Case: National Education Association v. United States Department of Education

Craig Trainor

NEW CASE/ COMPLAINT Filing fee $ 405, receipt number ANHDC-2609445 filed by National Education Association, National Education Association-New Hampshire. (Attachments: # 1 Exhibit A -- Feb. 14, 2025 Dear Colleague Letter, # 2 Exhibit B -- Feb. 28, 2025 Frequently Asked Questions, # 3 Civil Cover Sheet, # 4 Summons - Waiver U.S. Department of Education, # 5 Summons - Waiver Linda McMahon, # 6 Summons - Waiver Craig Trainor)(Bissonnette, Gilles) (Entered: 03/05/2025)

1 Exhibit A -- Feb. 14, 2025 Dear Colleague Letter

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2 Exhibit B -- Feb. 28, 2025 Frequently Asked Questions

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3 Civil Cover Sheet

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4 Summons - Waiver U.S. Department of Education

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5 Summons - Waiver Linda McMahon

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6 Summons - Waiver Craig Trainor

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NEW CASE/ COMPLAINT Filing fee $ 405, receipt number ANHDC-2609445 filed by National Education Association, National Education Association-New Hampshire. (Attachments: # 1 Exhibit A -- Feb. 14, 2025 Dear Colleague Letter, # 2 Exhibit B -- Feb. 28, 2025 Frequently Asked Questions, # 3 Civil Cover Sheet, # 4 Summons - Waiver U.S. Department of Education, # 5 Summons - Waiver Linda McMahon, # 6 Summons - Waiver Craig Trainor)(Bissonnette, Gilles) (Entered: 03/05/2025)

1 Exhibit A -- Feb. 14, 2025 Dear Colleague Letter

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2 Exhibit B -- Feb. 28, 2025 Frequently Asked Questions

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3 Civil Cover Sheet

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4 Summons - Waiver U.S. Department of Education

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5 Summons - Waiver Linda McMahon

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6 Summons - Waiver Craig Trainor

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Disclosure Statement by National Education Association disclosing no parent company, no publicly traded company, and no merger agreement. (Bissonnette, Gilles) (Entered: 03/05/2025)

Disclosure Statement by National Education Association disclosing no parent company, no publicly traded company, and no merger agreement. (Bissonnette, Gilles) (Entered: 03/05/2025)

Disclosure Statement by National Education Association-New Hampshire disclosing no parent company, no publicly traded company, and no merger agreement. (Bissonnette, Gilles) (Entered: 03/05/2025)

Disclosure Statement by National Education Association-New Hampshire disclosing no parent company, no publicly traded company, and no merger agreement. (Bissonnette, Gilles) (Entered: 03/05/2025)

NOTICE of Attorney Appearance by SangYeob Kim on behalf of National Education Association, National Education Association-New Hampshire Attorney SangYeob Kim added to party National Education Association(pty:pla), Attorney SangYeob Kim added to party National Education Association-New Hampshire(pty:pla).(Kim, SangYeob) (Entered: 03/05/2025)

NOTICE of Attorney Appearance by SangYeob Kim on behalf of National Education Association, National Education Association-New Hampshire Attorney SangYeob Kim added to party National Education Association(pty:pla), Attorney SangYeob Kim added to party National Education Association-New Hampshire(pty:pla).(Kim, SangYeob) (Entered: 03/05/2025)

NOTICE of Attorney Appearance by Henry Klementowicz on behalf of National Education Association, National Education Association-New Hampshire Attorney Henry Klementowicz added to party National Education Association(pty:pla), Attorney Henry Klementowicz added to party National Education Association-New Hampshire(pty:pla).(Klementowicz, Henry) (Entered: 03/05/2025)

NOTICE of Attorney Appearance by Henry Klementowicz on behalf of National Education Association, National Education Association-New Hampshire Attorney Henry Klementowicz added to party National Education Association(pty:pla), Attorney Henry Klementowicz added to party National Education Association-New Hampshire(pty:pla).(Klementowicz, Henry) (Entered: 03/05/2025)

