, Nancy) (Entered: 04/14/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 04/16/2025. (Gelernt, Lee)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 4/16/2025. Answer due for ALL FEDERAL DEFENDANTS by 6/15/2025. (Gelernt, Lee)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. PETER B. HEGSETH served on 4/16/2025; KRISTI NOEM served on 4/16/2025; MARCO A. RUBIO served on 4/15/2025; U.S. DEPARTMENT OF DEFENSE served on 4/16/2025; U.S. DEPARTMENT OF HOMELAND SECURITY served on 4/16/2025; U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT served on 4/17/2025; U.S. STATE DEPARTMENT served on 4/15/2025 (Gelernt, Lee)

AMENDED COMPLAINT against All Defendants filed by ANGELA CAROLINA SEQUERA, AMERICAN GATEWAYS, YAJAIRA DEL CARMEN CASTILLO RIVERA, REFUGEE AND IMMIGRANT CENTER FOR EDUCATION AND LEGAL SERVICES, AMERICANS FOR IMMIGRANT JUSTICE, LAS AMERICAS IMMIGRANT ADVOCACY CENTER, EUCARIS CAROLINA GOMEZ LUGO. (Attachments: (1) Amended Complaint Redline, (2) Todd Lyons Summons)(Gelernt, Lee)

1 Amended Complaint Redline

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2 Todd Lyons Summons

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AMENDED COMPLAINT against PETER B. HEGSETH, KRISTI NOEM, MARCO A. RUBIO, U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, U.S. STATE DEPARTMENT, TODD LYONS filed by JOHON ELIAS SUAZO-MULLER, RODOLFO JOEL LOPEZ JARQUIN. (Attachments: (1) Amended Complaint Redline, (2) Todd Lyons Summons)(Gelernt, Lee)

1 Amended Complaint Redline

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2 Todd Lyons Summons

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MOTION to Certify Class by RODOLFO JOEL LOPEZ JARQUIN, JOHON ELIAS SUAZO-MULLER. (Attachments: (1) Memorandum in Support of Motion for Class Certification, (2) Index of Exhibits, (3) Declaration of Johon Elias Suazo-Muller, (4) Declaration of Rodolfo Joel Lopez Jarquin, (5) Declaration of Helen Parsonage, (6) Declaration of Delaney Rohan, (7) Declaration of Xavier Jose Chirinos Toyo, (8) Declaration of Juan Diego Veliz Vicent, (9) Declaration of Carlos Luis Vera Gonzalez, (10) Declaration of Dominic Alexander Oliveros Tortolero, (11) Declaration of Noor Zafar, (12) Declaration of Scott Michelman JOHON ELIAS SUAZO-MULLER, et al., Plaintiffs, on behalf of themselves and those similarly situated v. KRISTI NOEM, Secretary of Homeland Security, in her official capacity, et al., Defendants. ) ) ))))))))))) Case No. 1:25-cv-418-CJN, (13) Proposed Order)(Gelernt, Lee)

1 Memorandum in Support of Motion for Class Certification

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2 Index of Exhibits

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3 Declaration of Johon Elias Suazo-Muller

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4 Declaration of Rodolfo Joel Lopez Jarquin

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5 Declaration of Helen Parsonage

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6 Declaration of Delaney Rohan

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7 Declaration of Xavier Jose Chirinos Toyo

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8 Declaration of Juan Diego Veliz Vicent

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9 Declaration of Carlos Luis Vera Gonzalez

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10 Declaration of Dominic Alexander Oliveros Tortolero

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11 Declaration of Noor Zafar

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12 Declaration of Scott Michelman JOHON ELIAS SUAZO-MULLER, et al., Plaintiffs, on

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13 Proposed Order

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ERRATA by RODOLFO JOEL LOPEZ JARQUIN, JOHON ELIAS SUAZO-MULLER. (Gelernt, Lee)

SUMMONS (1) Issued Electronically as to TODD LYONS. (Attachments: # 1 Notice and Consent)(zdp) (Entered: 04/28/2025)

1 Notice and Consent

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MOTION for Extension of Time to File Response/Reply as to 35 MOTION to Certify Class MOTION to Appoint Lead Counsel by PETER B. HEGSETH, TODD LYONS, KRISTI NOEM, MARCO A. RUBIO, U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, U.S. STATE DEPARTMENT. (Attachments: # 1 Text of Proposed Order)(Zubata, Jason) (Entered: 05/06/2025)

1 Text of Proposed Order

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MINUTE ORDER: Plaintiffs are ORDERED to file a response to the government's 38 Motion for Extension of Time by 12:00pm EST on 5/8/2025. Signed by Judge Carl J. Nichols on 5/7/2025 (lccjn3)

~Util - Set/Reset Deadlines

MINUTE ORDER: Plaintiffs are ORDERED to file a response to the government's 38 Motion for Extension of Time by 12:00pm EST on 5/8/2025. Signed by Judge Carl J. Nichols on 5/7/2025 (lccjn3) (Entered: 5/7/2025)

RESPONSE re 38 MOTION for Extension of Time to File Response/Reply as to 35 MOTION to Certify Class MOTION to Appoint Lead Counsel filed by AMERICAN GATEWAYS, AMERICANS FOR IMMIGRANT JUSTICE, YAJAIRA DEL CARMEN CASTILLO RIVERA, EUCARIS CAROLINA GOMEZ LUGO, LAS AMERICAS IMMIGRANT ADVOCACY CENTER, RODOLFO JOEL LOPEZ JARQUIN, REFUGEE AND IMMIGRANT CENTER FOR EDUCATION AND LEGAL SERVICES, ANGELA CAROLINA SEQUERA, JOHON ELIAS SUAZO-MULLER. (Gelernt, Lee) (Entered: 05/08/2025)