Case assigned to US Magistrate Judge Talesha L. Saint-Marc. The case designation is: 1:25-cv-91-TSM. Please show this number with the judge designation on all future pleadings. (ed)

Case assigned to US Magistrate Judge Talesha L. Saint-Marc. The case designation is: 1:25-cv-91-TSM. Please show this number with the judge designation on all future pleadings. (ed)

NOTICE of Assignment to U.S. Magistrate Judge and Consent Form sent to plaintiffs for service on all parties. MJ Consent Form Due 4/24/2025.(ed) (Entered: 03/07/2025)

NOTICE of Assignment to U.S. Magistrate Judge and Consent Form sent to plaintiffs for service on all parties. MJ Consent Form Due 4/24/2025.(ed) (Entered: 03/07/2025)

Notice - ECF

Notice - ECF

Case Assigned

Case Assigned

NOTICE. This case has been designated for Electronic Case Filing. All further submissions shall be filed in compliance with the Administrative Procedures for Electronic Case Filing. Pro se litigants are not required to file electronically and may continue to file documents in paper format. Persons filing electronically are strongly encouraged to complete the interactive training modules available on the courts website. To access these modules, click HERE. (ed)

NOTICE. This case has been designated for Electronic Case Filing. All further submissions shall be filed in compliance with the Administrative Procedures for Electronic Case Filing. Pro se litigants are not required to file electronically and may continue to file documents in paper format. Persons filing electronically are strongly encouraged to complete the interactive training modules available on the courts website. To access these modules, click HERE. (ed)

Case Reassigned

Case Reassigned

ORDER OF RECUSAL. US Magistrate Judge Talesha L. Saint-Marc recused. So Ordered by US Magistrate Judge Talesha L. Saint-Marc.(ed) (Entered: 03/07/2025)

ORDER OF RECUSAL. US Magistrate Judge Talesha L. Saint-Marc recused. So Ordered by US Magistrate Judge Talesha L. Saint-Marc.(ed) (Entered: 03/07/2025)

Case reassigned to Judge Joseph N. Laplante. The new case designation is: 1:25-cv-91-JL. Please show this number with the correct judge designation on all further pleadings. (ed)

Case reassigned to Judge Joseph N. Laplante. The new case designation is: 1:25-cv-91-JL. Please show this number with the correct judge designation on all further pleadings. (ed)

Assented to MOTION for Rachel E. Davidson to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2610334.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/07/2025)

Assented to MOTION for Rachel E. Davidson to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2610334.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/07/2025)

Assented to MOTION for Alexis Alvarez to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2610365.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/07/2025)

Assented to MOTION for Alexis Alvarez to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2610365.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/07/2025)

Assented to MOTION for Amanda Meyer to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2610366.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/07/2025)

Assented to MOTION for Amanda Meyer to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2610366.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/07/2025)

Assented to MOTION for Ethan Herenstein to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2610368.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/07/2025)

Assented to MOTION for Ethan Herenstein to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2610368.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/07/2025)

Assented to MOTION for Sarah Hinger to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2610371.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/07/2025)

Assented to MOTION for Sarah Hinger to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2610371.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/07/2025)

Assented to MOTION for Sophia Lin Lakin to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2610372.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/07/2025)

Assented to MOTION for Sophia Lin Lakin to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2610372.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/07/2025)

Assented to MOTION for Victoria Ochoa to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2610375.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/07/2025)

Assented to MOTION for Victoria Ochoa to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2610375.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/07/2025)

Summonses issued electronically as to US Department of Education, US Department of Education, Acting Assistant Secretary, US Department of Education, Secretary. NOTICE: Counsel shall print and serve the summonses and all attachments in accordance with Fed. R. Civ. P. 4. (Attachments: # 1 Notice ECF)(ed) (Entered: 03/07/2025)

Summonses issued electronically as to US Department of Education, US Department of Education, Acting Assistant Secretary, US Department of Education, Secretary. NOTICE: Counsel shall print and serve the summonses and all attachments in accordance with Fed. R. Civ. P. 4. (Attachments: # 1 Notice ECF)(ed) (Entered: 03/07/2025)

Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice

Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice

Case Reassigned

Case Reassigned

ENDORSED ORDER granting re 8 Motion for Rachel E. Davidson to Appear Pro Hac Vice; granting 9 Motion for Alexis Alvarez to Appear Pro Hac Vice; granting 10 Motion for Amanda Meyer to Appear Pro Hac Vice; granting 11 Motion for Ethan Herenstein to Appear Pro Hac Vice; granting 12 Motion for Sarah Hinger to Appear Pro Hac Vice; granting 13 Motion for Sophia Lin Lakin to Appear Pro Hac Vice; granting 14 Motion for Victoria Ochoa to Appear Pro Hac Vice. Text of Order: Granted. Local counsel shall comply with all obligations required by L.R. 83.2(b) absent order of the court. So Ordered by Judge Joseph N. Laplante. The clerk's office will provide the admitted attorney with instructions on how to obtain access to electronic filing by separate email. The admitted attorney must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of New Hampshire. After obtaining e-filing access, the admitted attorney must file an appearance to begin receiving electronic notices.(ko)

ENDORSED ORDER granting re 8 Motion for Rachel E. Davidson to Appear Pro Hac Vice; granting 9 Motion for Alexis Alvarez to Appear Pro Hac Vice; granting 10 Motion for Amanda Meyer to Appear Pro Hac Vice; granting 11 Motion for Ethan Herenstein to Appear Pro Hac Vice; granting 12 Motion for Sarah Hinger to Appear Pro Hac Vice; granting 13 Motion for Sophia Lin Lakin to Appear Pro Hac Vice; granting 14 Motion for Victoria Ochoa to Appear Pro Hac Vice. Text of Order: Granted. Local counsel shall comply with all obligations required by L.R. 83.2(b) absent order of the court. So Ordered by Judge Joseph N. Laplante. The clerk's office will provide the admitted attorney with instructions on how to obtain access to electronic filing by separate email. The admitted attorney must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of New Hampshire. After obtaining e-filing access, the admitted attorney must file an appearance to begin receiving electronic notices.(ko)

ORDER OF RECUSAL. Judge Joseph N. Laplante recused as outlined. So Ordered by Judge Joseph N. Laplante.(ko) (Entered: 03/10/2025)

ORDER OF RECUSAL. Judge Joseph N. Laplante recused as outlined. So Ordered by Judge Joseph N. Laplante.(ko) (Entered: 03/10/2025)

Case reassigned to Chief Judge Landya B. McCafferty. The new case designation is: 1:25-cv-91-LM. Please show this number with the correct judge designation on all further pleadings.(ko)

Case reassigned to Chief Judge Landya B. McCafferty. The new case designation is: 1:25-cv-91-LM. Please show this number with the correct judge designation on all further pleadings.(ko)

Assented to MOTION for PHILIP HOSTAK to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2611269.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/10/2025)

Assented to MOTION for PHILIP HOSTAK to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2611269.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/10/2025)

Assented to MOTION for JASON WALTA to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2611272.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/10/2025)

Assented to MOTION for JASON WALTA to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2611272.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/10/2025)

Assented to MOTION for MEGAN C. KEENAN to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2611273.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/10/2025)

Assented to MOTION for MEGAN C. KEENAN to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2611273.) filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/10/2025)

NOTICE of Attorney Appearance by Rachel Elizabeth Davidson on behalf of National Education Association, National Education Association-New Hampshire Attorney Rachel Elizabeth Davidson added to party National Education Association(pty:pla), Attorney Rachel Elizabeth Davidson added to party National Education Association-New Hampshire(pty:pla).(Davidson, Rachel) (Entered: 03/10/2025)