MINUTE ORDER: It is ordered that the Government's 38 Motion for Extension of Time is GRANTED. The Government's Response to Plaintiffs' 35 Motion to Certify Class shall be due on 6/9/2025. Signed by Judge Carl J. Nichols on 5/8/2025 (lccjn3)

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

MINUTE ORDER: It is ordered that the Government's 38 Motion for Extension of Time is GRANTED. The Government's Response to Plaintiffs' 35 Motion to Certify Class shall be due on 6/9/2025. Signed by Judge Carl J. Nichols on 5/8/2025 (lccjn3) (Entered: 5/8/2025)

NOTICE of Appearance by Malcolm McDermond on behalf of All Defendants (McDermond, Malcolm)

Consent MOTION for Extension of Time to File Response/Reply as to [35] MOTION to Certify Class MOTION to Appoint Lead Counsel by PETER B. HEGSETH, TODD LYONS, KRISTI NOEM, MARCO RUBIO, U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, U.S. STATE DEPARTMENT. (Attachments: (1) Text of Proposed Order)(Zubata, Jason)

1 Text of Proposed Order

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Memorandum in opposition to re [35] MOTION to Certify Class MOTION to Appoint Lead Counsel filed by PETER B. HEGSETH, TODD LYONS, KRISTI NOEM, MARCO RUBIO, U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, U.S. STATE DEPARTMENT. (Attachments: (1) Exhibit March 14, 2025 TRO Hearing Transcript, (2) Exhibit Ramos Declaration, (3) Exhibit Green Declaration, (4) Exhibit NSGB MOU)(Zubata, Jason)

1 Exhibit March 14, 2025 TRO Hearing Transcript

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2 Exhibit Ramos Declaration

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3 Exhibit Green Declaration

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4 Exhibit NSGB MOU

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MINUTE ORDER: It is ORDERED that the Government's 41 Consent Motion for Extension of time is GRANTED nunc pro tunc. The government shall respond to Plaintiff's motion for class certification on or before 6/10/2025. Plaintiffs shall submit their reply to the governments response on or before 6/18/2025. Signed by Judge Carl J. Nichols on 6/11/2025 (lccjn3)

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

MINUTE ORDER: It is ORDERED that the Government's 41 Consent Motion for Extension of time is GRANTED nunc pro tunc. The government shall respond to Plaintiff's motion for class certification on or before 6/10/2025. Plaintiffs shall submit their reply to the governments response on or before 6/18/2025. Signed by Judge Carl J. Nichols on 6/11/2025 (lccjn3) (Entered: 6/11/2025)

MOTION to Dismiss Plaintiffs' Amended Complaint by PETER B. HEGSETH, TODD LYONS, KRISTI NOEM, MARCO RUBIO, U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, U.S. STATE DEPARTMENT. (Attachments: (1) Text of Proposed Order)(Zubata, Jason)

1 Text of Proposed Order

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NOTICE of Appearance by Alexa Perlmutter on behalf of All Defendants (Perlmutter, Alexa) (Entered: 06/18/2025)

REPLY to opposition to motion re 35 Motion to Certify Class,,,, Motion to Appoint Lead Counsel,,, filed by RODOLFO JOEL LOPEZ JARQUIN, JOHON ELIAS SUAZO-MULLER. (Attachments: # 1 Declaration of Rafael Lopez Ocon, # 2 Declaration of Yamil Luna Gutierrez, # 3 Declaration of Marisol Dominguez Ruiz, # 4 Declaration of Afshan Khan, # 5 Declaration of Rodolfo Lopez Jarquin)(Gelernt, Lee) (Entered: 06/18/2025)

1 Declaration of Rafael Lopez Ocon

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2 Declaration of Yamil Luna Gutierrez

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3 Declaration of Marisol Dominguez Ruiz

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4 Declaration of Afshan Khan

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5 Declaration of Rodolfo Lopez Jarquin

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Memorandum in opposition to re [43] MOTION to Dismiss Plaintiffs' Amended Complaint filed by RODOLFO JOEL LOPEZ JARQUIN, JOHON ELIAS SUAZO-MULLER. (Gelernt, Lee)

MOTION for Extension of Time to File Response/Reply in Support of Defendants' Motion to Dismiss by PETER B. HEGSETH, TODD LYONS, KRISTI NOEM, MARCO RUBIO, U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, U.S. STATE DEPARTMENT. (Attachments: # 1 Text of Proposed Order)(Zubata, Jason) (Entered: 07/01/2025)

1 Text of Proposed Order

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REPLY to opposition to motion re 43 Motion to Dismiss, in support of Defendants' Motion to Dismiss Plaintiffs' Amended Complaint filed by PETER B. HEGSETH, TODD LYONS, KRISTI NOEM, MARCO RUBIO, U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, U.S. STATE DEPARTMENT. (Perlmutter, Alexa) (Entered: 07/07/2025)

NOTICE OF WITHDRAWAL OF APPEARANCE as to PETER B. HEGSETH, TODD LYONS, KRISTI NOEM, MARCO A. RUBIO, U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, U.S. STATE DEPARTMENT. Attorney Sarah S. Wilson terminated. (Wilson, Sarah) (Entered: 08/06/2025)

Consent MOTION to Withdraw as Attorney Deepa Alagesan for Plaintiffs by RODOLFO JOEL LOPEZ JARQUIN, JOHON ELIAS SUAZO-MULLER. (Attachments: (1) Text of Proposed Order)(Alagesan, Deepa)

1 Text of Proposed Order

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