NOTICE of Attorney Appearance by Rachel Elizabeth Davidson on behalf of National Education Association, National Education Association-New Hampshire Attorney Rachel Elizabeth Davidson added to party National Education Association(pty:pla), Attorney Rachel Elizabeth Davidson added to party National Education Association-New Hampshire(pty:pla).(Davidson, Rachel) (Entered: 03/10/2025)

Addendum/ to 17 Assented to MOTION for PHILIP HOSTAK to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2611269.) (Corrected Declaration) by National Education Association, National Education Association-New Hampshire. (Bissonnette, Gilles) (Entered: 03/10/2025)

Addendum/ to 17 Assented to MOTION for PHILIP HOSTAK to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2611269.) (Corrected Declaration) by National Education Association, National Education Association-New Hampshire. (Bissonnette, Gilles) (Entered: 03/10/2025)

Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice

ENDORSED ORDER granting 17 Assented to Motion for Philip Hostak to Appear Pro Hac Vice; granting 18 Assented to Motion for Jason Walta to Appear Pro Hac Vice; granting 19 Assented to Motion for Megan C. Keenan to Appear Pro Hac Vice. Text of Order: Granted. Documents 17, 18 and 19 are granted. Local counsel shall comply with all obligations required by L.R. 83.2(b) absent order of the court. So Ordered by Chief Judge Landya B. McCafferty.The clerks office will provide the admitted attorney with instructions on how to obtain access to electronic filing by separate email. The admitted attorney must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of New Hampshire. After obtaining e-filing access, the admitted attorney must file an appearance to begin receiving electronic notices.(de)

NOTICE of Attorney Appearance by Sarah Hinger on behalf of National Education Association, National Education Association-New Hampshire Attorney Sarah Hinger added to party National Education Association(pty:pla), Attorney Sarah Hinger added to party National Education Association-New Hampshire(pty:pla).(Hinger, Sarah) (Entered: 03/11/2025)

NOTICE of Attorney Appearance by Sarah Hinger on behalf of National Education Association, National Education Association-New Hampshire (Hinger, Sarah) (Entered: 03/11/2025)

NOTICE of Attorney Appearance by Amanda Marie Meyer on behalf of National Education Association, National Education Association-New Hampshire Attorney Amanda Marie Meyer added to party National Education Association(pty:pla), Attorney Amanda Marie Meyer added to party National Education Association-New Hampshire(pty:pla).(Meyer, Amanda) (Entered: 03/11/2025)

NOTICE of Attorney Appearance by Sophia Lin Lakin on behalf of National Education Association, National Education Association-New Hampshire Attorney Sophia Lin Lakin added to party National Education Association(pty:pla), Attorney Sophia Lin Lakin added to party National Education Association-New Hampshire(pty:pla).(Lakin, Sophia) (Entered: 03/11/2025)

NOTICE of Attorney Appearance by Ethan Herenstein on behalf of National Education Association, National Education Association-New Hampshire Attorney Ethan Herenstein added to party National Education Association(pty:pla), Attorney Ethan Herenstein added to party National Education Association-New Hampshire(pty:pla).(Herenstein, Ethan) (Entered: 03/11/2025)

NOTICE of Attorney Appearance by Victoria Ochoa on behalf of National Education Association, National Education Association-New Hampshire Attorney Victoria Ochoa added to party National Education Association(pty:pla), Attorney Victoria Ochoa added to party National Education Association-New Hampshire(pty:pla).(Ochoa, Victoria) (Entered: 03/12/2025)

AFFIDAVIT of Service of Complaint, Summonses, and ECF Notice as to All Defendants filed by National Education Association, National Education Association-New Hampshire. Served/Mailed on 3/7/2025. Answer Follow Up on 3/28/2025. The court only follow up date DOES NOT include 3 additional days that may apply per FRCP 6(d) and FRCrP 45(c). (Attachments: # 1 Exhibit A_Service - AG, # 2 Exhibit B_Service - DOE, # 3 Exhibit C_Service - Secretary, # 4 Exhibit D_Service - Acting Assistant Secretary)(Kim, SangYeob) (Entered: 03/12/2025)

NOTICE of Attorney Appearance by Alexis Alvarez on behalf of National Education Association, National Education Association-New Hampshire Attorney Alexis Alvarez added to party National Education Association(pty:pla), Attorney Alexis Alvarez added to party National Education Association-New Hampshire(pty:pla).(Alvarez, Alexis) (Entered: 03/13/2025)

Assented to MOTION to Exceed Page Limit for Motion for Preliminary Injunction filed by National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/19/2025)

Order on Motion to Exceed

ENDORSED ORDER granting 30 Assented to Motion to Exceed Page Limit for Motion for Preliminary Injunction. Text of Order: Granted. So Ordered by Chief Judge Landya B. McCafferty.(de)

NOTICE of First Amended Complaint by National Education Association, National Education Association-New Hampshire. (Attachments: # 1 Exhibit 1 -- First Amended Complaint, # 2 Exhibit 2 -- Redline)(Bissonnette, Gilles) (Entered: 03/21/2025)

1 Exhibit 1 -- First Amended Complaint

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2 Exhibit 2 -- Redline

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Endorsed Order - not on motion

ENDORSED ORDER re: 31 Notice of First Amended Complaint. Text of Order: Reviewed. Within 48 hours counsel shall electronically refile the pleading attached to the Notice of First Amended Complaint using the appropriate event in CMECF. So Ordered by Chief Judge Landya B. McCafferty.(de)

AMENDED COMPLAINT against US Department of Education, US Department of Education, Acting Assistant Secretary, US Department of Education, Secretary filed by National Education Association, National Education Association-New Hampshire, Center for Black Educator Development. (Attachments: # 1 Exhibit A -- Feb. 14, 2025 Dear Colleague Letter, # 2 Exhibit B -- Feb. 28, 2025 Frequently Asked Questions)(Bissonnette, Gilles) (Entered: 03/21/2025)

1 Exhibit A -- Feb. 14, 2025 Dear Colleague Letter

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2 Exhibit B -- Feb. 28, 2025 Frequently Asked Questions

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Disclosure Statement by Center for Black Educator Development disclosing no parent company, no publicly traded company, and no merger agreement. (Bissonnette, Gilles) (Entered: 03/21/2025)

MOTION for Preliminary Injunction filed by Center for Black Educator Development, National Education Association, National Education Association-New Hampshire. HEARING REQUESTED.Follow up on Objection on 4/4/2025. The court only follow up date DOES NOT include 3 additional days that may apply per FRCP 6(d) and FRCrP 45(c). (Attachments: # 1 Memorandum of Law, # 2 Exhibit (Affidavit) 1 -- Declaration of Sarah Hinger Authenticating Exhibits, # 3 Exhibit A -- Feb. 14, 2025 Dear Colleague Letter, # 4 Exhibit B -- Mar. 14, 2025 Investigations Press Release, # 5 Exhibit C -- Aug. 14, 2023 Dear Colleague Letter, # 6 Exhibit D -- SFFA Q & A, # 7 Exhibit E -- Strategies Report, # 8 Exhibit F -- Portal Press Release, # 9 Exhibit G -- End DEI Portal, # 10 Exhibit H -- Feb. 28, 2025 FAQs, # 11 Exhibit I -- Redacted Member A Declaration, # 12 Exhibit J -- Member B Declaration, # 13 Exhibit K -- Member C Declaration, # 14 Exhibit L -- Redacted Member D Declaration, # 15 Exhibit M -- Member G Declaration, # 16 Exhibit N -- Redacted Member E Declaration, # 17 Exhibit O -- NEA-NH Declaration, # 18 Exhibit P -- Redacted Member I Declaration, # 19 Exhibit Q -- Member H Declaration, # 20 Exhibit R -- Redacted Member F Declaration, # 21 Exhibit S -- NEA Declaration, # 22 Exhibit T -- TN Social Studies Standards (Excerpt), # 23 Exhibit U -- OK Social Studies Standards (Excerpt), # 24 Exhibit V -- OK ELA Standards (Excerpt), # 25 Exhibit W -- NH Commission for Human Rights Website, # 26 Exhibit X -- CBED Declaration, # 27 Exhibit Y -- Analytical Perspectives Budget 2025 (Excerpt), # 28 Exhibit Z -- DIVERSITY, EQUITY AND INCLUSION Definition, # 29 Exhibit AA -- DIVERSITY Definition, # 30 Exhibit AB -- EQUITY Definition, # 31 Exhibit AC -- INCLUSION Definition, # 32 Exhibit AD -- President Pinto shares message, # 33 Exhibit AE -- Feb. 18 New federal directives, # 34 Exhibit AF -- A message from President Gold, # 35 Exhibit AG -- Muskegon Community College suspends DEI, # 36 Exhibit AH -- DOE Cancels Additional $350 Million, # 37 Exhibit AI -- DOE Cuts Over $600 Million in Divisive Grants, # 38 Exhibit AJ -- DOE Lifts Pause, # 39 Exhibit AK -- Mass Layoffs Slash DOE, # 40 Exhibit AL -- End DEI Portal Article, # 41 Exhibit AM -- Dear Colleague Letter Has Been Sent, # 42 Exhibit AN -- DEI tug-of-war in Wake County Schools article, # 43 Exhibit AO -- X Post, # 44 Exhibit AP -- DOJ, HHS, ED, and GSA Announce Initial Cancelation of Grants, # 45 Exhibit AQ -- GSA letter to Columbia, # 46 Exhibit AR -- 2001 January Dear Colleague Letter, # 47 Exhibit AS -- 2014 October Dear Colleague Letter, # 48 Exhibit AT -- What is Test Optional, # 49 Exhibit AU -- Bennett 2021 Untested Admissions Examining Changes, # 50 Exhibit AV -- Freedle, Correcting the SATs Ethnic and Social-Class Bias, # 51 Exhibit AW -- How the SAT Creates Built-in-Headwinds, # 52 Exhibit AX -- Letter from DOE, # 53 Exhibit AY -- Resolution Agreement, East Side Union High School District, # 54 Exhibit AZ -- EO 14190, # 55 Exhibit BA -- EO 14151, # 56 Exhibit BB -- EO 14173, # 57 Exhibit BC -- DOGE Announces it's Slashing $881M from ED Contracts, # 58 Proposed Order)(Bissonnette, Gilles) (Entered: 03/21/2025)

1 Memorandum of Law

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2 Exhibit (Affidavit) 1 -- Declaration of Sarah Hinger Authenticating Exhibits

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3 Exhibit A -- Feb. 14, 2025 Dear Colleague Letter

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4 Exhibit B -- Mar. 14, 2025 Investigations Press Release

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5 Exhibit C -- Aug. 14, 2023 Dear Colleague Letter

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6 Exhibit D -- SFFA Q & A

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7 Exhibit E -- Strategies Report

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8 Exhibit F -- Portal Press Release

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9 Exhibit G -- End DEI Portal

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10 Exhibit H -- Feb. 28, 2025 FAQs

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11 Exhibit I -- Redacted Member A Declaration

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12 Exhibit J -- Member B Declaration

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13 Exhibit K -- Member C Declaration

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14 Exhibit L -- Redacted Member D Declaration

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15 Exhibit M -- Member G Declaration

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16 Exhibit N -- Redacted Member E Declaration

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17 Exhibit O -- NEA-NH Declaration

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18 Exhibit P -- Redacted Member I Declaration

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19 Exhibit Q -- Member H Declaration

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20 Exhibit R -- Redacted Member F Declaration

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21 Exhibit S -- NEA Declaration

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22 Exhibit T -- TN Social Studies Standards (Excerpt)

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23 Exhibit U -- OK Social Studies Standards (Excerpt)

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24 Exhibit V -- OK ELA Standards (Excerpt)

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25 Exhibit W -- NH Commission for Human Rights Website

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26 Exhibit X -- CBED Declaration

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27 Exhibit Y -- Analytical Perspectives Budget 2025 (Excerpt)

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28 Exhibit Z -- DIVERSITY, EQUITY AND INCLUSION Definition

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29 Exhibit AA -- DIVERSITY Definition

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30 Exhibit AB -- EQUITY Definition

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31 Exhibit AC -- INCLUSION Definition

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32 Exhibit AD -- President Pinto shares message

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33 Exhibit AE -- Feb. 18 New federal directives

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34 Exhibit AF -- A message from President Gold

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35 Exhibit AG -- Muskegon Community College suspends DEI

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36 Exhibit AH -- DOE Cancels Additional $350 Million

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37 Exhibit AI -- DOE Cuts Over $600 Million in Divisive Grants

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38 Exhibit AJ -- DOE Lifts Pause

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39 Exhibit AK -- Mass Layoffs Slash DOE

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40 Exhibit AL -- End DEI Portal Article

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41 Exhibit AM -- Dear Colleague Letter Has Been Sent

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42 Exhibit AN -- DEI tug-of-war in Wake County Schools article

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43 Exhibit AO -- X Post

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44 Exhibit AP -- DOJ, HHS, ED, and GSA Announce Initial Cancelation of Grants

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45 Exhibit AQ -- GSA letter to Columbia

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46 Exhibit AR -- 2001 January Dear Colleague Letter

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47 Exhibit AS -- 2014 October Dear Colleague Letter

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48 Exhibit AT -- What is Test Optional

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49 Exhibit AU -- Bennett 2021 Untested Admissions Examining Changes

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50 Exhibit AV -- Freedle, Correcting the SATs Ethnic and Social-Class Bias

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51 Exhibit AW -- How the SAT Creates Built-in-Headwinds

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52 Exhibit AX -- Letter from DOE

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53 Exhibit AY -- Resolution Agreement, East Side Union High School District

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54 Exhibit AZ -- EO 14190

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55 Exhibit BA -- EO 14151

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56 Exhibit BB -- EO 14173

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57 Exhibit BC -- DOGE Announces it's Slashing $881M from ED Contracts

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58 Proposed Order

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NOTICE of Attorney Appearance by Philip Adam Hostak on behalf of National Education Association, National Education Association-New Hampshire Attorney Philip Adam Hostak added to party National Education Association(pty:pla), Attorney Philip Adam Hostak added to party National Education Association-New Hampshire(pty:pla).(Hostak, Philip) (Entered: 03/24/2025)

Assented to MOTION for Alice O'Brien to Appear Pro Hac Vice (Filing fee $ 100, Receipt # ANHDC-2616037.) filed by Center for Black Educator Development, National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 03/24/2025)

ENDORSED ORDER granting 36 Assented to Motion for Alice O'Brien to Appear Pro Hac Vice. Text of Order: Granted. Local counsel shall comply with all obligations required by L.R. 83.2(b) absent order of the court. So Ordered by Chief Judge Landya B. McCafferty.The clerks office will provide the admitted attorney with instructions on how to obtain access to electronic filing by separate email. The admitted attorney must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of New Hampshire. After obtaining e-filing access, the admitted attorney must file an appearance to begin receiving electronic notices.(de)

NOTICE of Attorney Appearance by Jason Walta on behalf of National Education Association Attorney Jason Walta added to party National Education Association(pty:pla).(Walta, Jason)

Assented to MOTION to Extend Time to Object/Respond to 34 MOTION for Preliminary Injunction to April 11, 2025 filed by US Department of Education, US Department of Education, Secretary, US Department of Education, Acting Assistant Secretary. Attorney Robert J. Rabuck added to party US Department of Education(pty:dft), Attorney Robert J. Rabuck added to party US Department of Education, Secretary(pty:dft), Attorney Robert J. Rabuck added to party US Department of Education, Acting Assistant Secretary(pty:dft).(Rabuck, Robert) (Entered: 03/31/2025)

ENDORSED ORDER granting 39 Assented to Motion to Extend Time to Object/Respond to MOTION for Preliminary Injunction to April 11, 2025. Text of Order: Granted. So Ordered by Chief Judge Landya B. McCafferty.Follow up on Objection on 4/11/2025. (de)

Assented to MOTION to Exceed Page Limit for Motion for Temporary Restraining Order filed by Center for Black Educator Development, National Education Association, National Education Association-New Hampshire.(Bissonnette, Gilles) (Entered: 04/07/2025)

Motion Hearing

Endorsed Order - not on motion

Order on Motion to Exceed

Emergency MOTION Temporary Restraining Order filed by Center for Black Educator Development, National Education Association, National Education Association-New Hampshire. Attorney Henry Klementowicz added to party Center for Black Educator Development(pty:pla). HEARING REQUESTED.Follow up on Objection on 4/21/2025. The court only follow up date DOES NOT include 3 additional days that may apply per FRCP 6(d) and FRCrP 45(c). (Attachments: # 1 Memorandum of Law, # 2 Proposed Order, # 3 Exhibit (Affidavit) Hinger Declaration, # 4 Exhibit A -- Certification Requirement, # 5 Exhibit B -- NHED Certification Requirement Directions, # 6 Exhibit C -- Apr. 3 Certification Press Release, # 7 Exhibit D -- NY ESSA State Plan, # 8 Exhibit E - Mass ESSA State Plan, # 9 Exhibit F -- NYSED Letter to ED, # 10 Exhibit G -- NHED General Assurances FY 2026, # 11 Exhibit H -- Supplement Questionnaire)(Klementowicz, Henry) (Entered: 04/07/2025)

1 Memorandum of Law

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2 Proposed Order

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3 Exhibit (Affidavit) Hinger Declaration

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4 Exhibit A -- Certification Requirement

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5 Exhibit B -- NHED Certification Requirement Directions

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6 Exhibit C -- Apr. 3 Certification Press Release

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7 Exhibit D -- NY ESSA State Plan

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8 Exhibit E - Mass ESSA State Plan

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9 Exhibit F -- NYSED Letter to ED

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10 Exhibit G -- NHED General Assurances FY 2026

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11 Exhibit H -- Supplement Questionnaire

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Order

ENDORSED ORDER granting 40 Assented to Motion to Exceed Page Limit for Motion for Temporary Restraining Order. Text of Order: Granted. So Ordered by Chief Judge Landya B. McCafferty.(de)

Notice of Hearing on Motion

ENDORSED ORDER re: 41 Emergency MOTION Temporary Restraining Order . Text of Order: Given the time-sensitive nature of the relief requested in doc. no. 41, the court will schedule a motion hearing for 2:00 p.m. on April 9, 2025. Defendants are directed to file their response no later than 5:00 p.m. on April 8, 2025. So Ordered by Chief Judge Landya B. McCafferty.(de)

NOTICE re: 41 Emergency MOTION Temporary Restraining Order. Motion Hearing / Oral Argument set for 4/9/2025 at 02:00 PM before Chief Judge Landya B. McCafferty.(de)

NOTICE of Attorney Appearance by Callan E. Sullivan on behalf of National Education Association-New Hampshire Attorney Callan E. Sullivan added to party National Education Association-New Hampshire(pty:pla).(Sullivan, Callan) (Entered: 04/08/2025)

NOTICE of Attorney Appearance by Lauren Snow Chadwick on behalf of National Education Association-New Hampshire Attorney Lauren Snow Chadwick added to party National Education Association-New Hampshire(pty:pla).(Chadwick, Lauren) (Entered: 04/08/2025)

ORDER granting 37 Motion to Seal Certain Declarations. So Ordered by Chief Judge Landya B. McCafferty.(de) (Entered: 04/08/2025)